TOWER ARCH CAPITAL, LP
PRIVACY NOTICE
As required under applicable federal law, this notice informs you of the privacy policies of Tower Arch Capital LP and its affiliated investment funds (collectively referred to as “Tower Arch”). Tower Arch does not disclose non-public personal information about its clients, investors, former clients or investors to third parties other than as described below.
As you know, Tower Arch may obtain information about you in connection with the advisory/investment management services that Tower Arch provides to you or in the normal course of its formation, operation and dissolution of Tower Arch. This information may include, but is not limited to, your name, address, social security number, tax identification number, net worth, total assets, income, capital account balances, account data, information about participation in other investments, and other financial information necessary to determine required accreditation standards as well as financial sophistication. This information may be obtained through discussions, documentation, such as subscription agreements or advisory service agreements, and in the course of the advisory services Tower Arch provides to you and in the course of transactions between the Limited Partners and Tower Arch. Tower Arch may use this non-public personal information to provide investment management/advisory services to you, which can include the opening of accounts and other actions necessary to effect your advisory transactions. In connection with providing you with such services and effecting client transactions, Tower Arch may provide your personal information to its affiliates and other firms that assist Tower Arch in providing you with advisory services. It should be noted that Tower Arch requires or will require all such service providers and other financial institutions (that Tower Arch discloses your personal information to) to protect the confidentiality of your non-public information and to use or share such information only for the purposes for which it was disclosed to them. Even after Tower Arch has paid all distributions associated with your investment, we may continue to share your information as described in this notice.
Federal law gives you the right to limit only:
sharing for affiliates’ everyday business purposes;
affiliates from using your information to market to you;
sharing for non-affiliates to market to you.
State laws may provide additional rights to limit sharing.
In order to generally ensure that your non-public personal information is safeguarded, Tower Arch has also adopted the following internal procedures:
(a) access to non-public personal information is restricted to employees and service providers that need to access such information in order to engage in business activities on behalf of Tower Arch;
(b) hard-copies of documents containing non-public personal information are kept in a secured environment; and
(c) electronic files containing non-public personal information are contained in a secure database accessible to only individuals who have a business need for such information.
Additionally, Tower Arch’s disposal of non-public personal information shall be done in a secure manner.
Except as noted above, Tower Arch does not, and will not, provide non-public information about you to outside firms, organizations, groups or individuals except to Tower Arch’s attorneys, accountants, auditors, broker-dealers, custodians, transfer agents in the normal course of its formation, operation and dissolution of Tower Arch, and as required or permitted by law.
In all events, the Fund may disclose Limited Partner information: (x) to other Limited Partners as required or permitted under the Partnership Agreement; and (y) as otherwise required by applicable law.
The foregoing privacy notice reflects a privacy policy that has been adopted by the General Partner. It may be updated from time to time upon notice to the Limited Partners.
Please contact Christian Little, Tower Arch’s Chief Compliance Officer, at 801-997-5808 or clittle@towerarch.com with any questions regarding this policy.