This explains the manner in which Schneider Capital Management (“SCM”) and its affiliate Turnbridge Management Partners (together with SCM referred in this policy as “we” or “our”) collects, utilizes, and maintains nonpublic personal information about prospective, existing or former investors (collectively, “Investors”). This policy applies only to Investors that fall within the definition of “customer or consumer” under Regulation S-P.
We respect our Investor’s right to privacy and we are committed to maintaining and safeguarding nonpublic information. To manage Investors in a professional and efficient manner, we must from time to time obtain and disclose certain nonpublic personal information about an Investor. To protect the confidentiality of such information while making the necessary disclosures, we have developed the security policies described below.
I. Information Collected
We collect nonpublic personal information about Investors through subscription agreements, investor questionnaires, and email communication with Investors and their custodians. This generally includes your name, address, social security number, financial circumstances, employment, account balances and transactions and bank account numbers.
II. Information Disclosed
We will only disclose nonpublic personal information to third parties as permitted by applicable law, including administrators, accountants, auditors, broker-dealers and custodians that we need to use to provide services to you.
III. Security Procedures
Any service provider receiving an Investor’s personal information will be authorized to use such information only to perform the services required of them on our behalf and then only as permitted by applicable law. We restrict access to nonpublic personal information to those employees who require access to provide services to our affiliates and Investors. We maintain physical, electronic and procedural safeguards to guard Investor nonpublic personal information. An Investor’s right to privacy extends to all forms of contact with us including telephone, written correspondence and electronic media.