Your privacy is very important to us. This Privacy Notice sets forth the policies of Spring Mountain Capital, LP (including its SMC Fixed Income Management division) (“SMC”) with respect to non-public personal information about our Private Fund investors and Managed Account clients, and prospective and former investors and Managed Account clients. These policies may be changed at any time, provided a notice of such change is given to you.
You provide SMC with personal information, such as your address, social security number, assets and/or income information (i) in the Subscription Agreement and related documents; (ii) in correspondence and conversations with SMC's representatives; (iii) through transactions with SMC and its Private Funds; and (iv) potentially through investment management agreements in the case of Managed Accounts.
SMC does not disclose any of this personal information about our investors and Managed Account clients, prospective and former investors and Managed Account clients, to anyone other than to the management company of the Partnership, and except as permitted by law, such as to our accountants, attorneys, auditors, brokers, regulators and certain service providers, in each case only as necessary to facilitate the acceptance and management of your investment or account and our relationship with you. SMC will also release information about you if you direct us to do so, if compelled to do so by law, or in connection with any government or self-regulatory organization request or investigation. For example, it may be necessary, under anti-money laundering and similar laws, to disclose information about our investors and Managed Account clients in order to accept subscriptions and investment management agreements from them.
Each investor acknowledges that under Delaware law other investors in a Partnership/ Private Fund may be entitled to review the books and records of the Partnership/Private Fund and are entitled to see a list of investors and their respective capital commitments or capital contributions. Each investor explicitly consents to disclosure of the fact of his or her investment in the Partnership/Private Fund, his or her mailing address and his or her capital commitment or capital contribution to other investors in the Partnership/Private Fund.
SMC may also disclose information you provide to us to companies that perform marketing services on our behalf, such as our placement agent. If such a disclosure is made, we will require such third parties to treat your private information with confidentiality. SMC seeks to carefully safeguard your private information and, to that end, restrict access to non-public personal information about you to those employees and other persons who need to know the information to enable us to provide services to you. SMC maintains physical, electronic and procedural safeguards to protect your non-public personal information from unauthorized use.
For questions concerning our policy, please contact the Compliance Department at (212) 292-8300, or write to Spring Mountain Capital, LP, Attention: Compliance Department, 650 Madison Avenue, 20th Floor, New York, NY 10022.