Compliance

Privacy Policy

Maintaining the confidentiality of client personal financial information is very important to Paladin.

To provide clients with superior service, Paladin may collect several types of nonpublic personal information about clients, including:

  • Information from forms that clients may fill out and send to Paladin in connection with its services (such as name, address, and social security number).
  • Information a client may give Paladin orally.
  • Information about the amount clients have invested in an investment fund.
  • Information about any bank account clients may use for transfers between a bank account and a capital account of an investment fund.

Paladin does not sell or disclose client personal information to anyone except as permitted or required by law (for example, Paladin may share information collected about its clients with Paladin’s independent auditors and legal counsel and with regulators as it deems appropriate).

Additionally, a copy of an investor’s tax Form K-1 is included in a private investment fund’s tax return filed with the Internal Revenue Service.

Finally, Paladin may disclose information about its clients to any affiliated entity of Paladin and at the client’s written request (for example, by sending duplicate account statements or other information to someone designated by the client), and Paladin may disclose the client’s name in its marketing materials. Within Paladin, access to information about clients is restricted to those employees who need to know the information to service client accounts. Paladin employees are trained to follow its procedures to protect client privacy and are instructed to access information about clients only when they have a business reason to obtain it.

Use of Data

We will only use your data to supply you with the services and information which you have requested. For example:

  • if you are an investor or prospective investor in one of our funds, we may use your data in connection with that investment, or
  • if you are connected with a portfolio company or prospective portfolio company, we may use your data in connection with the monitoring and management of our investment.

We may also send you further information about our services or keep you informed of legal updates through our periodic newsletters, provided you have indicated that you are happy to be contacted for these purposes.

We may contact you by post or telephone as well as by e-mail.

If you change your mind about being contacted in the future, then please let us know.

Use of Google Analytics

Our website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses “cookies”, which are text files placed on your computer, to help the website analyze how users use the site. The information generated by your use of the website is stored in the cookie. Such information includes, for example, the number of times you have used a certain subpages of our website, the time spent on single pages, the pages on which you left our website, data concerning the location of your access (e.g. city or country) or details on the conversion rate of subpages. We have activated anonymizeIP and can therefore not see your computer’s IP address and connect it with the abovementioned date. The data stored in the cookie will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser or to install a deactivation-add-on (http://tools.google.com/dlpage/gaoptout?hl=de) to your browser.

Security

All information you provide to us is stored on secure servers with industry standard cyber security protection in place.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted online or through the website. Any transmission is at your own risk. Once we have received your information, we use strict procedures and security features to try to prevent unauthorized access.

Disclosure of Data

We process all data in accordance with the EU General Data Protection Regulation. We may disclose your data to other third parties who act for us, in order to provide the services you have requested.

Unless required to do so by law, we will not otherwise share, sell or distribute any of the data you provide to us without your consent.

Your Rights

You have certain rights by law including the right to access your information held by us (for which we may charge a small administrative fee) and to have any inaccurate information corrected. Your rights also include the right to be forgotten, to restrict processing and to object to processing, the right to data portability and the right to object to direct marketing. You have the right to withdraw consent, if consent has been given. If your personal details change, or if you have any queries or for further information, please do not hesitate to contact our Data Protection Officer.

Kenneth Pentimonti

20 North Audley Street

London W1K 6WD

United Kingdom
Data Protection Officer

Changes

We may make changes to this policy from time to time and any changes will be posted on this page.

Contact Us

If you have any queries or concerns regarding the use of your data or this policy, then please contact kpentimonti@paladincapgroup.com

We will make all efforts to deal with any requests or concerns as soon as possible.

 

Compliance Statement

Ladies and Gentleman:

Reference is hereby made to the Public Pension Fund Reform Code of Conduct adopted by Paladin Homeland Security Holdings, LLC (together with its subsidiaries and affiliates over which it exercises exclusive control, but excluding any sponsored, managed or advised investment fund or any portfolio company thereof, “Paladin”) on December 10, 2011 (as amended, amended and restated, or supplemented from time to time in accordance with the terms thereof, the “Code”).  Capitalized terms used herein (including in the Exhibits attached hereto) without definition will have the meanings set forth in the Code.

As of the date hereof, to the best of its knowledge after due inquiry, Paladin makes the disclosures set forth in Exhibits A, B and C attached hereto pursuant to the Code and certifies that such disclosures are accurate.

Very truly yours, PALADIN HOMELAND SECURITY HOLDINGS, LLC

By: Mark Maloney, Chief Compliance Officer