ATYANT CAPITAL

PRIVACY POLICY

 
This privacy policy explains the manner in which Atyant Capital Management and its affiliates (collectively “Atyant Capital”) collect, utilize and maintain nonpublic personal information about Atyant Capital’s existing and prospective investors (collectively “Investors”) as well as users of this website. This privacy policy only applies to nonpublic information of investors who are individuals (not entities).
 

Collection of Investor Information

Atyant Capital collects personal information about its Investors mainly through the following sources:

  • Subscription forms, investor questionnaires and other information provided by the investor in writing, in person, by telephone, electronically or by any other means. This information includes name, address, nationality, tax identification number, and financial and investment qualifications; and
  • Transactions within the Fund(s) and Partnership(s), including account balances, investments and withdrawals.
 

Disclosure of Nonpublic Personal Information

Atyant Capital does not sell or rent investor information.  Atyant Capital does not disclose nonpublic personal information about its Investors to nonaffiliated third parties or to affiliated entities, except as permitted by law.  For example, the Atyant Capital may share nonpublic personal information in the following situations:
 
  • To service providers in connection with the administration and servicing of the Fund(s) or Partnership(s), which may include attorneys, accountants, auditors and other professionals.  Atyant Capital may also share information in connection with the servicing or processing of  Fund or Partnership transactions;
  • To affiliated companies in order to provide Investors with ongoing personal advice and assistance with respect to the products and services they have purchased through Atyant Capital and to introduce Investors to other products and services that may be of value to the Investor;
  • To respond to a subpoena or court order, judicial process or regulatory authorities;
  • To protect against fraud, unauthorized transactions (such as money laundering), claims or other liabilities; and upon consent of an Investor to release such information, including authorization to disclose such information to persons acting in a fiduciary or representative capacity on behalf of the Investor.

Protection of Investor Information

Atyant Capital’s policy is to require that all employees, financial professionals and companies providing services on its behalf keep client information confidential.
 
Atyant Capital maintains safeguards that comply with federal standards to protect investor information.  Atyant Capital restricts access to the personal and account information of investors to those employees who need to know that information in the course of their job responsibilities.  Third parties with whom Atyant Capital shares investor information must agree to follow appropriate standards of security and confidentiality.
 
Atyant Capital’s privacy policy applies to both current, prospective and former investors.  Atyant Capital may disclose nonpublic personal information about a former investor to the same extent as for a current investor.
 

Changes to Privacy Policy

The Partnership may make changes to its privacy policy in the future.  Atyant Capital will not make any change affecting existing investors without first sending limited partners a revised privacy policy describing the change.