We are providing this Privacy Notice in compliance with the Federal Trade Commission’s rules regarding the privacy of personal, nonpublic information of our investors (the “Privacy Rules”). This Privacy Notice explains the manner in which Menlo Equities collects and uses nonpublic personal information about our investors.

In connection with the formation of any investment funds, we collect and maintain nonpublic personal information about our investors from the following sources:

  1. Information we receive from you on subscription agreements, investor questionnaires, limited partnership agreements or other forms or contracts, such as name, address and social security number;
  2. Information about your transactions with our investment funds, such as amounts contributed and distributed and your capital accounts; and
  3. Information obtained from meetings and telephone conversations with you.

Menlo Equities is committed to protecting your privacy and maintaining the confidentiality and security of your personal information. We only disclose personal information we receive from you (i) to third parties if it is necessary or appropriate for the effective management and administration of the investment funds in which you invest, (ii) to service providers (but only to the extent permitted by law), (iii) with your consent or as directed by you and (iv) as required by law. These disclosures include ones made to:

  1. Financial service providers, such as broker-dealers, placement agents, custodians, banks and others used to facilitate transactions for our funds;
  2. Other service providers, such as legal, accounting or tax preparation services;
  3. Other partners of our funds in connection with closing documentation, financial statements and other reports or other partner communications; and
  4. Transfer agents, portfolio companies, brokerage firms and the like, in connection with distributions to our partners.

Menlo Equities has always considered the protection of sensitive personal information to be a sound business practice, and we intend to continue to scrupulously guard the privacy of our investors. We do maintain records of the information provided by our former investors and apply the same policies to them that apply to current investors. We restrict access to nonpublic personal information about you to those employees who need to know that information to provide services to you. We maintain physical, electronic and procedural safeguards to guard the nonpublic personal information that we have obtained from you.