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). However, certain unregistered investment vehicles and other unregistered investment products PPM has sponsored have individual investors. PPM collects certain nonpublic personal information about individuals who invest or consider investing in such unregistered investment vehicles and products and retains information such as the investor’s name, address, telephone and social security numbers, as well as other financial information regarding income and assets, liabilities and debt as well as bank and brokerage account information. PPM may collect this information directly from investors or may receive it from service providers to the respective vehicle or product.
As a result, PPM provides privacy notices to such individual investors. In general, PPM does not share nonpublic personal information regarding such individual investors except as described below.
PPM may disclose any of the information we collect about individual investors to our affiliates or other persons that provide necessary services to the respective unregistered investment vehicle or product (such as its trustee, custodian, administrator, and accountants) where such disclosure is permitted or required by law or is authorized by the investor.
For example, PPM may disclose this information:
- To government entities, in response to subpoenas or to comply with laws or regulations
- When an investor directs us to do so or consents to the disclosure
- To companies that perform necessary services for the relevant vehicles or products, such as external auditors, outside counsel, and service providers that process or service transactions (custodians, broker-dealers, and banks)
- To protect against fraud or to collect unpaid debts
Access to nonpublic personal information about individual investors is limited to PPM employees who need to know that information to provide services. Our affiliates and third parties (such as the service providers described above) are permitted to use nonpublic personal information only for specific purposes and are not permitted to use or share this information for any other purpose. PPM maintains physical, electronic and procedural safeguards to guard nonpublic personal information about investors.
We also restrict access only to those employees who need to know to provide services related to such investors.
Internet Privacy Considerations
If an individual visits PPM's website, he or she will travel through the website pages anonymously. PPM tracks only the fact that someone has entered the site and has visited certain pages.