Privacy Policy

Fairview Investment Services, LLC (doing business as Fairview Compliance Administration and Fairview Compliance Services) and its affiliates (the “Company”, “we”, or “us”) are committed to respecting your privacy and the personal information you share with us in accordance with our policies. This Privacy Policy (“Policy”) describes our treatment of your personal data that we receive in providing compliance administration services, fund administration services, financial printing and filing, and / or website hosting and creation.

It is important that you read this Policy together with any other policies we provide when we are collecting or processing your personal data to ensure you understand how and why we use your information. By obtaining services from us and/or voluntarily providing personal data to us, you acknowledge that you have read and understand this Policy.

As used in this Policy, the term “Company” shall include the following entities:

• FilePoint EDGAR Services, LLC;
• Fairview, LLC (doing business as ViewPoint Partners, Fairview-FilePoint, Fairview FilePoint, Fairview/FilePoint, FV-FP, and/or FV/FP);
• Fairview Investment Services, LLC (doing business as Fairview Compliance and/or Fairview Compliance Administration);
• Fairview Investment Administration, LLC;
• Fairview Performance Services, LLC; and
• Fairview Cyber, LLC.

The Company reserves the sole discretion to change this policy by updating this page. You should review this page periodically to ensure that you are comfortable with any changes.

Details about collection and use of data

The information we collect varies depending on your activity and use of the services or products offered by the Company. This Policy describes our practices with respect to personal data we receive in relation to our provision of services, including compliance administration services (“Services”) and applies to you if you are a client of the Company or an employee, access person, or investor of a client or otherwise use the Services directly or indirectly (collectively, “Clients and Related Parties”). Our company websites may have separate policies, which you can find on the applicable website.

Categories of Personal Information

We collect the following categories of personal information from Clients and Related Parties:

• Marketing materials — provided by or on behalf of our clients, including performance information and any other information provided by you or your employer such as account numbers.

 

• Code of Ethics information – including account statements, transaction information, data feeds provided by custodians or other third parties, compliance policies and procedures, and trade blotter information.

 

• Information we receive through direct communication with you or a third party on your behalf or on behalf of your employer – including personal information you provide to us in direct communications, by email, phone, or otherwise, and other information provided to us to provide services to you, your employer, and / or a third party on behalf of you or your employer or an entity for which you are an access person, including without limitation outside business activities in which you are involved, gifts you receive or send, and political contributions you make. This also includes any other information provided by you or a third party that is related to the compliance program for which you are classified as an access person or otherwise subject to reporting requirements.

 

• Employment information – such as your employer name, your title, start and termination

 

• With respect to websites hosted by the Company that display this Privacy Policy (“Hosted Websites”), we may use Cookies – We use cookies when you use our websites and / or websites hosted by us. These may be ‘session’ cookies, meaning they delete themselves when you leave the Website, or ‘persistent’ cookies which do not delete themselves and help us recognize you when you return so we can provide a tailored service. However, you can block our usage by adjusting your browser settings to refuse cookies.

 

When you provide the information above, it is received by the Company and / or applicable entity to which you send such information and may also be received by such entity’s affiliated entities (“Affiliates”) and their employees. Further, your personal information may be provided to regulatory authorities pursuant to a legal or regulatory request, including but not limited to a subpoena or SEC request. Additionally, in providing Services, the Company may provide your name and contact information as part of a regulatory filing. See “Information Sharing and Disclosure” below for additional information.

When asked to provide information, you may decline to do so. However, if you choose not to provide information that is necessary for us to collect by law or to perform a contractual duty, we may not be able to enter into or perform such contract or perform other obligations with respect to you and / or your employer or an entity for which you are an access person. If you provide us with information about another person, you must ensure that you have the right to provide that information and that they understand how we will use their information.

