Effective Date: October 1, 2024
Information Collection and Use
Graphene Capital Management ("GCM") collects and uses nonpublic personal information about our clients and investors to provide investment management services. This information may include:
- Personal identifiers (e.g. name, address, Social Security number)
- Financial information (e.g. income, assets, account balances)
- Transaction history
- Investment objectives and risk tolerance
Information Sharing and Disclosure
GCM does not disclose nonpublic personal information about our clients or investors to nonaffiliated third parties, except as permitted or required by law. We may share information with affiliated entities or service providers that assist us in providing services to you.
Information Security
We maintain physical, electronic, and procedural safeguards to protect your nonpublic personal information. Our employees are permitted to access client information only for legitimate business purposes.
Access to Information
You have the right to access and request correction of any personal information we maintain about you. Please contact us to request access or corrections.
Changes to Privacy Policy
We reserve the right to amend this privacy policy at any time. We will notify clients of any material changes as required by law.
Contact Information
If you have any questions about this privacy policy, please contact:
Graphene Capital Management
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