Valu-Trac Investment Management Limited (the “Firm”) believes that protecting the privacy of the non-public personal information of investors and prospective or former investors (the “Investors”) is of the utmost importance, and the Firm is committed to maintaining the privacy of such non-public personal information in its possession.
The Firm provides all Investors with the following notices.
The Firm collects non-public personal information about Investors from the following sources:
- Information the Firm receives from subscription documents and related forms (e.g., name, address, date of birth, assets, income and investment experience); and
- Information about Investors’ transactions with the Firm (e.g., subscription and withdrawal information).
The Firm does not disclose any non-public personal information about Investors to anyone other than in connection with the administration, processing and servicing of customer accounts or to accountants, attorneys and auditors or as otherwise permitted or required by law.
The Firm restricts access to non-public personal information about Investors to personnel who need to know that information in order to provide products or services to Investors.
The Firm maintains physical, electronic and procedural controls in keeping with regulatory standards to safeguard such non-public personal information.
In addition, if the Firm chooses to dispose of an Investor’s non-public personal information, that it is not bound to maintain, then the Firm will do so in a manner that reasonably protects such information from unauthorized access.