Privacy Policy

ALGONQUIN ADVISORS LLC
PRIVACY POLICY

Pursuant to applicable federal and/or state privacy regulations Algonquin Advisors LLC (referred to as “Algonquin”) is a financial institution that has determined to keep confidential nonpublic personal information about each Algonquin client.

Nonpublic personal information is defined to mean personally identifiable financial information that is provided by a consumer to a financial institution, results from any transaction with the consumer or any service performed for the consumer, or is otherwise obtained by the financial institution.

Personally identifiable financial information means any information: (1) a consumer provides to a financial institution to obtain a financial product or service; (2) about a consumer resulting from any transaction involving a financial product or service between a financial institution and a consumer; or (3) a financial institution otherwise obtains about a consumer in connection with providing a financial product or service to that consumer. Attached hereto and made a part hereof is a copy of Algonquin’s

Privacy Notice that is to be distributed by Algonquin: (1) initially: (a) to each existing Algonquin client; and (b) to each new client prior to or at the time of establishing a “customer relationship” with Algonquin; and (2) annually thereafter for as long as the client maintains its relationship with Algonquin.

The purpose of Algonquin’s Privacy Notice, Privacy Policy as well as its underlying procedures is to protect the confidentiality and security of its clients’ nonpublic personal information. The categories of nonpublic personal information that Algonquin collects from a client depend upon the scope of the client engagement. It may include information about the client’s personal finances, information about the client’s health to the extent that it is needed for the planning process, information about transactions between the client and third parties, and information from consumer reporting agencies. Algonquin has instituted certain technical, administrative and physical safeguards through which Algonquin seeks to protect this nonpublic personal information about current and former clients from unauthorized use and access. First, technical procedures are used in order to limit the accessibility and exposure of client information contained in electronic form. Second, administrative procedures are used in order to control the number and type of employees, affiliated and nonaffiliated persons, to whom customer information is accessible. Third, physical safeguards have been established to prevent access to client information contained in hard-copy form. As illustrated above, Algonquin realizes the importance of information confidentiality and security, and emphasizes practices which are aimed at achieving those goals.

 

ALGONQUIN ADVISORS LLC
PRIVACY NOTICE

Algonquin Advisors LLC (referred to as “Algonquin”) maintains physical, electronic, and procedural safeguards that comply with federal standards to protect its clients’ nonpublic personal information (“information”). Through this policy and its underlying procedures, Algonquin attempts to secure the confidentiality of customer records and information and protect against anticipated threats or hazards to the security or integrity of customer records and information.

It is the policy of Algonquin to restrict access to all current and former clients’ information (i.e., information and records pertaining to personal background, investment objectives, financial situation, tax information/returns, investment holdings, account numbers, account balances, etc.) to those employees and affiliated/nonaffiliated entities who need to know that information in order to provide products or services to the client. Algonquin may disclose the client’s information if Algonquin is: (1) previously authorized to disclose the information to individuals and/or entities not affiliated with Algonquin, including, but not limited to the client’s other professional advisors and/or service providers (i.e., attorney, accountant, insurance agent, broker-dealer, investment adviser, account custodian, etc.); (2) required to do so by judicial or regulatory process; or (3) otherwise permitted to do so in accordance with the parameters of applicable federal and/or state privacy regulations. The disclosure of information contained in any document completed by the client for processing and/or transmittal by Algonquin in order to facilitate the commencement/continuation/termination of a business relationship between the client and a nonaffiliated third party service provider (i.e., broker-dealer, investment adviser, account custodian, insurance company, etc.), including information contained in any document completed and/or executed by the client for Algonquin (i.e., advisory agreement, client information form, etc.), shall be deemed as having been automatically authorized by the client with respect to the corresponding nonaffiliated third party service provider.

Algonquin permits only authorized employees and affiliates who have signed a copy of Algonquin’s Privacy Policy to have access to client information. Employees violating Algonquin’s Privacy Policy will be subject to Algonquin’s disciplinary process. Additionally, whenever Algonquin hires other organizations to provide services to Algonquin’s clients, Algonquin will require them to sign confidentiality agreements and/or the Privacy Policy. Should you have any questions regarding the above, please contact John Hyman, Chief Compliance Officer. Mr. Hyman may be reached at (203) 629-2114 or via email at jhyman@algonquinadvisors.com.

WHAT DOES ALGONQUIN ADVISORS LLC DO WITH YOUR PERSONAL INFORMATION?

Financial companies choose how they share your personal information. Federal law gives our clients the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.

We do not disclose nonpublic personal information about our clients or former clients to third parties other than as described below.

Personal information we collect. We collect personal information about you in connection with our providing advisory services to you. This information includes your social security number and may include other information such as your:

  • Assets
  • Investment experience
  • Transaction history;
  • Income; and
  • Wire transfer instructions.

How we collect this information. We collect this information from you through various means.

For example when you give us your contact information, enter into an investment advisory contract with us, buy securities (i.e., interests in a fund) from us, tell us where to send money, or make a wire transfer. We also may collect your personal information from other sources, such as our affiliates1

How we use this information. All financial companies need to share customers’ personal information to run their everyday business and we use the personal information we collect from you for our everyday business purposes. These purposes may include for example: or other non-affiliated companies.

  • To provide advisory services to you.
  • To open an account for you.
  • To process a transaction for your account.
  • To market products and services to you.
  • To respond to court orders and legal investigations.

Disclosure to others. We may provide your personal information to our affiliates and to firms that assist us in servicing your account and have a need for such information, such as a broker or fund administrator. We may also disclose such information to service providers and financial institutions with whom we have joint marketing arrangements (i.e., a formal agreement between nonaffiliated financial companies that together market financial products or services to you, such as placement agents). We require third-party service providers and financial institutions with which we have joint marketing arrangements to protect the confidentiality of your information and to use the information only for the purposes for which we disclose the information to them. These sharing practices are consistent with Federal privacy and related laws, and in general, you may not limit our use of your personal information for these purposes under such laws. We note that the Federal privacy laws only give you the right to limit the certain types of information sharing that we do not engage in (e.g., sharing with our affiliates certain information relating to your transaction history or creditworthiness for their use in marketing to you, or sharing any personal information with nonaffiliates for them to market to you).

How we protect your personal information. To protect your personal information from unauthorized access and use, we use security measures that comply with Federal law. These measures include computer safeguards and secured files and buildings.

Who is providing this Privacy Notice. This Privacy Notice relates to the following entities:

  •  Algonquin Advisors LLC
  •  The Algonquin Fund, L.P.
  •  The Algonquin Fund, Ltd.
  •  Global Equity Access Fund, L.P.
  •  Algonquin Special Opportunities Fund I, L.P.
  •  Algonquin Middle Market Opportunities Fund, L.P.
  •  AMMOF LTD
  • AMMOF AIV

Who to contact with questions. If you have any questions about this Privacy Notice, call John A. Hyman at 203-629-2114.