Maintaining the confidentiality of investor personal information is very important to KWK Management, LLC (“KWK Management”, “the Firm”, “we”, “us”, “our”). To service our relationship with our investors, we may collect several types of personal information, including:
- Personal information from subscription agreements and other forms that investors complete and send to KWK Management in connection with the Firm’s services such as name, address, email addresses, phone numbers, date of birth, driver license number, passport number, and social security number.
- Information an investor may communicate to KWK Management via phone, email or other written correspondence.
- Information from third party sources in connection with complying with requirements relating to anti-money laundering, taxation, and other legislation applicable to the financial services industry or for vetting or screening purposes.
- Information about the dollar amount investors have invested in a private investment fund managed by KWK Management (such as initial investment and any additions to and withdrawals from a capital account).
- Information about any bank account investors may use for transfers between a bank account and a capital account of a private investment fund managed by KWK Management.
- Other financial information investors may provide to KWK Management.
KWK Management does not sell investor information, and we will not disclose investor personal information to anyone except as permitted or required by law. For example, we share specific information collected about our investors with our independent auditors, our custodians, and our fund administrator. We may share investor information with the Firm’s legal counsel, as we deem appropriate, and with regulators. Additionally, a copy of the investor’s tax Form K-1 is included in a private investment fund’s tax return filed with the Internal Revenue Service. Finally, KWK Management may disclose information about investors at the investor’s request (for example, by sending duplicate account statements to someone designated by the investor), or as otherwise permitted or required by law.
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 offices. Within KWK Management, access to information about investors is restricted to those employees or other associated persons who need to know the information to service investor accounts. Our employees and associated persons are trained to follow the Firm’s procedures to protect investor privacy and are instructed to access information about investors only when they have a business reason to obtain it.
We will retain your personal information for the duration of your relationship with KWK Management and for a period of time after your account is closed as specified under applicable law.
Individual investors residing in the EU or natural persons investing in our offshore fund have certain rights regarding personal information including: 1) the right to be informed, 2) the right to access and data portability, 3) the right to rectification, 4) the right to object, 5) the right to be forgotten, 6) rights in relation to automated decision making, and 7) the right to complain or seek compensation.