Commonwealth’s Privacy Policies and Practices:
Commonwealth Capital Corp. and its affiliates are committed to respecting your privacy. We value the trust you have placed in us. Pursuant to Federal Trade Commission regulations and SEC Regulation S-P, we are required to tell investors how their personal information is treated and to provide this statement to you once each year.
Commonwealth does not sell investors’ personal information. Commonwealth will protect the confidentiality of any personal information you share with us. Commonwealth’s corporate policies require that employees with access to confidential investor information may not use or disclose the information except for business use. All employees are trained and required to safeguard such information.
Disclosures to Unaffiliated Third Parties
Commonwealth does not disclose any nonpublic personal information about our current or former investors to any non-contractual third parties, except as permitted by law. We reserve the right to disclose all categories of the nonpublic personal information if required by SEC, FINRA, State or Federal regulations, contractual obligations or other applicable obligations, but only as permitted or required by law (such as to protect against fraud or in response to a subpoena).
Examples of third-parties with contractual obligations who may receive your personal information are: our legal counsel, our auditing firm, our third-party Investor Database Service Vendor (Conduent Securities Services, who performs business operations on our behalf, such as mailing of distribution checks, mailing of quarterly or annual reports and mailing of tax information), escrow agents for our offerings, a third party shredding company and an electronic storage media company, as required by SEC Rule 17a-4. We reserve the right to disclose in the future to different non-affiliated third parties, not for marketing purposes, but to provide investor services or as required by law.
Our investors become protected under our policies once they have been approved by the General Partner or Manager as a limited partner or member in any of our public or private funds, or when an existing investor newly subscribes to an additional fund.
Our investors will receive initial privacy notices with their first investment confirmation and additional privacy notices with each subsequent investment confirmation in a different fund, and additionally will receive a copy with their tax information package each year. Once a fund liquidates and dissolves or an investor prematurely withdraws their investment with general partner/manager approval (heavy restrictions apply – please see prospectus), the obligation to deliver privacy notices to those investors will cease.
How we secure your assets and protect your information:
- We authorize disclosure to only a limited group of employees with password-protected restricted use;
- We train our employees to protect investor information;
- All investor information is kept in locked, secure areas;
- We continually change and enhance our security systems;
- We’ve contracted with an independent shredding company(s) for confidential disposal of information; and
- We protect investor data by asking you for information that only you would know when you contact us.
Categories of Nonpublic Personal Information collected:
Information provided by an individual to a financial institution to obtain a financial product or service from such institution (e.g. information provided on an application or subscription agreement);
Information about an individual resulting from any transaction with the financial institution (e.g. transaction history);
Information obtained about an individual in connection with providing a financial product or service to such individual (e.g. information from a credit report);
A list, description or other grouping of individuals (and publicly available information pertaining to them) that is derived from nonpublic personal information (e.g. a list of individuals’ names and street addresses derived using such individuals’ account numbers);
Nonpublic information includes your name, addresses, phone number, social security number, e-mail address, income, assets, policies, third-party accounts, family data, and information with respect to business transactions or experiences with us or other financial institutions (collectively, NPI); and
The fact that an individual is or has been a customer of a financial institution.
Information About Former Investors
While in the ordinary course of business we do not actively distribute any personal information concerning former investors (i.e., investors in liquidated funds or who have withdrawn from our partnerships or LLCs), certain entities involved in the offerings of the prior funds may retain such information. Also, we reserve the right to disclose all categories of the nonpublic personal information on former investors if required by SEC, FINRA, State or Federal regulations, contractual obligations or other applicable obligations, but only as permitted or required by law (such as to protect against fraud or in response to a subpoena).
We strive to maintain accurate information on your account.
If you would like to order additional privacy notices or believe your account information is not correct, please let us know by calling our toll-free Investor Hotline, (800) 249-3700, to speak to an Investor Services Representative.
This Privacy Statement replaces any prior privacy statements you received from us.