H/L Ventures considers customer privacy to be an essential part of our investor relationships and is committed to maintaining the confidentiality, integrity and security of our current, prospective and former investors’ non-public personal information. H/L Ventures have developed policies that are designed to protect this confidentiality, while permitting investor needs to be served.
Obtaining Personal Information. While providing investors with products and services, H/L Ventures, and certain service providers, such as the H/L Ventures’ Transfer Agents and/or Administrators, may obtain non-public personal information about investors, which may come from sources such as (i) account applications, subscription agreements and other forms, (ii) written, electronic or verbal correspondence, (iii) investor transactions, (iv) an investor’s brokerage or financial advisory firm, financial advisor or consultant, and/or (v) from information captured on applicable websites. The non-public personal information that may be collected from investors may include the investor’s name, address, tax identification number, birth date, investment selection, beneficiary information, and possibly the investor’s personal bank account information and/or email address if the investor has provided that information, as well as the investor’s transaction and account history with H/L Ventures.
Respecting Your Privacy. H/L Ventures reserves the right to report or disclose personal or account information to third parties in circumstances where H/L Ventures believes in good faith that disclosure is required or permitted under law, to cooperate with regulators or law enforcement authorities, or to protect its rights or property. In addition, H/L Ventures may disclose information about an investor or an investor’s accounts to a third party at the investor’s request or with the consent of the investor.
Sharing Information with Third Parties. H/L Ventures reserve the right to report or disclose personal or account information to third parties in circumstances where H/L Ventures believe in good faith that disclosure is required or permitted under law, to cooperate with regulators or law enforcement authorities, to protect their rights or property, or upon reasonable request by H/L Ventures in which an investor has invested. In addition, H/L Ventures may disclose information about an investor or an investor’s accounts to a third party at the investor’s request or with the consent of the investor.
Procedures to Safeguard Private Information. H/L Ventures is committed to its obligations to safeguard investor non-public information. In addition to this policy, H/L Ventures has implemented procedures that are designed to limit access to an investor’s non-public personal information to internal personnel who require the information to complete tasks, such as processing transactions, maintaining client accounts or otherwise providing services the investor requested. Physical, electronic and procedural safeguards are in place to guard an investor’s non-public personal information.
Information Collected from Websites. Websites maintained by H/L Ventures or its service providers may use a variety of technologies to collect information that helps H/L Ventures and its service providers understand how the website is used. Information collected from your web browser (including small files stored on your device that are commonly referred to as “cookies”) allow the websites to recognize your web browser and help to personalize and improve your user experience and enhance navigation of the website. If you are a registered user of H/L Ventures’ and/or its service providers’ websites, H/L Ventures, its service providers, or third party firms engaged by H/L Ventures and/or its service providers, may collect or share information submitted by you, which may include personally identifiable information. You can change your cookie preferences by changing the setting on your web browser to delete or reject cookies. If you delete or reject cookies, some website pages may not function properly. H/L Ventures does not look for web browser “do not track” requests.
Revised: June 2020