Data Retention and Protection

Your personal data is generally stored until we receive a request to remove it or as otherwise required by internal policies and procedures, applicable law and / or contractual terms. Data we collect is generally stored in the United States and is subject to our Network Security Policy, except when data is submitted to Company outside of the United States or sent through a third-party platform, in which case its storage will be governed by such third-party platform’s terms. If data is submitted to Company outside of the United States, then the data storage and processing may vary depending on the sender’s location and method of submission. The Company uses reasonable physical and technical measures to prevent unauthorized access or loss, and / or unlawful processing. Usage of this Website is not permitted outside of the United States.

We do not use your personal data for automated decision-making or profiling, which have a legal or similarly significant effect on users.

Information about processing of personal data

Purpose for Processing

We use personal data of Clients and Related Parties for the following purposes:

• Providing Services and fulfilling contractual obligations – including providing Services to you and / or your employer or the fund in which you invest and assisting Clients with website development and hosting.

 

• Business operations and marketing purposes – including (1) communication with you regarding our Services and regulatory updates; (2) compliance with our legal obligations or the obligations of your employer, a firm for whom you are an access person, or a fund in which you invest; (3) in response to court orders or regulatory requests and in exercising our legal rights; (4) in protecting our and our clients’ rights and

 

• Assisting our Clients and Related Parties with meeting regulatory requirements – including (1) compliance and regulatory reporting and books and records requirements; (2) fund compliance and administration, including AML compliance; and (3) financial printing fulfillment and submitting filings through FINRA and / or EDGAR.

 

Any information provided to us by you and / or your employer and / or an entity for which you are an access person will only be used for the purposes for which it was provided and any reasonably related purposes including providing you with the information that you request from us. We may also use your contact information to communicate regulatory updates. However, in the event you wish to stop receiving such communication, you may opt out by selecting an “unsubscribe” or by contacting our legal department at legal@fariviewinvest.com.

Legal Bases for Processing

We process data for one or more of the following legal bases:

• Your consent – By providing, or requesting a third party to provide, or otherwise making information available to the Company, you acknowledge that you have read this Policy, understand it, agree to its terms, and authorize the Company to collect, use and disclose information pursuant to this Policy.

 

• To enter into, or perform under, the agreement between us and your employer and / or entity for which you are an access person, and to comply with your instructions;

 

• As is necessary for our legitimate interests, this may include direct marketing, fulfilling a Service obligation or request, and maintaining for legal purposes or internal policies and procedures; and / or

 

• To comply with the law and our legal obligations, as well as to protect you and other individuals from certain harms.

 

Information Sharing and Disclosure

Your personal information may be shared with:

• Our Affiliates of the Company – When you provide personal information, it is received by the Company its representatives, and may also be received by its affiliated entities, including Fairview®, LLC, Fairview® Compliance Administration; Fairview® Investment Administration, LLC; Fairview® Performance Services, LLC; Fairview® Cyber, LLC (“Affiliates”). In such cases, the Affiliates receiving the information are subject to this Privacy Policy.

 

• Our service providers – including, as applicable, IT service providers, commercial email providers, security consultants, software vendors, payment processors, and other vendors we engage so that they may provide services to us or on our behalf.

 

• Other third parties – pursuant to a regulatory request or subpoena or and / or when we believe it is required by, or necessary to comply with, applicable We may also provide your personal information to third parties when you (or your employer or service provider) ask us to do so.

 

No Rights of Third Parties

This Policy does not create rights enforceable by third parties.

Links to Third-Party Sites

For your convenience and informational purposes, our websites may include hyperlinks to third-party websites. The Company does not attest to the content found on those sites and the user assumes the risk of use. Once you have left our website(s), you should check the applicable privacy policy of the third-party website to determine how they collect information from you.

Changes to this policy

The Company reserves the sole discretion to change this policy by updating this page. We will use reasonable efforts to notify you of any material changes to this policy, such as by sending you the revised policy by email or posting a notice on our website. This policy is effective from November 7, 2023.

Support

Please report any system issues and / or incidents promptly upon identification to complianceviewssupport@fairviewinvest.com.