Privacy Policy

As may be required under the Gramm-Leach-Bliley Act and its implemented regulations, as applicable, the purpose of this notice is to inform you of our policies and practices concerning how we handle, protect and limit the use of non-public personal information that we collect and maintain to service and administer your business with one or more of our collective investment vehicles (each, a “Fund,” and your investment herein, an “Interest”) for which Kudy Financials LLC (“Kudy”) serves as investment advisor and certain affiliates of Kudy provided distribution and/or other services (collectively “Kudy”, and, as applicable, the managing member of such Funds(s), together with such Fund(s) “we” or “us”). The security of personal information about you is our priority. To protect your personal information from unauthorised access and use, we use security measures that comply with federal law. The measures include computer safeguards and secured files and buildings.

We train our employees in the proper handling of personal information. When we use other companies to provide services for us, we require them to protect the confidentiality of personal information they receive from us.

In connection with Kudy’s distribution of third-party products, we collect and maintain personal information, including non-public personal information, about you from the following sources:

1. Information received from you on subscription documents, investor questionnaires and other forms.
2. Information about your transactions with us and our affiliates.
3. Information we receive about you from other sources, including unaffiliated third parties; and
4. Information we receive about you from consumer reporting agencies.

Personal information that we collect generally will include, but is not necessarily limited to:

1. Contact information (eg, name, address, phone number, fax, email address).
2. Identifying information (e.g., Social Security number, passport or driver’s license number, other government-issued identification);
3. Professional information (e.g., employer, role or title, business address); and
4. Financial information (e.g., financial account numbers).

We will use such personal information for everyday business purposes, such as to process transactions, maintain accounts, respond to court orders and legal investigations, and otherwise as may be disclosed in the offering materials provided to you and the agreement you enter into in respect of the third-party products offered to you.

Whether you are a current or former investor in third-party products or services, we will not disclose personal information about you you except (i) to our employees and affiliates on a need-to-know basis, which includes personnel who need to know such information to comply with applicable anti-money laundering laws and customer identification requirements, and (ii) to sponsors of third-party products, and their advisers and service providers, as may be required to satisfy any legal, regulatory or compliance requirements of such persons. Your personal information, once disclosed to sponsors of third-party products, their advisers and service providers or otherwise to facilitate your investment in such third-party products, is not subject to the control of Kudy, and Kudy accepts no responsibility for the use or misuse of such information by such persons. You should carefully consider/review all offering materials concerning such third-party products and your rights and obligations thereunder.

Your personal information may also be subject to disclosure to the following third parties:

1. Financial service providers, non-financial companies, and other service providers or other non-affiliated companies in connection with services provided to Kudy, such as those provided by any administrators, auditors, tax advisers, legal advisers or other Kudy service providers; and
2. Government agencies, regulatory authorities, court and the like as necessary, required or advisable.

In each such case, Kudy’s disclosure of any of your non-public personal information will be subject to customary undertakings of confidentiality. We do not sell your personal information.

We have collected some or all of the following categories of personal information from individuals within the last twelve (12) months:

1. Identifiers: such as name, contact details and address (including physical address, email address and Internet Protocol address), and other identification (including social security number, passport number and driver’s license or state identification card number);
2. Other Customer records: such as telephone numbers, signature, bank account number, other financial information (including accounts and with other institutions and anti-money laundering information), and verification documentation and infoirmation regarding investor’s status under various laws and regulations (including social security number, tax status, income and assets);
3. Protected classification characteristics: Protected classification characteristics under California or federal law, such as date of birth, citizenship and birthplace;
4. Commercial information, such as account data and other information contained in any document provided by investors to authorised service providers (whether directly or indirectly), risk tolerance, transaction history, investment experience and investment activity, information regarding a potential and/or actual investment in the applicable fund(s), including ownership percentage, capital investment, income and losses, sources of fund used to invest in the applicable fund(s); and
5. Internet or other electronic network activity information, such as information regarding your use of our website, client portal or mobile app (e.g., cookies, browsing history and/or search history), as well as information you provide to us when you correspond with us in relation to inquiries.

Within the last twelve (12) months, for a business purpose, we have shared each of the categories of personal information and sensitive personal information collected with affiliates and third-party service providers as outlined in “Disclosure of Information” in the Privacy Notice above. We do not collect or process Sensitive Personal Information for inferring characteristics about a customer.

Purposes of Collecting Personal Information and Sensitive Personal Information: We may collect or share personal information we collect about you for one or more of the following business or commercial purposes:

• Performing services to you, including but not limited to:
  • The administrative processes (and related communication) in preparing for the admission of investors to the fund(s).
  • Ongoing communication with potential investors, their representatives, advisors and agents (including the negotiation, preparation and signature of documentation) during the process of admitting potential investors to the fund;
  • The performance of obligations under the governing documents of the funds (and all applicable anti-money laundering, KYC and other related laws and regulations) in assessing the suitability of potential investors in the applicable fund;
  • Ongoing operations, administrative, accounting, reporting, account maintenance and other processes and communication required to operate the business of the funds following its governing documents and other documentation between the parties, including customer service, processing or fulfilling transactions, verifying personal information, processing contributions and distributions and financing;
  • Keeping investors informed about the business of the general partner or managing member of the applicable fund and its affiliates generally, including offering opportunities to make investments and other than to the applicable fund and related advertising;
    • Auditing and verifications related to investor interactions, including but not limited to verifying the quality and effectiveness of services and compliance;
    • Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity; and
    • Complying with U.S., state, local and non-U.S. laws, rules and regulations.

We do not sell and have not sold within the last 12 months any of the personal information and sensitive personal information we collect about you to anyone.
We do not knowingly sell or share the personal information of consumers under 16 years of age.

You have the right to request that we disclose to you certain information regarding our collection, use, disq and sale of personal information specific over the last (12) twelve months. Such information includes:

• The categories of personal information we collect about you;
• The categories of sources from which the personal information is collected.
• Our business or commercial purpose for collecting, selling or sharing such personal information;
• Categories of third parties with whom we share the personal information;
• The specific pieces of personal information we collect about you; and
• Whether we disclose your personal information to a third party, and if so, the categories of personal information that each recipient obtained.