True North Resources, LLC, a Florida limited liability company (the “Company”) acts as the manager for a number of private funds. The Company and its principals and/or affiliates collect, utilize, and maintain nonpublic personal information about the funds’ investors, as required under recently enacted Federal legislation.

This privacy policy only applies to nonpublic information concerning investors who are individuals, not entities.

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Collection of Investor Information

The Company collects personal information about investors mainly through subscription documents, investor questionnaires, other written documents provided by investors, personal meetings, telephone calls, electronically, and through transactions within the Company. This information may include names, addresses, nationalities, tax identification numbers, financial and investment qualifications, account balances, investments, and withdrawal information.

 

Disclosure of Nonpublic Personal Information

The Company does not sell or rent investor information. The Company does not disclose nonpublic personal information about investors to nonaffiliated third parties or to affiliated entities, except as permitted by law. For example, the Company may share nonpublic personal information in the following situations:

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1. To service providers in connection with the administration and servicing of the Company, which may include attorneys, accountants, accountants, and other professionals. The Company may also share information in connection with the servicing or processing of Company transactions;

2. To affiliated companies in order to provide you with ongoing personal advice and assistance with respect to the products and services you have purchased through the Company and to introduce you to other products and services that may be of value to you;

3. To respond to a subpoena or court order, judicial process or regulatory authorities;

4. To protect against fraud, unauthorized transactions (such as money laundering), claims or other liabilities; and

5. 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

The Company’s policy is to require that all employees, financial professionals and companies providing services on its behalf keep client information confidential. Additionally, the Company maintains safeguards that comply with Federal standards to protect investor information. The Company restricts 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 the Company shares investor information must agree to follow appropriate standards of security and confidentiality. The Company’s privacy policy applies to both current and former investors. The Company may disclose nonpublic personal information about a former investor to the same extent as for a current investor.

 

Changes to the Privacy Policy

The Company may make changes to its privacy policy after sending investors a revised privacy policy describing the change.

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Anti-Money Laundering Obligations

The Company will comply with applicable U.S. anti-money laundering regulations. In addition, the Company could be requested or required to obtain certain assurances from applicants making capital contributions, disclose information pertaining to them to governmental, regulatory, or other authorities or to financial intermediaries or engage in due diligence or take other related actions in the future. It is the Company’s policy to comply with requirements to which it is or may become subject. Each applicant will be required to agree in the Subscription Agreement, and will be deemed to have agreed by reason of owning an interest in the Company, that it will provide additional information or take such other actions as may be necessary or advisable for the Company (in the sole judgment of its management) to comply with any requirements, related legal processes, or appropriate requests (whether formal or informal). Each applicant, by executing the Subscription Agreement and by owning an interest in the Company, is deemed to have consented to disclosure by the Company and its agents to relevant third parties of information pertaining to it in respect of requirements or information requests related thereto. Failure to honor any such request may result in a mandatory withdrawal by the Company or a forced sale to another Partner of such applicant’s interest.

 

For further information, see your Subscription Agreement itself. Subscribers should ensure all applicable documentation specified in the Subscription Agreement accompanies such submitted Subscription Agreement.