Your privacy is very important to us. Set forth below are the policies of Spring Mountain Capital, LP (“SMC”) and its funds and managed accounts with respect to non-public personal information about our investors and managed account clients, and prospective and former investors and managed account clients. These policies apply to investors in our funds and managed accounts and may be changed at any time, provided a notice of such change is given to you.
You provide us with personal information, such as your address, Social Security number, assets and/or income information (i) in the subscription agreement (in the case of funds) or investment management agreement (in the case of managed accounts) and related documents; (ii) in correspondence and conversations with SMC’s representatives; and (iii) through transactions with SMC, its funds and managed accounts.
We do not disclose any of this personal information about our investors and managed account clients, and prospective and former investors and managed account clients, to anyone other than to our affiliates and except as permitted by law, such as to our accountants, attorneys, auditors, brokers, regulators and certain service providers, in each case, only as necessary to facilitate the acceptance and management of your investment or account and our relationship with you. We will also release information about you if you direct us to do so, if compelled to do so by law, or in connection with any government or self-regulatory organization request or investigation. For example, it may be necessary, under anti-money laundering and similar laws, to disclose information about our investors and managed account clients in order to accept subscriptions from them.
Each investor acknowledges that, under Delaware law, other investors in funds managed by SMC may be entitled to review the books and records of such funds and are entitled to see a list of investors and their capital commitments or capital contributions. Each investor explicitly consents to disclosure of the fact of his or her investment in such fund, his or her mailing address and his or her capital commitment or capital contribution to other investors in the relevant fund.
We may also disclose information you provide to us to companies that perform marketing services on our behalf, such as a placement agent. If such a disclosure is made, we will require such third parties to treat your private information with confidentiality.
We seek to carefully safeguard your private information and, to that end, restrict access to non-public personal information about you to those employees and other persons who need to know the information to enable SMC to provide services to you. We maintain physical, electronic and procedural safeguards to protect your non-public personal information from unauthorized use.
For questions concerning our policy, please contact the Compliance Department at 212-292-8300, or write to Spring Mountain Capital, LP, Attn: Compliance Department, 650 Madison Avenue, 20th Floor, New York, NY 10022.