SummerHaven Index Management, LLC (“SummerHaven”) and its affiliates do not disclose any personal, non-public information about their prospective, existing or former clients (the “Information”) to third parties other than as described below.
SummerHaven and its affiliates collect such Information (such as your name, address, social security number, assets and income) from their discussions with you, from documents that you may complete and deliver to them and in the course of their providing services to you. SummerHaven and its affiliates may use the Information to provide advisory services to you, to open an account for you, to process a transaction for your account or otherwise in furtherance of our business. In order to service your account and effect your transactions, SummerHaven and its affiliates may provide your Information to the following: (i) any SummerHaven affiliate, the administrator of any private investment fund advised by SummerHaven, attorneys, accountants, auditors and other service providers (such as brokers) who need the Information in connection with providing services to SummerHaven or any of SummerHaven’s affiliated private investment funds, (ii) third party service providers or financial institutions who perform marketing services on behalf of SummerHaven or its affiliated private investment funds, provided that such persons must agree to protect the confidentiality of the Information and to use the Information only for purposes of performing such marketing services, and (iii) any other party if required or permitted by law.
SummerHaven and its affiliates seek to carefully safeguard your Information and, to that end, restrict access to your Information to those SummerHaven employees and other persons who need to know the Information in order to enable SummerHaven to provide services to you. We maintain physical, electronic and procedural safeguards to protect your Information.