Protecting your privacy is important to us and we want you to know how we treat your nonpublic personal information. The policy of Windmuehle is to protect the confidentiality, integrity, and security of any nonpublic personal information of its members and prospective members, and to prevent unauthorized access to, or the use or disclosure of such information. In its capacity as an investment adviser, Windmuehle receives and/or comes into contact with certain nonpublic personal information concerning its current and/or former members through information received from a member through data collected from subscription documents, other related forms and information about a member’s transactions with the funds managed by Windmuehle including data from service providers that is necessary to carry on everyday business. 

Windmuehle protects the security and confidentiality of the nonpublic personal information collected and make efforts to ensure that such information is used for proper business purposes in connection with the management or servicing of the funds and members.

Windmuehle does not sell your nonpublic personal information to anyone. Nor does Windmuehle provide such information to others except to service providers that have been advised as to proper handling of the information and otherwise as permitted or required by law and regulation.

Windmuehle restricts access to nonpublic personal information about its members to those employees and agents of Windmuehle who have been advised as to the proper handling of such information and who need to know that information to provide services to its funds and members. Windmuehle may also disclose such information to its affiliates and to service providers and financial institutions that provide services to the funds that are necessary or appropriate for the administration of the funds and the effectuation of its transactions or are otherwise permitted by law, such as prime brokers and administrators. A member cannot opt out of allowing Windmuehle to share nonpublic personal information with non-affiliated third-party service providers and financial institutions which are necessary to providing services to our members. Windmuehle does not share member information with any third parties that do not need the information to provide a necessary service. Windmuehle will require such third-party service providers and financial institutions to protect the confidentiality of the members’ nonpublic personal information and to use the information only for purposes for which it is disclosed to them. Windmuehle may also disclose nonpublic personal information to regulatory authorities as required or permitted by applicable law. Windmuehle maintains physical, electronic, and procedural safeguards that comply with federal standards to safeguard the members’ nonpublic personal information and which Windmuehle believes is adequate to prevent unauthorized disclosure of such information. Nonpublic personal information regarding members will be maintained during the time a member is a client, and for the required time thereafter that such records are required to be maintained by federal and state securities laws. After this required period of record retention, all such information will be destroyed.

We will send our members a notice of our Privacy Policy for as long as a member maintains an ongoing relationship with Windmuehle. Periodically we may revise our Privacy Policy and will provide a revised policy if the changes materially alter the previous Privacy Policy. We will not, however, revise our Privacy Policy to permit the sharing of nonpublic personal information other than as described in this notice unless we first notify our members to provide members with an opportunity to prevent the information sharing.

Windmuehle does not otherwise provide information about current, former, and prospective individual members to outside firms, organizations, or individuals except at the subscriber’s request or to attorneys, accountants, and auditors of any current, former, and prospective members.

If you have any questions concerning this privacy policy, please contact Robert Lee, CCO at Robert.Lee@windmuehlefunds.com.

For residents of California please refer to our California Privacy Policy.

For residents of the UK or EU please refer to our UK/EU Privacy Policy.