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 PRIVACY POLICIES |
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Regulation S-P Privacy Policy Statement Instream Partners LLC ("Instream Partners") is committed to protecting the financial privacy of the individual investors that participate in our clients' financing transactions. Toward that end, we have adopted the following policies to safeguard investor information: Information We Might Receive Individual investors in private placements may provide personal financial information when seeking to qualify as investors. Instream Partners may receive copies of such private financial information in connection with the services it provides its clients. Individual investors generally may provide personal information on the investor qualification statement or investor questionnaire, and may include information such as name, address, social security number, assets and income and similar information. Access to Information Employee access to nonpublic investor information is provided in connection with the Firm's business purposes only and is granted only to Instream Partners employees. Access is based on the need to know such information to allow the orderly completion financing transactions. The Firm requires each of its employees who have access to investor information to protect and keep it confidential. Security Standards Instream Partners continues to assess new technology to evaluate its ability to provide additional protection of investor personal information. The Firm safeguards this information in accordance with federal standards and established security standards and procedures. Measures taken in this regard include implementation of physical, electronic and procedural safeguards. Sharing Information The Firm does not sell investor information to third parties. In the course of conducting business, the Firm discloses necessary investor information to non-brokers and other businesses including non-affiliated third parties, as allowed by law, in order to:
If, at any time, Instream Partners deems it necessary to disclose any non-public investor information in a way that is inconsistent with this policy, we will provide advance notice of the proposed disclosure and allow every individual investor the opportunity to opt-out of such disclosure. Application Our privacy policy applies to all individual investors in current and former Instream Partners private placements. Any individual investor having concerns regarding this privacy policy is encouraged to contact the Instream Partners Chief Compliance Officer, John H. Schlesinger, Monday through Friday, between 9:00 am and 5:00 pm., Pacific Time: 415-217-6400. Web Privacy Policy At Instream Partners LLC, we are committed to protecting your privacy as a visitor to our web site. We do not currently sell or exchange personally identifiable information about you with third parties, nor do we currently have any plans to do so. Our web hosting service tracks and collects general information about visits to our site. This information is used to monitor the areas of our site which are highly visited and which are not, allowing us to give you a better web site and determine which services may be of greater interest to our clients. We do not provide information to any third party other than companies helping us to improve our web site. We do not currently give out information to third parties. We will give out information, however, under the following circumstances: If necessary to comply with any valid legal process, such as a search warrant, subpoena or court order If we reasonably conclude that you or others are involved in illegal or improper conduct, such as breach of contract, unfair business practices or infringement of proprietary rights To comply with any other legal requirement In response to fraud or a threat to any person Our web site may contain links to third-party sites that you may find useful. These sites will have their own privacy policies that may differ from ours. We are not responsible for the content or privacy practices employed by other sites. Our privacy policy is subject to change, but no change will be implemented until it is first posted on our web site. We will continue to post this policy so that you can know what information we gather and how it is used. For further information, please e-mail John Schlesinger at jschlesinger@instreampartners.com or call 415.217.6400 ext. 204. |
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Business Continuity Plan | Anti-Money Laundering | Privacy Policies