Privacy Notice
I. Background
Federal and state regulations require financial institutions to maintain clear, conspicuous and accurate statements of their privacy policies including the information collected about its clients, with whom it shares the information and how it protects the information. The SEC’s Regulation S-P, which is applicable to all Registered Investment Advisers in compliance with Section 504 of the Gramm-Leach-Bliley Act, requires Dimension Capital Management LLC (“DCM”) to distribute this privacy policy to any clients who are natural persons, and the FTC Financial Privacy Rule requires that the private investment funds advised by DCM (“the Funds”) distribute this privacy policy to Fund investors who are natural persons.
II. Overview
DCM looks to protect nonpublic personal data and provides 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 DCM and the Funds.
III. Policy Details
Collection of Information
From time-to-time nonpublic personal information may be collected as required for legitimate business purposes. Personal information is collected from Clients at the inception of their accounts and occasionally thereafter, primarily to determine accounts’ investment objectives and financial goals and to assist in providing Clients with a high level of service. While DCM strives to keep Client information up to date, Clients are requested to monitor any information provided to them for errors. The following are sources of information collected:
a. When an investor enters into an investment advisory contract
b. When clients seek advice from DCM concerning investments;
c. When clients provide DCM with their income information;
d. Transactions with the Funds, including information DCM receives and maintains relating to new investments and other securities transactions with and through the Funds; and written, telephonic or electronic, between investors and DCM.
Disclosure of Information
DCM may share all of the information that we collect, as described above, with our affiliates in order to service investor accounts or provide investors with information about other products and services offered by DCM or our affiliates that may be of interest to them.
In addition, DCM may disclose all of the information that it collects about investors to certain third parties who are not affiliated with DCM under one or more of the following circumstances:
a. As Authorized: if an investor requests or authorizes disclosure of the information.
b. As Required by Law: for example, to cooperate with regulators or law enforcement authorities.
c. As Permitted by Law: for example, sharing information with companies that maintain, process or service the Funds or investor accounts or financial products and services or who effect, administer or enforce Fund or investor transactions is permitted. Among other activities, DCM may share information with persons acting in a representative or fiduciary capacity on a Fund’s or an investor’s behalf. The sharing of information for these purposes is essential to providing investors with necessary or useful services with respect to their accounts.
Information Safeguarding Policy
To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings. DCM restricts access to nonpublic personal information about investors internally to those of our employees and affiliates who need to know the information to enable us to provide our services to investors.