Privacy Policy

The Nephila Companies have adopted policies and procedures relating to the collection, use and protection of nonpublic personal information of the Nephila Companies' clients and investors (each referred to herein as a "customer"). The Nephila Companies' Privacy Policy is set out below.

The Nephila Companies (herein referred to as "we") consider customer privacy to be fundamental to our relationship with our clients. In the course of operating and acting as trading advisor to the private investment vehicle in which you have invested (the "Investment Vehicle") or acting as trading advisor over your individual account (the "Account"), we collect personal information about you ("nonpublic personal information"). We collect this information to know who you are and to meet our obligations under the laws and regulations that govern us.

Throughout our history we have been, and we remain, committed to maintaining the confidentiality, integrity and security of our clients’ personal information. It is our policy to respect the privacy of our current and former clients and to protect the personal information entrusted to us. This Privacy Policy describes the standards we follow for handling your personal information, with the dual goals of meeting your financial needs while respecting your privacy.

Information We Collect

We collect nonpublic personal information about you from three sources:

  • Information on subscription agreements or other forms. This category may include your name, address, tax identification number, age, marital status, number of dependents, assets, debts, income, employment history, beneficiary information and personal bank account information.
  • Information from your transactions with us, such as your investment history in the Investment Vehicle and/or the Account and your account balance.
  • Information obtained from others, such as consumer credit reporting agencies.

Information We Disclose

We may disclose any of the nonpublic personal information we collect with unaffiliated third parties only if necessary to operate and act as trading advisor to the Investment Vehicle or to act as trading advisor over your Account or to complete a transaction for the Investment Vehicle or the Account.

For example, we may disclose nonpublic personal information about you to the unaffiliated third parties and in the circumstances described below, as permitted by applicable laws and regulations:

  • Companies with whom we have contracted to provide Investment Vehicle- or Account-related services.
  • Our lawyers, accountants, auditors, regulators, advisors, and quality-control consultants.
  • If we suspect fraud.
  • To protect the security of our records, Web site and telephone customer service center.
  • Information you have authorized us to disclose.

Protecting Your Information

We limit access to the information we have about you to our employees who need to know such information in order for us to operate and act as trading advisor to the Investment Vehicle or to act as trading advisor over the Account. In addition, we maintain appropriate physical, electronic and procedural safeguards to protect your information.

Keeping You Informed

We will send you a copy of this Privacy Policy annually. We will also send you all changes to this Privacy Policy as they occur.