Introduction

Pursuant to U.S. Securities and Exchange Commission (“SEC”) Regulation S-P, investment advisers must adopt and implement policies and procedures designed to: 1) ensure the security and confidentiality of client records and information; 2) protect against any anticipated threats or hazards to the security or integrity of client records and information; and, 3) protect against unauthorized access to or use of client records or information that could result in substantial harm or inconvenience to any client.

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Furthermore, investment advisers must provide their individual clients (or alter egos thereof such as IRA accounts and revocable grantor trusts) with an initial privacy notice at the time a client relationship is established and an annual privacy notice thereafter if they share non-public personal information with non-affiliated third parties (other than service providers or as required by law or regulation) or if the adviser’s privacy policy as described in the most recent annual notice has changed.

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As private funds or other pooled investment vehicles are not natural persons, investment advisers are not required to provide privacy notices to each private fund or other pooled investment vehicle client; however, Federal Trade Commission (“FTC”) rules require that private funds or other pooled investment vehicles provide their investors, who are natural persons, with initial and annual privacy notices. Investment advisers typically provide the privacy notices to investors on behalf of the private funds or pooled investment vehicles.

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Policy

Greenline Partners, LLC (“Greenline”) does not disclose any non-public personal information about its clients to non-affiliated third parties except to service or manage the client accounts or as permitted by law. Furthermore, Greenline restricts access to the personal information of its clients to those employees who need that information to provide products or services to the clients. If a client closes their account, Greenline will continue to adhere to its privacy policy with respect to the non-public personal information of that client. The disposal of non-public personal information shall be done in a secure manner as described in Greenline’s Compliance and Policy Manual.

Collection of Information

Greenline may possess non-public personal information about clients to serve investment needs, provide customer service, and comply with legal and regulatory requirements. The type of non-public personal information Greenline may possess may include the following:​

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• Names,

• Addresses,

• Telephone numbers,

• Information regarding existing accounts,

• Driver's license,

• Financial status as it relates to qualifying for an investment in a private fund managed by Greenline (e.g. assets and income).

 

Greenline collects this information from the following sources:

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• The documents delivered in connection with making an investment in a private fund managed by Greenline, including subscription documents,

• Transactions with Greenline and its affiliates in which the client participates,

• Correspondence and other communications (including telephone, mail, and e-mail).

 

Opt-Out Right

Every client has the right to direct Greenline to not disclose the non-public personal information about that client to a non-affiliated third party. If a client would like to exercise its right to ‘opt out’ of Greenline’s privacy policy, such client must provide a written statement exercising that right. This right to opt out may be exercised at any time and will remain in effect until written notice revoking said right is received by Greenline from the client. However, in the event Greenline encounters circumstances where it is compelled by law to disclose the non-public personal information, Greenline must provide the information even if the client has exercised its right to opt out.

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Confidentiality and Security

Except as described below, access to non-public information about existing, former, and prospective clients is restricted to Greenline employees who need to know that information in order to provide products or services to clients. Those employees with access to non-public personal information are required to protect the confidentiality of that information. Greenline maintains physical and procedural safeguards to protect non-public personal information.

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Physical Safeguard Procedures

1. When in use, client information will not be left unattended,

2. Greenline’s office is located in a secured building and is locked off hours to prevent unauthorized entry onto the premises,

3. Physical access to Greenline’s office is limited to authorized personnel only and any visitors will remain escorted at all times,

4. Any hard copy documents containing client information that are not to be retained will be disposed of promptly.

 

Electronic Safeguard Procedures

1. All computers with access to client information are password protected and have active and current anti-virus, anti-spyware, and firewall protection,

2. When not in use, all computers will be locked in screen saver mode.

 

Anti-Identity Theft Procedures

In addition to complying with procedures above regarding safeguarding of non-public personal information, Greenline will only transfer funds to client accounts that are in the name of the client of record and, in the case of wire transfers, to such client’s account as identified upon the opening of the account. No payment of any client funds will be knowingly sent to any third party, and Greenline’s financial or accounting personnel will report suspicious requests for third-party payments or changes to client account or wire information to the CCO.

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Uses of Information

Client non-public personal information may be used internally by employees of Greenline to process subscriptions and provide services to such clients or the private funds in which they are invested.

Greenline may also provide non-public personal information about its prospective, existing, and former clients to the following:

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• Unaffiliated financial service providers, such as a broker-dealers, custodians, or other firms that have a need for such information in order to service or process a financial product or service requested or authorized by such client or who will maintain or service such client’s account on Greenline’s behalf,

• Broker-dealers, issuers of securities, and their counsel in connection with determinations of eligibility and participation in private securities placements,

• Attorneys, accountants, and auditors retained by Greenline, to the extent required by them to perform services for Greenline and its clients,

• As permitted or required by federal, state, or local law, such as in response to a subpoena, to prevent fraud, or to comply with an inquiry or other requirement of a governmental agency or regulator,

• To an affiliate of Greenline whose privacy and confidentiality policy is at least co-extensive with Greenline.

 

Many jurisdictions are in the process of creating or changing anti-money laundering, embargo and trade sanction, or similar laws, regulations, requirements or regulatory policies (whether or not with force of law) and many financial intermediaries are in the process of creating or changing responsive disclosure and compliance policies (collectively “AML Policies,” which are further described in Greenline’s Compliance and Policy Manual). Greenline may provide non-public personal information collected from clients, former clients, and prospective clients in respect of AML Policies or information requests related thereto to relevant third parties.