FRONTLINE HEALTHCARE PARTNERS, LLC
Notice Regarding Privacy of Financial Information
We respect our investors’ right to privacy. In the course of conducting business, we collect and maintain certain nonpublic personal information about our former and current individual investors from different sources. Throughout this notice, we use the term “personal information” to describe information that can be associated with a specific person and used to identify that person. We do not consider personal information to include information that has been anonymized so that it does not identify a specific investor. Specifically, in connection with forming and operating our private investment funds for our limited partners, we collect such personal information from the following sources:
- Information received from investors or their legal representatives in conversations, in voicemails, over our website, including cookies, through written correspondence, including email, submitted in subscription agreements, contracts and questionnaires or other forms or agreements, such as name, address, telephone number and other contact information, occupation, bank account or other account numbers, tax identification number, social security number, the types and amounts of investments, statements of net worth and other Investor qualification information;
- Information about investors’ transactions with us, our affiliates or others, such as participation in other investment opportunities, ownership of accounts and other account data; and
- Information we receive from a consumer reporting agency, such as an individual’s creditworthiness and credit history.
We do not disclose such personal information to any non-affiliated third parties except as set forth below. In the normal course of serving our investors, we may share such personal information with our affiliates or with companies that perform various services for us such as our accountants, auditors, attorneys, fund administrators, consultants, transfer agents, placement agents and other agents, custodians, broker-dealers, service providers, lenders or financial institutions, and as permitted by law. In addition, certain information may be shared with the other investors in the Fund, such as the fact that the Investor is a Limited Partner in the Fund, its contact information and the amount of its Commitment. Other disclosures may be made with the consent of investors, such as to the extent provided in the Subscription Agreement, the Partnership Agreement and/or other agreements. We require third-party service providers and financial institutions with which we have relationships to confirm that they have implemented and maintain appropriate safeguards to protect the confidentiality of personal information and to use the information only for the purpose for which we disclose the information to them. We do not sell any personal information to any third-party, nor do we share any personal information, including mobile opt-in information, with other financial companies for joint marketing purposes.
We store and process investors’ personal information on our computers in the U.S., and we maintain physical, electronic and procedural safeguards designed to comply with applicable U.S. federal and state regulations. To further protect our investors’ personal information, we permit access only by our authorized employees, affiliates, agents or representatives (including, without limitation, those Persons described in the foregoing paragraph) who need access to this information to provide services to us, the Fund and the Limited Partners or other investors. We maintain physical, electronic and procedural safeguards for such information that comply with U.S. federal standards.
We reserve the right to change our privacy policies and this Privacy Notice at any time. This notice complies with the privacy provisions of Regulation S-P. You may have additional rights under other foreign or domestic laws that may apply to you.