Privacy Policy - Nimble Partners

Protecting the privacy of each investor is very important to Passport Capital, LLC and Nimble Partners, LLC (together with their affiliates, the “Adviser”). The Adviser will not share nonpublic personal information about an investor with nonaffiliated third parties without such investor’s consent, except in the specific purposes described below. This Privacy Policy explains the Adviser’s collection, use, retention and security of information about investors.

The Adviser may obtain information about investors from the following sources:

Each investor’s commitment documents and other information that such investor provides at the time it becomes an investor, whether in writing, in person, by telephone, electronically or by any other means. This information may include an investor’s name, address, phone number, email address, social security number, employment information, income, investment experience and credit references; and
Consumer reporting agencies. This information may include account information and credit history.

The Adviser may disclose non-public personal information about an investor to nonaffiliated third parties without such investor’s consent when the Adviser believes it necessary for the conduct of its business or as required or permitted by law, such as:

If requested or authorized to disclose the information;
To respond to a subpoena or court order, law enforcement or regulatory authorities, or otherwise in the course of the judicial process;
To consumer reporting agencies;
To perform services for the Adviser or on its behalf to develop or maintain proprietary trading or other software;
In connection with a proposed or actual sale, merger or transfer of all or a portion of the Adviser’s business or an operating unit; and
To help the Adviser prevent fraud.

In addition, the Adviser may disclose any nonpublic personal information about investors to service providers who maintain or service investor accounts for the Adviser in order for the Adviser to be able to provide investors with necessary services with respect to their investments, such as:

To help process an investor’s application to become an investor or to service its investment;
To enable the provision of business services to the Adviser;
To assist the Adviser in performing marketing services or offering services to investors; and
For investor qualification and reporting purposes.

The information provided to these service providers may include the categories of information described above. These service providers are not allowed to use an investor’s personal information for their own purposes and are contractually obligated to maintain strict confidentiality. The Adviser also limits its use of an investor’s personal information to the performance of the specific service the Adviser has requested.

Except in those specific, limited situations, without an investor’s consent, the Adviser will not make any disclosure of such investor’s non-public personal information to other companies who may want to sell their products or services to such investor. For example, the Adviser will not sell investor lists and the Adviser will not sell investor names to a catalogue company.

If, at any time in the future, it is necessary to disclose any of an investor’s personal information in a way that is inconsistent with this Privacy Policy, the Adviser will give such investor advance notice of the proposed disclosure so that such investor will have the opportunity to opt out of such disclosure.

Even if an investor is no longer an investor of the Adviser, this Privacy Policy will continue to apply to such investor.

This Privacy Policy applies to individuals who obtain or have obtained service from the Adviser, used primarily for personal or family financial purposes.

The Adviser also takes steps to safeguard investor information. The Adviser restricts access to the personal and account information of its investors to its employees and agents for business purposes only. The Adviser maintains physical, electronic and procedural safeguards to guard an investor’s personal information.

The Adviser also has internal controls to keep investor information as accurate and complete as the Adviser can.

The Adviser reserves the right to change this Privacy Policy from time to time, but investors can always review the current policy by requesting a copy from the Adviser. The examples contained within this Privacy Policy are illustrations and they are not intended to be exclusive. If an investor has any questions about this Privacy Policy, or believes that any of its information is not accurate, such investor should contact the Adviser’s Compliance Team at (415) 321-4600.