Collection of Investor Information
Vivaldi collects the following Investor Information:
- Name, address, contact information, social security number, nationality, employment information, and financial and investment qualifications (including income, assets and investment experience) as well as wire transfer instructions from investor questionnaires, subscription documents, account forms, and other information provided by investors in writing, in person, by telephone, electronically or by any other means; and
- Account balances, investments, withdrawals/redemptions and fees from account activity.
In addition to collecting information through conversation and from documents provided to Vivaldi, Vivaldi may acquire information about investors from verification services and consumer reporting agencies. Such information may include an investor’s creditworthiness or credit history. Vivaldi does not generally use these services.
Disclosure of Nonpublic Personal Information
Vivaldi may share Investor Information in the context of providing everyday business services. Such services include investigating and responding to investor inquiries about their accounts and investments, processing transactions, maintaining accounts, and responding to court orders. Additionally, Vivaldi may share Investor Information with affiliates, as permitted or required by law.
Vivaldi does not disclose nonpublic personal information about investors or potential investorsto nonaffiliated third parties, except as permitted by law (for example, to service providers who provide services to investors).
Protection of Investor Information
To protect Investor Information from unauthorized access and use, Vivaldi uses security measures in accordance with federal law and applicable state standards. These measures include computer safeguards and secured files and buildings. Further, Vivaldi restricts access to investors’ personal and account information to those employees with a need to know that information in the course of fulfilling their job responsibilities. Vivaldi and its service providers will destroy, erase or make unreadable data, computer files and documents containing nonpublic personal information prior to disposal.