Privacy Policy

This notice is being delivered to you pursuant to SEC Regulation S-P.

INFORMATION WE HAVE ABOUT YOU

We receive nonpublic personal information about you from various sources, including:

  1. Your requests or applications for our products and services,
  2. Your answers to questions in our Offering Questionnaires in order to determine your eligibility for our Limited Partnerships and other managed accounts, and
  3. Information included in submittals in conjunction with our advisory and sub-advisory agreements.

HOW WE USE THE INFORMATION ABOUT YOU

We do not disclose any nonpublic personal information about our customers or former customers to anyone except as required by law. Your information is confidential and we do not share this information, simply out of common courtesy and acceptable proprietary sensibilities. We will only share information under proper request and direction from regulatory authorities and law enforcement officials who have legal jurisdiction over us or if we are required to do so by United States or other applicable law; provide information to protect against fraud; for audit purposes with outside auditors to produce required tax filings; share information with your consent; and give aggregate performance information where details of individual investors are not disclosed. We do not have any joint marketing agreements where your information would be shared to offer products that are not under the control of Palo Alto Advisors, Inc.

PROTECTING THE CONFIDENTIALITY OF OUR CLIENT INFORMAITON

We restrict access to nonpublic personal information about you to employees of Palo Alto Advisors and only necessary select associated parties. We maintain physical, electronic, and procedural safeguards that comply with federal standards to guard your nonpublic personal information.

WHO IS COVERED BY THE PRIVACY POLICY

We provide our Privacy Policy to our clients when they open a new account with us or become a limited partner in a partnership, enter into certain contractual relationships and annually after that. If we materially change our Privacy Policy, we will notify you. Our policy continues to be of the utmost confidentiality and courtesy and far exceeds any government requirements or interference.

If you have any questions about this notice, please contact our compliance officer at
Compliance@PaloAltoAdvisors.com