This notice describes the Privacy Policies of FirstMark Capital, LLC (“FirstMark”) regarding how FirstMark and/or its affiliates handle and protect personal information that is received about its prospective, current or former clients/investors.
FirstMark collects personal information primarily to provide investment management services, communicate information about its products and services and process subscriptions in its private investment vehicles. Personal information, which may be obtained from discussions with you and documents you may deliver to FirstMark, may include your:
• telephone number;
• social security number or tax identification number;
• assets, net worth and income;
• bank account information; and
• occupation (collectively, “Personal Information”).
FirstMark permits only authorized individuals, who have been advised as to the proper handling of client information, and who need to access this information to perform services, to have access to this information. These authorized individuals are required to maintain and protect the confidentiality of Personal Information. FirstMark maintains physical, electronic and procedural safeguards to protect Personal Information.
In order to service your account and process transactions for your account, FirstMark may provide Personal Information to its affiliates and to non-affiliated third party financial service providers that assist FirstMark in servicing your account and have a need for such information, such as a broker-dealer or administrator. In addition, FirstMark may share Personal Information with non-affiliated third party non-financial service providers, in order to process or service client transactions or products. Unaffiliated third parties in this instance may include service providers such as word processors and printers. Any such contract entered into by FirstMark will include provisions designed to ensure that the third party will uphold and maintain FirstMark’s privacy standards when handling Personal Information. FirstMark may also disclose Personal Information to regulatory authorities as required or permitted by applicable law. FirstMark does not otherwise provide information about you to outside firms, organizations or individuals except at your request or to our attorneys, accountants and auditors and as permitted by law.
Except as described in this Privacy Notice, FirstMark will not use Personal Information for any other purpose unless FirstMark describes in advance how such Personal Information will be used and you are given an opportunity to decline approval of such use of your Personal Information.
All material changes to this privacy notice will be posted on FirstMark’s websites at www.FirstMarkcap.com, offered to existing clients of FirstMark and made available upon request. If you have any questions or concerns about your Personal Information or this Privacy Notice, please contact Investor Relations at info@FirstMarkcap.com.
Effective Date: July 1, 2008