Collection of investor information

Threesixty Elements collects personal information about its investors mainly through the following sources:
• subscription forms, investor questionnaires and other information provided by the investor in writing, in person, by telephone, electronically or by any other means. This information includes name, address, nationality, tax identification number, and financial and investment qualifications; 
• transactions within the managed funds entities, including account balances, investments and redemptions.

Disclosure of nonpublic personal information

Threesixty Elements does not sell or rent investor information. We do not disclose nonpublic personal information about investors to nonaffiliated third parties or to affiliated entities, except as permitted by law. For example, we may share nonpublic personal information in the following situations:
• to service providers in connection with the administration and servicing of the managed funds, which may include attorneys, accountants, auditors and other professionals. Fund entities may also share information in connection with the servicing or processing of transactions;
• to affiliated companies in order to provide you with ongoing personal advice and assistance with respect to the products and services you have purchased earlier through entities of the group and to introduce you to other products and services that may be of value to you;
• to respond to a subpoena or court order, judicial process or regulatory authorities;
• to protect against fraud, unauthorized transactions (such as money laundering), claims or other liabilities; 
• 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.

Protection of investor information

Threesixty Elements’ policy is to require that all employees, financial professionals and companies providing services on their behalf keep client information confidential.
We restrict access to the personal and account information of investors to those employees who need to know that information in the course of their job responsibilities. Third parties with whom we share investor information must agree to follow appropriate standards of security and confidentiality.
Threesixty Elements’ privacy policy applies to both current and former investors. We may disclose nonpublic personal information about a former investor to the same extent as for a current investor.

Changes to privacy policy

Threesixty Elements may make changes to privacy policy in the future.