Madison Street Partners, LLC
Our Commitment to You
When you become a client of Madison Street Partners (“we” or “us”), either through a separate account or a pooled investment product, you entrust us with not only your hard-earned money but your personal and financial data as well. We recognize that your relationship with us is based on trust, and that you expect us to act responsibly and in your best interests. Because your personal and financial data is your private information, we hold ourselves to the highest standards in its safekeeping and use.
This means, most importantly, that we do not sell client information — whether it is your personal information or the fact that you are an investor with us — to anyone.
Instead, we use your information primarily to complete transactions that you request or to make you aware of other financial products and services offered by us or our affiliates.
The Information We Collect About You
You typically provide personal information when you complete our client documentation materials, our subscription materials, when you request a transaction that involves an investment in one of our products, or when you visit our website and your browser interacts with our website. This information may include your:
- Name and address
- Social Security number or taxpayer identification number
- Capital contributions
- Other information about your prior investment history
How We Handle Your Personal Information
As emphasized above, we do not sell information about current or former clients or their accounts to third parties. Nor do we share such information, except when necessary to complete transactions at your request or to make you aware of related financial products and services offered by us or our affiliates. Here are the details:
- To complete certain transactions or changes that you direct, we may be required to provide identifying information to companies, individuals, or groups that are not affiliated with us. For example, if you ask to transfer assets from another financial institution to one of our separate accounts or pooled investment products, we may need to provide certain information about you to that institution to complete the transaction.
- To alert you to other financial products and services, we may share your information within our family of affiliated companies. This would include, for example, sharing your information within our family so we can make you aware of new investment products and asset management services.
- In certain instances, we may contract with nonaffiliated companies to perform services for us. Where necessary, we will disclose information we have about you to these third parties. In those situations, we provide the third party with only the information necessary to carry out its assigned responsibilities and only for that purpose. And, we require these third parties to treat your private information with the same high degree of confidentiality that we do.
- Finally, we will release information about you if you direct us to do so, if we are compelled by law to do so, or in other legally limited circumstances (for example, to protect you from fraud).
How We Safeguard Your Personal Information
We restrict access to information about you to those of our employees who need to know the information to provide products or services to you. We maintain strict physical, electronic, and procedural safeguards to protect your personal information. We have adopted written policies and procedures providing for the proper disposal of, and reasonable measures to protect against, unauthorized access to, or use of, your information in connection with its disposal.
We’ll Keep You Informed
Adopted: April 15, 2004; revised June 1, 2005; further revised May 17, 2007; further revised January 5, 2008.
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APPROVED FOR AND ADOPTED BY MADISON STREET PARTNERS, LLC