Pharo Management
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Pharo is committed to protecting your privacy and maintaining the confidentiality and security of your personal information. This Privacy Policy explains the manner in which Pharo collects, utilizes and maintains nonpublic personal information about its investors ("Investors"), as required under Federal Law. "Pharo" collectively refers to Pharo Global Advisors Limited, Pharo Management UK LLP, Pharo Management LLC, and each investment account, partnership, limited liability company or funds for which they serve as investment manager, investment advisor, general partner, managing member and/or director. As noted above, this Privacy Policy only applies to products and services provided by Pharo to individuals (including regarding investments in the Funds) and which are used for personal, family, or household purposes (not business purposes).

I. Collection of Investor Information

Pharo collects personal information about its Investors from the following sources:

  • Subscription forms, investor questionnaires, account forms, and other information provided by the Investor in writing, in person, by telephone, electronically or by any other means. This information includes name, address, employment information, and financial and investment qualifications;
  • Transactions within the Fund, including account balances, investments, withdrawals/ redemptions and fees;
  • Other interactions with Pharo (for example, discussions with our staff); and
  • Verification services and consumer reporting agencies, including an Investor’s creditworthiness or credit history. (Pharo generally does not use these services.)

II. Disclosure of Non-public Personal Information

Pharo may share nonpublic personal information about its Investors or potential Investors with affiliates, as permitted by law. Pharo does not disclose nonpublic personal information about its Investors or potential Investors to nonaffiliated third parties, except as permitted by law (for example, to service providers who provide services to the Investor or the Investor’s account).

Pharo may share nonpublic personal information, without an Investor’s consent, with affiliated and nonaffiliated parties in the following situations, among others:

  • To respond to a subpoena or court order, judicial process or regulatory inquiry;
  • In connection with a proposed or actual sale, merger, or transfer of all or a portion of its business;
  • To protect or defend against fraud, unauthorized transactions (such as money laundering), law suits, claims or other liabilities;
  • To service providers of Pharo in connection with the administration and operations of Pharo, the Fund and other Pharo products and services, which may include brokers, attorneys, accountants, auditors, administrators or other professionals;
  • To assist Pharo in offering Pharo-affiliated products and services to its Investors; and
  • To process or complete transactions requested by an Investor.

III. Former Customers and Investors

The same Privacy Policy applies to former Investors.

IV. Protection of Investor Information

Pharo maintains physical, electronic and procedural safeguards that comply with federal standards to protect customer information. Pharo 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.

V. Further Information

Pharo reserves the right to change this Privacy Policy at any time. The examples contained within this Policy are illustrations and are not intended to be exclusive. This Policy complies with Federal Law regarding privacy.