PRIVACY POLICY FOR McKinley Capital
This notice is provided to you as a customer of McKinley Capital, pursuant to the Commodity Futures Trading Commission's adoption of rules regarding the Privacy of Consumer Financial Information in accordance with federal laws related to the privacy of certain information. You become a customer of McKinley Capital when you subscribe and are approved to invest in a fund or account operated or advised by us or when you execute your first investment transaction with us.
McKinley Capital collects the following categories of nonpublic personal information from its customers:
Information that you provide to us, about yourself in order to obtain a financial service from us, such as a client questionnaire that enables McKinley Capital to determine if you qualify to invest in an offering or to complete a subscription agreement to invest in an offering. This information would include such items as your name and address, asset and income levels, employment history, and past investment experience.
All of those types of nonpublic information are disclosed only to McKinley Capital to provide financial services. McKinley Capital is engaged in the business of acting as commodity trading advisors, appropriately registered. McKinley Capital does not provide nonpublic financial information to companies that are not Affiliates. These same disclosure polices apply to former customers of McKinley Capital. If you close your account or end your customer relationship with us, we will adhere to the privacy policies and practices described within this notice.
McKinley Capital does not disclose any non-public personal information about its customers or former customers to anyone, except as permitted by law without customers express permission. However, we may share a customer's nonpublic personal information in order to: (i) comply with applicable federal, state, local, or regulatory laws or valid legal process, (ii) to protect the McKinley Capital rights or property or (iii) when we believe that physical safety is at risk.
We have adopted these policies and practices to protect the confidentiality and security of nonpublic personal information that McKinley Capital obtains from you. Access to that information is restricted to its staff members [and the staff members of its Affiliates] who need to know that information in order to market and sell financial services offered by McKinley Capital. It is also provided to our staff members who need to know that information in order to provide us with services such as accounting and compliance operations of the funds that McKinley Capital operates, as well as to other necessary employees of the Affiliates.
In addition, McKinley Capital requires staff members with access to your nonpublic personal information to strictly comply with this Privacy Policy Employees who misuse customer information may be subject to disciplinary action, including but not limited to termination of employment with McKinley Capital. McKinley Capital maintains physical, electronic, and procedural safeguards to guard your non-public personal information.
McKinley Capital provides this notice to you at the beginning of our relationship with you and annually thereafter in conjunction with mailing of their annual financial or year end report. McKinley Capital Privacy Policy PDF