In the course of managing assets on behalf of various funds for whom we act as investment manager, van Biema Value Partners, LLC (“van Biema”, “our”, “us”, or “we”) collects information from (i) your Subscription Agreement and related documents; (ii) in correspondence and conversations with van Biema's representatives; and (iii) through transactions. The types of personal information van Biema collects and shares may include your Social Security or tax identification number, assets, income information, financial needs and goals, account balances and transactions, investment experience, and wire transfer instructions. We believe that this information is, and should remain, private and confidential.
Your privacy is very important to van Biema and its affiliates. This notice sets forth van Biema’s policies with respect to the collection of non-public personal information from its clients, investors, prospective investors and former investors. These policies may be changed at any time, provided a notice of such change is given to you.
Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires van Biema to tell you how we collect, share, and protect your personal information. When you are no longer an investor in our funds, van Biema will continue to protect and/or share information about you as described in this notice. Investors in Cayman Islands investment funds have broadly analogous rights under the Data Protection Law, 2017 of the Cayman Islands ("DPL"). Investors in Cayman Islands investment funds also have the right to lodge a complaint under the DPL with the Office of the Ombudsman in the Cayman Islands.
All financial companies need to share customers’ personal information to run their everyday business. van Biema discloses, as necessary, your nonpublic personal information for “everyday business purposes,” such as to facilitate the acceptance of your investment in a van Biema private fund (regardless of the location of the offices of such service providers), to process transactions, maintain account(s), respond to court orders and legal investigations, or report to credit bureaus; or (2) as permitted by law. Thus, it may be necessary, under anti-money laundering and similar laws, for van Biema to disclose your nonpublic information prior to accepting your subscriptions. van Biema will also release information about you if you direct us to do so, if compelled to do so by law, or in connection with any government or self-regulatory organization request or investigation. van Biema may also use your personal information to market other van Biema private funds to you. We do not provide your personal information to any unaffiliated entities for the purposes of marketing.
van Biema seeks to carefully safeguard your private information and, to that end, restricts access to non-public personal information about you to those employees and other persons who need to know the information to enable us to provide services to you. van Biema maintains physical (e.g., secured files and building), electronic and procedural safeguards to protect your non-public personal information.
Cayman Islands Data Protection Measures
Any transfer of personal data by us or our duly authorized affiliates and/or delegates outside of the Cayman Islands shall be in accordance with the requirements of the DPL.
We and our duly authorized affiliates and/or delegates shall apply appropriate technical and organizational information security measures designed to protect against unauthorized or unlawful processing of personal data, and against accidental loss or destruction of, or damage to, personal data.
We shall notify you of any personal data breach that is reasonably likely to result in a risk to the interests, fundamental rights or freedoms of either you or those data subjects to whom the relevant personal data relates.
 “Nonpublic personal information” is generally defined as personally identifiable financial information provided by a consumer to a financial institution, resulting from any transaction or any service performed for the consumer, or otherwise obtained by the financial institution.