The privacy of our investors is very important to us. This notice (this “Privacy Notice”) is provided by Endicott Capital Management, L.L.C. (together with its affiliates, “Endicott,” “we,” “our,” or “us”) and sets forth its policies with respect to the collection, sharing and protection of non-public personal information related to our investors, including prospective and former investors. These policies apply to individuals and Individual Retirement Accounts only and may be changed at any time, provided a notice of such change is given to the relevant investors. Please read this Privacy Notice carefully to understand what we do.
We collect personal information, such as an investor’s address, social security number, assets, transaction and/or income information, for example, when an investor: (i) provides it to us in Subscription Agreements and related documents; (ii) provides it to us in correspondence and conversations with our representatives; or (iii) makes transactions with us or our affiliates, such as when you transfer money to us or tell us where to send money or make a wire transfer. We also may collect an investor’s personal information from other sources, such as affiliates.
We may disclose information about our investors, prospective investors or former investors to affiliates (i.e., financial and non-financial companies related by common ownership or control) or non-affiliates (i.e., financial or non-financial companies not related by common ownership or control) for our everyday business purposes, such as to process transactions, maintain investor account(s) or respond to court orders and legal investigations. Thus, it may be necessary, under anti-money laundering and similar laws, to disclose information about our investors in order to accept subscriptions from them. We will also release information about an investor if the investor directs us to do so. We do not share our investors’ information with non-affiliates for their marketing purposes. Nor do we share information about our investors’ credit worthiness with our affiliates for their everyday business purposes.
We may also disclose information our investors provide to us to companies that perform services on our behalf, such as placement agents.
To protect our investors’ personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings.
If you have any questions about this Privacy Notice, call 212-450-8070.