This Privacy Notice generally describes the personal information that Efficient collects about investors and other persons, and Efficient’s treatment of that information, and will be given to Efficient’s investors as required by applicable law.
I. Categories of Information Efficient May Collect
Efficient collects personal information about investors or other persons from the following sources and for the following purposes:
(i) Personal information Efficient receives from an investor in a Fund’s subscription documents and related forms and documents for the purpose of making an investment in or redemption from a Fund. Such information, may include, for example, name, contact information (address, email, phone number), social security or taxpayer identification number, occupation, birth date, assets, income, investment experience, and bank account information;
(ii) Personal information about an investor’s transactions with a Fund. Such information may include, for example, account activity and balances;
(iii) Personal information from persons (such as prospective investors or other members of the public) who request to receive information from Efficient, such as newsletters, updates and other basic information on Efficient. Such information may include, for example, name, contact information (address, email, phone number) assets, income and investment experience.
II. Categories of Information Efficient May Disclose
Efficient does not disclose any personal information it collects, as described above, about its current or former investors or other persons except as necessary to administer, process and service investor accounts; to effect, administer or enforce transactions requested or authorized by an investor; to Efficient’s fund administrators, custodians, accountants, attorneys, auditors, information technology providers, cybersecurity providers and other service providers and professional advisers that need the information to perform services for or on behalf of Efficient or a Fund; or otherwise as permitted or required by applicable law, rules and regulations. As such, Efficient does not share personal information in a manner that gives rise to “opt-out” rights under the U.S. Securities and Exchange Commission’s Regulation S‑P requirements.
III. Safeguards, Confidentiality, and Security of Information
Efficient restricts access to personal information it collects about investors and other persons to employees and service providers who need to know that information in order to provide products or services for the benefit of such investor or person and in connection with the administration and operations of Efficient and a Fund. Efficient maintains administrative, technical, physical, electronic and procedural safeguards reasonably designed to protect personal information against anticipated threats or hazards and unauthorized access to or use of such information. Efficient also maintains written policies and procedures reasonably designed to detect, respond to and recover from unauthorized access to or use of nonpublic personal information, including procedures to assess, contain and control security incidents, oversee service providers that have access to personal information, as well as policies and procedures regarding the maintenance of records.
IV. Privacy Notice Changes, Legal Rights, and Contact Information
Efficient may update or change this Privacy Notice. Please note that the examples provided above are merely illustrative and are not intended to be all inclusive. This Privacy Notice is qualified in its entirety by Efficient’s other relevant policies and procedures. You may have additional rights under other laws or regulations that may apply to you. In addition, if Efficient becomes aware of unauthorized access to or use of sensitive customer information relating to you as an investor, Efficient will provide any notice of such unauthorized access as may be required by applicable law. If you have any questions about this Privacy Notice, please contact Efficient at 630.657.6800 or compliance@efficient.com.