Privacy Policy

INVESTOR PRIVACY IS A PRIMARY CONCERN FOR PCG ASSET MANAGEMENT (“PCG AM”)

This privacy notice is being provided to explain PCG AM’s practices for collecting and disclosing the personal information of Clients to both affiliates of PCG AM and nonaffiliated third parties. For purposes of this privacy notice, an affiliate is an entity that (i) controls PCG AM, (ii) is controlled by PCG AM, or (iii) is under common control with PCG AM. Nonaffiliated third parties are parties who are not affiliates of PCG AM.

Confidentiality of Personal Information

PCG AM maintains the confidentiality of nonpublic personal information that a Client provides to it. PCG AM maintains physical, electronic and procedural safeguards to guard a Client’s nonpublic personal information. All third parties that handle information must agree to follow the standards for confidentiality that PCG AM has established. In addition, all people who work for PCG AM are trained to handle a Client’s information properly in order to maintain its security, and only employees who need to know nonpublic personal information about a Client to provide services to such Client have access to such information.

Categories of Nonpublic Personal Information that the PCG AM Collects

PCG AM collects nonpublic personal information about Clients from the following sources: (i) information it receive from Clients on applications or other forms; and (ii) information about Clients’ transactions with PCG AM, its affiliates, or others.

Disclosure of Nonpublic Personal Information to Affiliates

PCG AM generally may share all of a Client’s nonpublic personal information with PCG AM’s affiliates; provided that such affiliates will be obligated to keep such nonpublic personal information confidential to the same extent as PCG AM. PCG AM shares information with its affiliates in order to serve the Clients better. If a Client prefers that PCG AM not disclose nonpublic personal information about such Client to its affiliates, such Client may opt out of those general disclosures ― that is, such Client may direct PCG AM not to make such disclosures (other than disclosures permitted or required by applicable law or otherwise permitted by PCG AM’s privacy policy). However, notwithstanding any such opt-out, PCG AM will be permitted to disclose personal information to its affiliates to the extent necessary or appropriate for such affiliates to perform services for the benefit of the Client.

Disclosure of Nonpublic Personal Information to Non-affiliates

PCG AM does not sell or market a Client’s personal information to nonaffiliated third parties. PCG AM’s intent is to respect the Clients’ expectations that their personal information will be kept confidential. However, in order to serve the Clients better, PCG AM will disclose personal information to nonaffiliated third parties (including service providers to PCG AM), but only to the extent necessary or appropriate for such third parties to perform services for the benefit of the Client and only if PCG AM believes that such personal information will be kept confidential by such third parties after such disclosure.

Additional Information About Categories of Nonpublic Personal Information that the PCG AM Discloses

Except as required by applicable law and described in this privacy notice, PCG AM will not share any other nonpublic personal information about a Client with its affiliates or nonaffiliated third parties.

Nonpublic Personal Information of Former Investors

This privacy notice, and PCG AM’s policy regarding treatment of nonpublic personal information of Clients, also apply to former Clients.

Changes to Privacy Policy

PCG AM may modify its privacy policy at any time.

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