This Privacy Notice explains the manner in which we collect, utilize and maintain nonpublic personal information about our Limited Partners.  This Privacy Notice applies only to Limited Partners who are individuals.

We are committed to protecting your privacy and maintaining the confidentiality and security of your personal information.  We are sending you this Privacy Notice to help you understand how we handle the personal information about you that we collect and how we use that information.

Categories of Information We Collect and May Disclose

We use the personal information collected about you in order to provide you with better service or to comply with applicable law and regulations.  We may collect nonpublic personal information about you from the following sources:

• Investor Questionnaires, Limited Partnership Agreements or other forms (for example, name, address, Social Security number, assets and income);

• Ownership records of the fund in which you are a Limited Partner (such as the amount of your percentage ownership interest and any capital commitment); and

• Other interactions with us or our affiliates (such as discussions or other contacts with our staff, via telephone, written correspondence, and electronic media).

We may disclose nonpublic personal information we collect about you to our affiliates (including those who are involved in the operation, administration or management of, or the sale of interests in the fund of which you are a Limited Partner) and nonaffiliated service providers, only as permitted by applicable law and regulations.  For example, we may share nonpublic personal information about you in the following situations:

• In connection with the administration and operations of the fund of which you are a Limited Partner, including disclosure to attorneys, accountants, auditors, administrators, or companies that assist us with mailing statements or processing your transactions, or other professionals;

• To broker-dealers, custodians and transfer agents to facilitate in-kind distributions of portfolio securities;

• To respond to a subpoena or court order, judicial process or regulatory inquiry; and

• At your direction or with your consent, including upon your authorization to disclose such information to persons acting in a fiduciary or representative capacity on your behalf.

We may also share your personal information with other providers of services necessary or convenient to the formation, operation or dissolution of the fund of which you are a Limited Partner.  Finally, as required or permitted by the Limited Partnership Agreement, we may distribute to all partners in such fund certain personal financial information, such as capital account information and various schedules to the Limited Partnership Agreement.

The information of our former Limited Partners is treated in the same manner as the information of our current Limited Partners. 

Confidentiality and Security 

We have always considered the protection of sensitive information to be a sound business practice and a foundation of customer trust.  We protect personal information we collect about you by maintaining physical, electronic and procedural safeguards.

Within our management entities we restrict access to nonpublic personal information about you to those employees who need to know that information to provide products or services to you.

Further Information

We reserve the right to change this Privacy Notice at any time.  The examples contained within this notice are illustrations and are not intended to be exclusive.  This notice complies with United States federal law regarding privacy.  You may have additional rights under other foreign or domestic laws that may apply to you.

If you have any questions regarding how JTS uses or collects personal data, your privacy rights, including GDPR, please contact info@jtscap.com.