Privacy
September 30, 2004

 

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 we collect and use nonpublic personal information about our investors.

Confidentiality and Security

We are committed to protecting your privacy and maintaining the confidentiality and security of your personal information. We have 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 will maintain records of the information provided by any 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 s afeguards to guard the nonpublic personal information that we have obtained from you.

Categories of Information We Collect

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

  • Information we receive from you on subscription agreements, investor questionnaires, LLC agreements or other forms or contracts, such as name, address and social security number;
  • Information about your transactions with our investment funds, such as amounts contributed and distributed and your capital accounts;
  • Information obtained from meetings and telephone conversations with you; and
  • Information we collect through operation of our website, including personal information and any information we collect using “cookies”.  Currently investors may voluntarily enter and share with other Legacy investors their personal information, including contact information and areas of philanthropic interest and involvement.  Other Legacy investors whom Legacy provides with a log-in name and password can view information that an investor allows to be shared.  Legacy can not guarantee that this system cannot be broken into by others or that other investors will restrict their use of this information to the originally intended purposes of encouraging philanthropic collaboration among investors.

Disclosure

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:

  • Financial service providers, such as broker-dealers, custodians, banks, donor-advised funds, donor-designated charities, and others used to facilitate transactions for investors or our private funds;
  • Other service providers to our investment funds, such as legal, accounting, tax preparation, and investor communication services;
  • Other investors in our investment funds in connection with closing documentation, investor financial or other reports or other investor communications;
  • Transfer agents, venture capital firms, brokerage firms, donor-advised funds, donor-designated charities, and the like, in connection with handling distributions to our investors.