Privacy Policy

PivotalPath (Americas) LLC (“PivotalPath”) considers client privacy to be a fundamental aspect of our client relationships. We are committed to maintaining the confidentiality and security of our clients’ personal information. In the course of providing you with advisory services, we may collect, retain, and use client information for the purpose of administering our operations, providing client service, and complying with legal and regulatory requirements. This information may come from sources such as account applications, investment policy statements, from your transactions, and other forms from other written, electronic or verbal correspondence from different sources.

PivotalPath may disclose such information about our current, prospective and former clients to other affiliates (i.e. financial and non-financial companies related by common ownership or control) or non-affiliates (i.e. financial or non-financial companies not related by common ownership or control) for our everyday business purposes, such as to process your transactions, maintain your account(s) or respond to court orders and legal investigations. It may be necessary, under anti-money laundering and similar laws, to disclose information to comply with regulations. We will also release information about you if you direct us to do so. We may also disclose information about your transactions and experiences with us to our affiliates for their everyday business purposes. You cannot limit these types of sharing. We may also disclose information you provide to us to companies that perform marketing services on our behalf, such as any sales agent that we may retain. If such a disclosure is made, the Fund will require such third parties to treat your private information with confidentiality.

We do not otherwise share your information with affiliates or non-affiliates. If we intend to otherwise share your information with other affiliates or third parties, we will provide you with prior notice. You may contact us at any time to discuss limiting these types of sharing. To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings.

If you have any questions about this Privacy Notice, email info@pivotalpath.com or, if you do not have email, call (212) 257-4860.