PRIVACY NOTICE OF BRENTON POINT CAPITAL PARTNERS, LLC
Pursuant to the Gramm-Leach-Bliley Act, Public Law No. 106-102, and the rule issued by the Federal Trade Commission regarding the Privacy of Consumer Financial Information, 16 C.F.R. Part 313 (the “FTC Privacy Rule”), institutions that provide certain financial products or services to individuals to be used for personal, family, or household purposes are required to provide written notices to their customers regarding disclosure of nonpublic personal information. This notice is being provided to you to comply with the FTC Privacy Rule.
Personal information we collect. In order to accurately and efficiently conduct our business, we must collect and maintain certain non-public information about our investors. This information includes your name, address, email address, and social security or tax identification number, and may include other information such as information about your investments with us that you provide in your subscription documents, partnership agreements, and other forms.
How we collect this information. We collect this information from you through various means. We may collect this information from you through pre-qualification questionnaires, subscription agreements, account applications, or similar forms. We collect information from you when you give us your contact information, or subscribe for our services. We also may collect your personal information from other sources, such as our affiliates or other non-affiliated companies.
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:
- To provide information to you about your investments.
- To process your subscription or the withdrawal of your investment;
- To prevent fraud or other financial crime in accordance with our internal policies and regulatory requirements, including to identify and prevent money laundering and terrorist financing;
- To respond to court orders, regulatory inquiries, and legal investigations; and
- To market our products and services to you.
How we share your information. We do not disclose any nonpublic personal information about our investors or former investors to anyone other than our affiliates and service providers, except as permitted by law and as described in the following sentences. Our service providers include, for example, our attorneys, accountants, auditors, administrators, entities that assist us with the distribution of stock to our investors and placement agents for future fundraising activities. Consistent with industry practice (and the provisions of our fund agreements), we may distribute certain personal information of investors in a fund, such as their names and contact information, to other investors in that fund. We may also disclose certain personally-identifiable financial information such as the names of investors and the amount of their capital commitments to the portfolio companies of the fund (including prior to the General Partner’s acceptance of the subscription agreement). Furthermore, we may be required by law to provide to self-regulatory organizations, state governments, and the federal government information about the identity of our investors as well as their individual receipts of income and gross proceeds.
In connection with fundraising efforts for future funds, we may disclose information about existing investors to one or more placement agents for use in marketing efforts, including communication with prospective future investors.
How we protect your personal information. We restrict access to nonpublic personal information about you to those employees who need to know that information to provide services to the fund and its investors. We maintain physical, electronic, and procedural safeguards to guard your nonpublic personal information.
Who is providing this Privacy Notice? Brenton Point Capital Partners, LLC is providing this Privacy Notice.
Who to contact with questions? If you have any questions about this Privacy Notice, please contact info@brentonpointcp.com, or write to us at the address below.
169 Madison Ave, Suite 1145
New York, New York, 10016
