January 1, 2021
TABLE OF CONTENTS
- SECTION 1. FIRM POLICY
- SECTION 2. COLLECTION OF PERSONAL INFORMATION
- SECTION 3. USE OF PERSONAL INFORMATION
- SECTION 4. PROTECTING YOUR PERSONAL INFORMATION
- SECTION 5. DISCLOSURE OF PERSONAL INFORMATION
- SECTION 6. CAN-SPAM ACT OF 2003
- SECTION 7. CALIFORNIA PRIVACY RIGHTS
- SECTION 8. INTERNATIONAL TRANSFERS OF DATA
- SECTION 9. CHILDREN’S PRIVACY
- SECTION 10. CHANGE OF CONTROL
- SECTION 11. POLICY CHANGES
- SECTION 12. CONTACT INFORMATION
SECTION 1. FIRM POLICY
SECTION 2. COLLECTION OF PERSONAL INFORMATION
When you interact with us, we may collect information about you (“Personal Information”) in subscription agreements, investor questionnaires, applications or other forms. You may also provide us Personal Information in your correspondence and transactions with us by phone, mail, e-mail or other electronic means. Please note that when you are no longer our customer, we may continue to share your information as described in this notice. We may collect your information from third party service providers, such as broker-dealers, screening companies, investor placement entities, or public databases, who perform services on our behalf or at your request to verify or supplement our information.
Specifically, we may collect the following categories of information:
- Contact information, such as name, address, email, telephone number;
- Identification information, such as signature, date of birth, social security number, taxpayer identification number, driver’s license, passport, or other government identification;
- Background information, such as information revealed in information you provide to us in response to our know-your- customer (KYC) and anti-money laundering (AML) inquiries;
- Financial information, such as assets, income, net worth, investment amounts and history, transaction information, tax information
SECTION 3. USE OF PERSONAL INFORMATION
We use the information we collect primarily to enable us to provide our services to you in the best possible manner. In addition, we may use your Personal Information as follows:
- To fulfill your requests for financial and investment products and services offered and subscribed or accepted by you, through any medium of communication;
- To deliver to you any administrative notices, advice and communications relevant to your use of our products or services;
- To analyze the website usage and improve the services offered;
- For market research, project planning, troubleshooting problems; and
- For detecting and protecting against error, fraud or other criminal activity.
SECTION 4. PROTECTING YOUR PERSONAL INFORMATION
To protect the Personal Information of individuals, we permit access only by authorized employees who need access to that information to provide services to us and to you. To guard investors’ Personal Information, we maintain physical, electronic and procedural safeguards that comply with applicable federal and state standards. Your right to privacy extends to all forms of contact with us, including telephone, written correspondence and electronic media. We have developed procedures to protect the integrity of your information. These procedures include:
- Restricting physical and other access to your Personal Information to persons with a legitimate business need to know the information in order to service your account;
- Confirming that third parties doing business with us to keep your Personal Information confidential and secure and to use it only as authorized by us;
- Providing information to you only after we have used reasonable efforts to assure ourselves of your identity;
- Maintaining reasonably adequate physical, electronic, and procedural safeguards to protect your information; and
- Disposing of Personal Information in a secure manner.
SECTION 5. DISCLOSURE OF PERSONAL INFORMATION
Affiliates and Service Providers. We may share your information that we collect with our subsidiaries, affiliates, third-party service providers, or any subcontractors as required to offer you our products and services. This may include asset managers, financial services providers, non-financial companies, and others. Any such affiliate or third party service provider of ours who we disclose information to is required to maintain the confidentiality of your Personal Information and only use your Personal Information for purposes that we have agreed to permit.
We may share your information that we collect with third parties who provide services to you, which services are related to our products and services. For example, if you made an investment in one of our funds with the assistance of your investment adviser or similar professional, we may share your information on an on-going basis with that adviser in the course of providing services to you relating to your investment in our fund. We use our best efforts to share your information only with third parties of this sort who we reasonably believe have a service relationship with you (which may be direct or indirect) and only where we believe that such sharing would a beneficial or helpful to you. We typically do not have any contractual relationships with these types of third parties. As such, we do not control how they use your information. These third parties will have their own privacy policies and we do not accept any responsibility or liability for these policies. Please check these third party policies before you submit any information to these third parties.
