|PPM AMERICA, INC.
Effective June 26, 2001
PPM America, Inc. (PPM) does not have individual customers as defined in the
Gramm - Leach - Bliley Act (i.e.: An individual who obtains or has obtained a
financial product or service used primarily for personal, family, or household
purposes). PPM, however, is required to send out notices regarding our privacy
policy on certain investment vehicles as stated under Regulation FD. Certain
CBOs and other investment products sponsored by PPM (Funds) that have
individual investors are included under the regulation. Because those Funds are
unregistered, they are required by FTC regulations (not the SEC) to provide
privacy notices to individual (not institutional) investors regarding their
privacy policies. In general, PPM does not share nonpublic personal information
regarding individual investors except as described in the statement below.
Fund-specific notices for each of the Funds are sent annually to all their
PPM collects certain nonpublic personal information about individuals who
invest or consider investing in an affiliated Fund. In the context of those
Funds, PPM retains personally identifiable financial information about
investors, such as the amount of their interests in the Funds and
representations about their assets, income, and their investment. Investors
provide PPM with some of this information when they invest in the Funds and
when they engage in certain Fund transactions. In addition, PPM receives
information about investors from companies that provide services to the Funds.
about former investors in the funds and individuals who inquire about investing
in the Funds.
Information Collected and Disclosed
to certain investors and possibly their family and generally includes
information provided by investors to PPM in their Fund Subscription Agreement,
such as: name, address and telephone and social security numbers; employment
information, including salary; and information relating to investors' financial
situation, including income and assets and liabilities and debts.
PPM may disclose all of the information we collect about Fund investors to
affiliates, to persons that provide necessary services to the affiliated Fund,
such as its trustee, custodian, administrator, and accountants, or as permitted
by law or authorized by you. For example, PPM may disclose this information:
To government entities, in response to subpoenas or to comply with laws or
||When the investor directs us to do so or consents to the disclosure
||To companies that perform necessary services for the Funds, such as external
auditors, outside counsel, and service providers that process or service
transactions (such as the custodian, broker-dealers, and banks)
||To protect against fraud
||To collect unpaid debts
|Internet Privacy Considerations
If an individual visits PPM's Web site, they will travel through the Web site
pages anonymously. PPM tracks only the fact that someone has entered the site
and has visited certain pages.
Investors who choose to view their account information online will find that
their personal financial information is secured by state-of-the-industry
technology, which as of this writing requires investors to have a username and
password. All data transmission is encrypted with a sophisticated data
encryption program and provides the highest level of security and privacy which
PPM believes is currently available.
information that gets entered into the memory of a visitor's Web browser. The
cookie cannot be read by a Web site other than the one that placed the cookie.
PPM does not require acceptance of cookies in order to visit the Web site.
Access to nonpublic personal information about individual fund investors is
limited to our employees, affiliates and, in some cases, third parties (such as
the service providers described above) as permitted by law. PPM maintains
physical, electronic, and procedural safeguards to guard nonpublic personal
information about investors.
PPM reserves the right to change this policy, or any supporting or related
policies or procedures at any time.