At GRT Capital Partners, L.L.C. (“GRT Capital”), we can receive nonpublic personal information from investors in private investment funds we manage, from clients who enter into investment management agreements with us, and from general inquiries. We receive this information from subscription agreements, investment management agreements, and accredited investor questionnaires, as well as from ongoing account activity. We have designed policies and practices to safeguard nonpublic personal information from such sources who are natural persons deemed to be customers or consumers of GRT Capital under the applicable regulations (“Covered Persons”).
We do not disclose any nonpublic personal information about Covered Persons to anyone, except as required or permitted by law or as necessary in order to process or service their accounts. Access is provided to third party service providers, unaffiliated with us, who need to know that information in connection with providing services relating to the account. For example, access is provided to the accountants and brokers who provide services to the private investment funds we manage. GRT Capital and its affiliates may also use nonpublic personal information to market their own products to Covered Persons.
We also maintain physical and electronic safeguards consistent with industry standards to protect the nonpublic personal information.