Disclosures Required by Law. We may be required to disclose your data in response to lawful requests by public authorities, including to meet law enforcement requirements. We may be under a duty to disclose or share your personal data in order to comply with any legal obligation, to enforce or apply our terms and conditions and other agreements, to protect our rights, property, or safety, or the protect the rights, property, or safety of others. This includes exchanging information with other companies and organizations for the purposes of fraud protection.
SECTION 6. CAN-SPAM ACT OF 2003
The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations. We collect your email address in order to deliver important updates and communication about our products and services.
- To be in accordance with CAN-SPAM we agree to do the following:
- NOT use false, or misleading subjects or email addresses
- Identify the message as an advertisement in some reasonable way
- Include the physical address of our business or site headquarters
- Honor opt-out/unsubscribe requests quickly
- Allow users to unsubscribe by using the link at the bottom of each email.
If you would like to stop receiving our emails, please follow the instructions at the bottom of each email to unsubscribe.
SECTION 7. CALIFORNIA PRIVACY RIGHTS
If you are a California consumer, you have the following rights:
- The right to know what Personal Information is being collected about you.
- The right to know whether your Personal Information is sold or disclosed and to whom.
- The right to say no to the sale of Personal Information.
- The right to access your Personal Information.
- The right, in certain circumstances, to delete the information you have provided to us.
- The right to equal service and price, even if you exercise your privacy rights.
Request for Information. California consumers have the right to request, up to twice in a 12-month period, that a business that collects Personal Information about the consumer disclose to the consumer the information listed below for the preceding 12 months. We have the right to request verification of your identity for all requests for information.
- The categories of Personal Information it has collected about that consumer.
- The categories of sources from which the Personal Information is collected.
- The business or commercial purpose for collecting or selling Personal Information.
- The categories of third parties with whom the business shares Personal Information.
- The categories of Personal Information that the business sold about the consumer and the categories of third parties to whom the Personal Information was sold, by category or categories of Personal Information for each third party to whom the Personal Information was sold.
- The categories of Personal Information that the business disclosed about the consumer for a business purpose.
- The specific pieces of Personal Information it has collected about that consumer. To make such a request, please call us at (407) 476-5453 or visit this webpage https://www.commongoodcap.com.
Do Not Sell My Personal Information. California consumers have the right to opt out of the sale of the consumer’s Personal Information. To make such a request, please call us at (407) 476-5453 or visit this webpage https://www.commongoodcap.com.
Third Party Marketing. California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your Personal Information to third parties for the third parties’ direct marketing purposes. To make such a request, please contact us at (407) 476-5453 or visit this webpage https://www.commongoodcap.com.
SECTION 8. INTERNATIONAL TRANSFERS OF DATA
If you are accessing our website or apps from outside of the United States, any data that you provide to us will be accessed, shared or processed by our offices, located in the United States, and service providers located in the United States, if such data transfer is necessary for the specific purpose for which you submitted your data (such as the provision of goods or services under a written contract).
This may entail a transfer of your Personal Information across international borders into the United States. The data protections standards may differ and be lower than the standards enforced in your jurisdiction.
SECTION 9. CHILDREN’S PRIVACY
Our website is not directed at individuals under the age of 18. We do not knowingly collect Personal Information from children under 18. If you become aware that a child has provided us with Personal Information, please contact us at the following toll-free number (407) 476-5453 or visit this webpage https://www.commongoodcap.com. If we become aware that a child under 18 has provided us with Personal Information, we will take steps to delete such information.
SECTION 10. CHANGE OF CONTROL
Personal Information may be transferred to a third party as a result of a sale, acquisition, merger, reorganization or other change in control. If we sell, merge or transfer any part of the business, part of the sale may include your Personal Information.
SECTION 11. POLICY CHANGES
SECTION 12. CONTACT INFORMATION