This Privacy Notice describes the policies of Neon Liberty Capital Management (the "Firm") with respect to nonpublic personal information of the Firm's partners, prospective partners and former partners (collectively, "Partners"). These policies apply to individuals only and are subject to change.
The Firm collects and maintains nonpublic personal information about Partners as follows:
Information we receive in subscription agreements, investor questionnaires and other forms which Partners complete and submit to us, such as names, addresses, phone numbers, social security numbers, and employment, asset, income and other household information;
Information we receive and maintain relating to a Partner's capital account, such as profit and loss allocations and capital withdrawals and additions;
Information about your investment in and other transactions with us and our affiliates, including information we receive and maintain relating to securities transactions with and through the Firm and its affiliates; and
Information we receive about a Partner from the Partner's purchaser representative, financial advisor, investment consultant or other financial institution with whom the Firm has a relationship and/or whom the Partner may have authorized to provide such information to the Firm.
The Firm does not disclose any nonpublic personal information about its Partners or former Partners except as may be required or permitted by law. The Firm may disclose information about a Partner to its affiliates (including the Firm's general partner and/or investment manager and the Firm's employees and agents with a need to know such information to enable the Firm to provide statements, information and services to its Partners), and to the following types of third parties:
Financial service providers who assist the Firm as part of the ordinary course of servicing your investment in the Firm;
Legal representatives of the Firm, such as our counsel, accountants and auditors;
Certain non-affiliated parties who perform marketing services for the Firm or with whom we have entered into joint marketing agreements; and
Persons acting in a fiduciary or representative capacity on behalf of an individual Partner, such as an IRA custodian or Trustee of a grantor trust.
On all occasions when it is necessary for us to share your personal information with non-affiliated companies, we will require that such information only be used for the limited purpose for which it is shared and will advise these companies not to further share your information with others except to fulfill that limited purpose.
The Firm takes its responsibility to protect the privacy and confidentiality of Partner information very seriously. We maintain appropriate physical, electronic and procedural safeguards to guard Partners' nonpublic personal information. We provide Partners with a Privacy Notice as part of their subscription materials and annually after that. If the Firm changes its privacy policies to permit it or its affiliates to share additional information the Firm has about you or to permit disclosures to additional types of parties, you will be notified in advance, and, if required by law, you will be given the opportunity to opt out of such additional disclosure and to direct us not to share your information with such parties.
If you have any questions or concerns about this Privacy Notice, please contact us at: 600 Third Avenue 26th Floor New York, New York 10016 Phone: (212) 983-1518