We maintain physical and electronic security measures to safeguard nonpublic personal information from unauthorized access by implementing strict confidentiality policies and procedures. These safeguards include measures such as access controls, secure passwords, as well as encrypted file storage and transmission. Employees are obligated to adhere to these policies, and are trained on their responsibilities to protect client information.

In the normal course of providing products and services to our clients or investors, it may be necessary for us to disclose specific client or investor information (i) to companies or organizations which provide certain products or services on our behalf, (ii) in a limited capacity to other broker-dealers or financial institutions with whom we have joint marketing agreements, (iii) to regulatory agencies or (iv) as may be permitted or required by law. Some specific examples of circumstances where certain nonpublic personal information may be made available to non-affiliated third-party companies or organizations include:

• In connection with the private placement of securities (i) to establish compliance with federal or state securities or other laws, and (ii) to obtain a facility for financing investors’ unpaid obligations to related private funds. Specific requirements or exceptions, if applicable, are disclosed to investors in the Private Placement Memorandum and/or related Partnership Agreement and Subscription Materials for a particular investment.
• In connection with managing liquid asset portfolios (i) to perform services for our clients’ accounts where we have obtained the services of a third-party provider, such as custodial services, aggregated reporting or financial planning, (ii) to effect transactions in our client’s accounts.
• In connection with the provision of insurance products, pursuant to policy application, underwriting and delivery processes.

Outside of these types of circumstances, we do not disclose confidential and nonpublic personal information about our clients to third parties.

Unaffiliated third-party organizations which provide services to or for us are contractually obligated to maintain confidentiality concerning nonpublic personal client information.