CapfiPartners, LLC


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Privacy Policy October 2017

This Privacy Policy sets forth the manner in which CapFi Partners, LLC (“CapFi”) may collect, utilize and maintain nonpublic information about individual persons, as required under federal and other applicable law. CapFi is committed to protecting privacy and maintaining the confidentiality and security of an investors’ personal information.

Collection of Information

CapFi may collect personal information about investors from the following sources:

CapFi may request that investors and clients complete CapFi’s Customer Documentation Records that includes questionnaires and other requests for information.
Investor questionnaires and other information provided by the investor in writing, in person, by telephone, electronically or by any other means. This information may include name, address, employment information and financial and investment qualifications as applicable;
Information about investors from financial institutions and service providers that an investor has authorized to provide such information to CapFi; and
Verification services and consumer reporting agencies, which may include information regarding an investor’s creditworthiness or credit history, as applicable.

Disclosure of Nonpublic Personal Information

CapFi does not disclose nonpublic personal information about investors or potential investors to affiliates or non-affiliated third parties except as permitted by law.  CapFi may share nonpublic personal information about investors, without the investor’s consent, with affiliated and non-affiliated parties in the following situations, among others:

In connection with the administration and operations of CapFi products and services, with its brokers, attorneys, accountants, auditors, administrators or other service providers;
To respond to a subpoena or court order, judicial process or regulatory inquiry;
In connection with a proposed or actual sale, merger or transfer of all or a portion of its business;
To protect or defend against fraud, unauthorized transactions (such as money laundering), law suits, claims or other liabilities;
To respond to requests for information regarding compliance with anti-money laundering laws, anti-terrorist due diligence, disclosure or reporting requirements;
Upon consent of an investor to release such information, including authorization to disclose such information to persons acting in a fiduciary or representative capacity on behalf of the investor;
To assist CapFi in offering affiliated products and services to investors; and
CapFi may share nonpublic personal information about investors at investor direction or with investor consent.

Former and Prospective Investors

This same Privacy Policy applies to prospective and former investors.

Protection of Subscriber Information

CapFi maintains physical, electronic and procedural safeguards that comply with federal standards to protect investor information. CapFi restricts access to the personal information of investors to those registrants and employees who need to know that information in the course of their job responsibilities.

Further Information

CapFi reserves the right to change its Privacy Policy at any time. The examples contained within this Policy are illustrations and are not intended to be exclusive. CapFi’s Privacy Policy complies with federal law regarding privacy. Investors may have additional rights under other domestic or foreign laws that may apply.