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Privacy Policy

Windstream Partners LLC (“Windstream”) is committed to protecting the confidentiality and security of personal information entrusted to us. This Privacy Policy is intended to comply, to the extent applicable, with the Gramm-Leach-Bliley Act, Regulation S-P, and other applicable privacy and information-security requirements.

Information We Collect

In providing services to clients, Windstream may receive non-public personal information concerning clients, investors, prospective investors, beneficial owners, employees, representatives, and other individuals associated with our clients.

This information may include names, addresses, email addresses, telephone numbers, dates of birth, Social Security or tax identification numbers, government identification information, bank or account information, investment qualifications, ownership information, and transaction or financial information. Windstream may receive this information directly from clients or individuals, or from fund administrators, banks, brokers, accountants, attorneys, compliance consultants, and other service providers.

How We Use Information

Windstream uses personal information only for legitimate business purposes, including to:

  • Providing accounting, operations, compliance, and related services;
  • Assisting with transactions, payments, subscriptions, redemptions, and account activity;
  • Preparing financial, accounting, tax-support, audit-support, and regulatory records;
  • Conducting identity verification, due diligence, fraud prevention, and anti-money-laundering activities;
  • Protecting Windstream, its clients, and investors against unauthorized activity; and
  • Complying with legal, regulatory, contractual, and professional obligations.
  • Disclosure of Information

    Windstream does not sell or rent personal information. Windstream may disclose personal information only as reasonably necessary to provide its services, as directed or authorized by a client or individual, or as permitted or required by law. Windstream may also disclose information in response to legal or regulatory requests, to prevent fraud or unauthorized transactions, to respond to an information-security incident, or to protect legal rights.

    Protecting Information

    Windstream maintains administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, use, disclosure, alteration, or destruction. Access to personal information is limited to employees, contractors, and service providers who need the information to perform authorized responsibilities. Windstream requires service providers with access to protected information to maintain appropriate confidentiality and security safeguards.

    If Windstream becomes aware of a security incident affecting information maintained for a client, Windstream will promptly notify the client in accordance with applicable law and the applicable service agreement and will reasonably assist with the investigation and response.

    Retention and Disposal

    Windstream retains personal information only for as long as reasonably necessary to provide services and satisfy legal, regulatory, contractual, and recordkeeping obligations. When information is no longer required, Windstream takes reasonable measures to securely dispose of it.

    Contact Details

    Questions regarding this Privacy Policy may be directed to:
    Windstream Partners, LLC
    Carrie Youngberg
    1120 Avenue of the Americas, New York, NY 10036
    917-886-5992
    carriey@windstreamllc.com