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
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.
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.
20 North Audley Street
London W1K 6WD
Data Protection Officer
We may make changes to this policy from time to time and any changes will be posted on this page.
If you have any queries or concerns regarding the use of your data or this policy, then please contact email@example.com
We will make all efforts to deal with any requests or concerns as soon as possible.
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