Brooke Private Equity Associates Management, LLC (“BPEA”) collects nonpublic personal information about individuals that are investors in the investment funds and accounts that are managed, directly or indirectly, by BPEA (the “Funds”) from the following sources:
- Information received from investors on subscription agreements, partnership agreements and other forms; and
- Information about investors’ transactions with BPEA and their investments in the Funds.
BPEA does not disclose nonpublic personal information about individuals who are current or former investors to anyone, except as permitted by law. BPEA may disclose such information to its affiliates and to third parties that perform services for BPEA. For example, BPEA may forward such information to its accountants to complete financial statements and maintain accounting records or to lenders that provide financing for the Funds’ investments. Furthermore, consistent with industry practice and the provisions of BPEA’s Fund agreements, BPEA may distribute certain personally identifiable information, such as the schedule of investors, to all investors in each specific Fund.
BPEA also may disclose nonpublic personal information about current or former investors obtained from subscription agreements, partnership agreements and other forms (such as the investors’ names, contact information and financial profiles) to companies that perform marketing services on BPEA’s behalf or to other financial institutions, such as broker-dealers and placement agents with whom BPEA has agreements in connection with offering new and existing Funds.
BPEA restricts access to nonpublic personal information about individuals who are investors in the Funds to those employees and service providers that use such information in connection with the offering, formation and operation of new and existing Funds or managing and servicing investor accounts. BPEA maintains physical, electronic and procedural safeguards that comply with federal guidelines to protect nonpublic personal information.