Privacy policy


This privacy policy sets out how Firmwareuses and
protects any information that you provide Firmware.
Firmware is devoted to ensuring that your privacy is protected. Should we ask you to
provide certain information by which you can be identified when accessing your account
information, you can be assured that such information will only be used in accordance
with this privacy statement.
Firmware has a firm policy of protecting the confidentiality and security of information
that we collect from our Investors. We do not share your non‐public personal
information with unaffiliated third parties. Information is only shared with your consent
except for the specific purposes below, in accordance with all applicable laws. Please
read this policy carefully. It gives you important information about how we handle your
personal information.
Firmware reserves the right to change this policy at any time.


We limit the collection and use of non‐public personal information to the minimum we
believe is necessary to deliver superior service to you. Services can include advising you
about our investments, services and other opportunities, maintaining your account with
us, providing you with your K‐1 tax documents so that you can properly file your
returns, processing distribution and contribution transactions and administering our


We obtain most non‐public personal information directly from you or your agents
whether in person, by telephone or electronically.
We may obtain the following information:
• First name, last name and job title


We do not disclose any kind of non‐public personal information about our Investors or
former Investors to anyone, except when we believe it necessary for the conduct of our
business, or where disclosure is required by law. Except in those specific, limited
situations, without your consent, we will not make any disclosures of non‐public
personal information to other companies who may want to sell their products or
services to you.


We require this information to understand your needs and provide you with better
service, and in particular for the following reasons:
• Internal record keeping
• We send email about new investment properties, investor statements, valuation
statements, capital calls or other information which we think may be valuable
using the email address which you have provided
• From time to time, we may also use your information to contact you for general
account information and for collecting capital calls. We may contact you by
email, phone, fax or mail
• We may use the information to customize our website to provide better service
to you
• We are required by law to provide certain information, including social security
numbers and addresses, to the Internal Revenue Service and state and local
taxing authorities


We are committed to ensuring that your information is secure. In order to prevent
unauthorized access or disclosure we have put in place suitable physical, electronic and
managerial procedures to safeguard and secure the information we collect. In ensuring
that your information is secure we partner with Miles Technologies, a leading provider
of technology‐based business solutions to small and medium‐sized businesses. Miles
Technologies uses the Barracuda Web Site Firewall that provides award-winning
protection against hackers leveraging protocol or application vulnerabilities to
instigate data theft, denial of service or defacement of their Web site.
Powerful, Complete Solution
The Barracuda Web Site Firewall protects Web applications and Web services from
malicious attacks, and can also increase the performance and scalability of these
applications. The Barracuda Web Site Firewall offers every capability needed to
deliver, secure and manage enterprise Web applications from a single appliance
through an intuitive, real-time user interface.
• Single point of protection for inbound and outbound traffic for all Web
• Protects Web sites and Web applications against application layer attacks
• Delivers best practices security right out of the box
• Monitors traffic and provides reports about attackers and attack attempts
• Protection against common attacks
• Outbound data theft protection
• Web site cloaking
• Granular policies
• Secure HTTP traffic
• SSL Offloading
• SSL Acceleration
• Load Balancing
Controlling your personal information
We will not sell, distribute or lease your personal information to third parties unless we
have your permission or are required by law to do so.