Maintaining the confidentiality of client personal financial information is very important to Polaris Greystone. To provide clients with superior service, Polaris Greystone may collect several types of nonpublic personal information about clients, including:
- Information from forms that clients may fill out and send to Polaris Greystone in connection with investment in a private investment fund (such as name, address, and social security number).
- Information a client may give Polaris Greystone orally.
- Information about the amount clients have invested in a private investment fund (such as initial investment and any additions to and withdrawals from a capital account).
- Information about any bank account clients may use for transfers between a bank account and a capital account of a private investment fund.
Polaris Greystone does not sell or disclose client personal information to anyone except as permitted or required by law. For example, Polaris Greystone may share information collected about its clients with Polaris Greystone's independent auditors in the course of the annual audit of a private investment fund in which clients have an investment. Polaris Greystone may share this information with Polaris Greystone's legal counsel as we deem appropriate and with regulators. Additionally, a copy of client's tax Form K-1 is included in a private investment fund's tax return filed with the Internal Revenue Service. Finally, Polaris Greystone may disclose information about clients at the client's request (for example, by sending duplicate account statements to someone designated by the client), or as otherwise permitted or required by law.
Within Polaris Greystone, access to information about clients is restricted to those employees who need to know the information to service client accounts. Polaris Greystone employees are trained to follow our procedures to protect client privacy and are instructed to access information about clients only when they have a business reason to obtain it.