Privacy Policy

The following privacy policy describes the standards that ClearLake Advisors, L.L.C. follows for the collection, use and protection of nonpublic personal information.

Information the Advisor Collects

ClearLake Advisors, L.L.C. collects nonpublic personal information from the following sources: (i) information received on applications and other forms including subscription documents, investment advisory agreements, and questionnaires, which information may include name, address, Social Security number, income, net worth, asset statement, tax circumstances, investment experience, investment goals and risk tolerance; (ii) information about transactions with the Advisor, its affiliates and others such as other products purchased, information about additions and withdrawals, parties to a transaction, positions held or sold and pricing; and (iii) correspondence (written, telephonic or electronic), including information obtained from third parties such as brokers and custodians. "Nonpublic personal information" is nonpublic information that is obtained in connection with the provision of a financial product or service for personal, family or household purposes.

Information the Advisor Discloses

ClearLake Advisors, L.L.C. does not disclose any nonpublic personal information that it collects to unaffiliated third parties except to certain service providers or as is expressly permitted by a client or required by law, regulation or the request of any regulatory or self-regulatory authority. The Advisor treats nonpublic personal information concerning former clients the same way it treats such information about current clients. The Advisor does not sell any personal information about clients. In the normal course of business, personal information collected, as described above, may be shared with nonaffiliated third party service providers as necessary to (i) effect, administer or enforce a transaction that a client may request or authorize; (ii) in connection with processing or servicing a financial product or service that a client may request; or (iii) in connection with maintaining or servicing a client's account. For example, information may be disclosed to others to enable them to perform general administrative activities, to assist in processing a transaction or to coordinate with a custodian.

Protecting Confidentiality and Security

ClearLake Advisors, L.L.C. maintains physical, electronic and procedural safeguards to protect client nonpublic personal information. It treats this information in a confidential manner, and restricts access of nonpublic information to employees who have an appropriate reason to access it. The Advisor educates employees on the importance of protecting the privacy and security of confidential personal information. In addition, the Advisor only shares this information with third parties who maintain (i) policies and procedures designed to assure only appropriate access to, and use of information about, clients; and (ii) physical, electronic and procedural safeguards that comply with federal standards to guard nonpublic information of clients.

 

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ClearLake Advisors, L.L.C.