Collection of Investor Information
Chadwick collects personal information about its Investors from the following sources:
1. Account forms, subscription forms, investor questionnaires and other information provided by the Investor in writing, in person, by telephone, electronically or by any other means. This information includes name, address, employment information, and financial and investment qualifications;
2. Transactional activity in Investor accounts, including account balances, investments, withdrawals/redemption’s and fees/commissions;
3. Other interactions with Chadwick (for example, discussions with our staff); and
4. Verification services and consumer reporting agencies including an Investor’s creditworthiness or credit history.
Disclosure of Nonpublic Personal Information
Chadwick may share nonpublic personal information about its Investors or potential Investors with affiliates, as permitted by law. Chadwick does not disclose nonpublic personal information about its Investors or potential Investors to nonaffiliated third parties, except as permitted by law (for example, to service providers who provide services to the Investor or the Investor’s account). Chadwick will not share nonpublic personal information about an Investor with other Investors.
Chadwick may share nonpublic personal information, without the investor’s consent, with affiliated and nonaffiliated parties in the following situations, among others:
1. To respond to a subpoena or court order, judicial process or regulatory inquiry;
2. In connection with a proposed or actual sale, merger, or transfer of all or a portion of its business;
3. To protect or defend against fraud, unauthorized transactions (such as money laundering), law suits, claims or other liabilities;
4. To service providers of Chadwick in connection with the administration and operations of Chadwick and its Funds and other products and services, which may include brokers, attorneys, accountants, auditors, administrators or other professionals;
5. To assist Chadwick in offering Chadwick-affiliated products and services to its Investors; and
6. To process or complete transactions requested by an Investor.
Former Customers and Investors
Protection of Investor Information
Chadwick maintains physical, electronic and procedural safeguards that comply with federal standards to protect customer information. Chadwick restricts access to the personal and account information of Investors to those employees who need to know that information in the course of their job responsibilities.