EFM INVESTMENTS & ADVISORY, LLC
REQUIRED DISCLOSURES TO INVESTORS
General
Federal and state regulations require financial institutions to maintain clear, conspicuous and accurate statements of their privacy policies including the information collected about their clients, with whom they share the information and how they protect the information. FTC Financial Privacy Rule requires EFM Investments & Advisory, LLC. (“EFM”) and each private investment fund (including the Fund) advised by EFM to distribute this privacy policy to Fund investors who are natural persons.
Overview
EFM and the Fund (“we” or “us”) look to protect nonpublic personal data and provide this policy to clients and investors regardless of whether they are natural persons. The policy set forth below is intended to be compliant with the federal and state regulations as applied to EFM and the Fund.
Privacy Policy Details
- Collection of Information. From time to time non-public personal information may be collected as required for legitimate business purposes. The following are sources of information collected:
- Subscription Agreements, investor questionnaires and other forms, which may include an investor’s name, address, Social Security number and personally identifiable financial information such as personal income and bank account information;
- Account history, including information about an investor’s capital account, such as capital contributions, profit and loss allocations and distributions and withdrawals to and from the Fund;
- Transactions with the Fund, including information EFM receives and maintains relating to transactions with and through the Fund; and
- Correspondence, written, telephonic or electronic, between investors and EFM, any of EFM’s affiliates or any Fund service providers.
In addition to the sources listed above, EFM and the Fund may also collect this information from our Web sites.
• Disclosure of Information. EFM and the Fund may share all of the information that we collect, as described above, with our affiliates in order to service investor accounts.
In addition, EFM and the Fund may disclose all of the information that we collect about investors to certain third parties who are not affiliated with EFM or the Fund under one or more of the following circumstances:
- As Authorized – if an investor requests or authorizes disclosure of the information.
- As Required by Law – for example, to cooperate with regulators or law enforcement authorities.
- As Permitted by Law – for example, sharing information with companies that maintain, process or service Fund or investor accounts or financial products and services or that effect, administer or enforce Fund or investor transactions is permitted. Among other activities, EFM may share information with persons acting in a representative or fiduciary capacity on a Fund’s or an investor’s behalf. EFM believes that sharing of information for these purposes is essential to providing investors with necessary or useful services with respect to their accounts.
Information Safeguarding Policy
EFM and the Fund restrict access to non-public personal information about Fund investors internally to those of our employees and our agents (e.g., auditors, attorneys and accountants) who need to know the information to enable us to provide our services to Fund investors. EFM maintains physical, electronic and procedural safeguards to guard an investor’s non-public personal information.