Efficient Capital Management®, LLC (“Efficient” or “we”) is committed to protecting the privacy of investors’ nonpublic personal information (personal information). Personal information is nonpublic information about a natural person that is personally identifiable and that we obtain in connection with providing a financial product or service to investors.
This Privacy Policy describes the personal information that we collect about investors, and our treatment of that information. Efficient collects personal information about investors or other persons from the following sources:
Information we receive from an investor in the applicable fund’s (the Fund) subscription documents and related forms and documents and other information provided by the investor in writing, in person, electronically or by any other means. Such information, includes, for example, name, contact information (address, email, phone number), social security or taxpayer identification number, occupation, birth date, assets, income and investment experience;
Information about an investor’s transactions with us, the Fund, their affiliates or others (for example, account activity and balances);
Consumer reporting and similar agencies, for example, information regarding an investor’s credit history and creditworthiness (although the Fund does not generally utilize such services); and
Information from persons who request to receive information from Efficient, such as newsletters, updates and account information, including name, contact information (address, email, phone number) assets, income and investment experience, as applicable.
We do not disclose any personal information we collect, as described above, about our investors or former investors or other persons other than in connection with the administration, processing and servicing of investor accounts or to our accountants, attorneys, auditors and other professional advisers, or otherwise as permitted or required by applicable law, rules and regulations.
We restrict access to personal information we collect about investors and other persons to affiliated and non-affiliated personnel 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 the Fund. We maintain physical, electronic and procedural safeguards to protect nonpublic personal information, and will destroy, erase or make unreadable data, computer files and documents containing nonpublic personal information prior to disposal.
Efficient may change this Privacy Policy. Please note that the examples provided above are merely illustrative and are not intended to be all inclusive. You may have additional rights under other foreign or domestic laws that may apply to you. If you have any questions about this Privacy Policy, please contact Efficient at +1 630 657 6800 or compliance@efficient.com.