Adviser Privacy Notice

Our Commitment to Your Privacy

Mebanewood Management LLC recognizes the importance of protecting the confidentiality and security of personal information.

This Adviser Privacy Notice describes how Mebanewood Management LLC and, where applicable, its affiliated entities collect, use, disclose, and protect nonpublic personal information in connection with the Firm’s investment advisory business.

This notice applies to individuals who are current or former advisory clients and, to the extent applicable, prospective clients, investors, representatives, beneficial owners, trustees, authorized persons, and other individuals whose personal information the Firm receives in connection with providing or considering financial products or services.

In this notice, “Mebanewood Management,” “Mebanewood,” “the Firm,” “we,” “us,” and “our” refer to Mebanewood Management LLC.

Personal Information We Collect

The nature of the information we collect depends on the relationship, services requested, account structure, and applicable legal and regulatory requirements.

We may collect personal information from the following sources:

Information You Provide

We may receive information from applications, agreements, questionnaires, subscription documents, tax forms, correspondence, identification documents, and other materials, including:

• name, address, email address, and telephone number;
• date of birth and government-issued identification information;
• Social Security number, taxpayer identification number, or similar identifiers;
• citizenship, residency, and tax status;
• employment, occupation, and organizational affiliations;
• financial condition, income, net worth, assets, liabilities, and investment holdings;
• investment objectives, experience, risk tolerance, liquidity needs, and time horizon;
• bank, brokerage, custody, and other financial-account information;
• source of funds and source of wealth;
• legal, tax, trust, estate, and beneficial-ownership information;
• signatures, instructions, authorizations, and authentication information; and
• other information you provide in connection with an actual or prospective relationship.

Information About Transactions and Accounts

We may collect information concerning:

• account balances and holdings;
• purchases, sales, deposits, withdrawals, and transfers;
• investment activity and performance;
• advisory fees and other charges;
• account restrictions and investment guidelines;
• communications and instructions;
• custodial and brokerage relationships; and
• other transactions involving the Firm, its affiliates, custodians, brokers, administrators, or service providers.

Information From Other Sources

We may receive information from:

• custodians, brokers, banks, administrators, and other financial institutions;
• accountants, attorneys, consultants, and other professional advisers;
• trustees, fiduciaries, authorized representatives, and account owners;
• affiliated entities;
• identity-verification, compliance, cybersecurity, and fraud-prevention providers;
• consumer-reporting agencies or background-information providers, where permitted by law;
• governmental, regulatory, sanctions, and public-record sources; and
• other persons or sources authorized by you or permitted by law.

How We Use Personal Information

We may use personal information to:

• evaluate and establish advisory or investment relationships;
• provide investment management and related services;
• open, maintain, administer, and service accounts;
• communicate with clients, prospective clients, and authorized persons;
• process instructions and coordinate account activity;
• calculate and collect fees;
• prepare reports, statements, tax information, and other records;
• confirm identity, authority, eligibility, accreditation, or qualification;
• conduct anti-money-laundering, sanctions, fraud-prevention, and other compliance reviews;
• manage investment allocations and conflicts of interest;
• protect accounts, information, systems, and business operations;
• maintain required books and records;
• satisfy contractual, legal, regulatory, examination, reporting, and audit obligations;
• establish, exercise, or defend legal rights and claims;
• support business continuity and incident response; and
• conduct other activities reasonably necessary to operate our advisory business.

How We Share Personal Information

We do not sell personal information.

We may disclose personal information only as reasonably necessary to conduct our business, provide services, administer relationships, comply with law, or as otherwise permitted or required by applicable law.

Our Everyday Business Purposes

We may disclose personal information to nonaffiliated third parties that assist us in operating our business or servicing accounts, including:

• custodians, brokers, banks, and other financial institutions;
• fund administrators and other investment-vehicle service providers;
• accountants, auditors, attorneys, consultants, and compliance professionals;
• information-technology, cloud-hosting, software, communications, and cybersecurity providers;
• data-management, recordkeeping, document-storage, and reporting providers;
• identity-verification, background-screening, sanctions, and fraud-prevention providers;
• insurers and other risk-management providers; and
• governmental, judicial, law-enforcement, and regulatory authorities.

These disclosures may include information necessary to process transactions, maintain accounts, perform services, protect against fraud or unauthorized activity, comply with legal obligations, or respond to lawful requests.

Affiliates

We may share personal information with entities under common ownership or control with Mebanewood Management when reasonably necessary to:

• administer an existing or prospective relationship;
• provide or evaluate requested services;
• conduct internal operations;
• maintain records;
• manage legal, compliance, security, and risk matters; or
• satisfy contractual or regulatory obligations.

Mebanewood affiliates are required to handle personal information consistently with applicable law and appropriate confidentiality and security requirements.

We do not share personal information with affiliates for their independent marketing purposes unless permitted by applicable law and, where required, appropriate notice and choice have been provided.

Other Permitted or Required Disclosures

We may also disclose personal information:

• at your request or with your consent;
• to persons you authorize;
• to protect the rights, property, security, or interests of you, the Firm, or others;
• in connection with an actual or proposed merger, acquisition, financing, restructuring, sale, transfer, or similar business transaction;
• to prevent fraud, unauthorized transactions, claims, or other liability;
• to comply with subpoenas, court orders, regulatory inquiries, examinations, or other legal process; or
• as otherwise permitted or required by applicable law.

Our Information-Sharing Practices

Because Mebanewood does not disclose nonpublic personal information in a manner that currently gives rise to a general opt-out right under applicable financial privacy law, this notice does not include an opt-out election form.

Former Clients

If an advisory or other covered relationship ends, we will continue to treat personal information relating to that relationship in accordance with this notice and applicable law.

Information Security

We maintain administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, use, alteration, disclosure, loss, or destruction.

These safeguards may include:

• access controls based on business need;
• authentication and security controls;
• encryption and secure transmission methods where appropriate;
• cybersecurity and incident-response procedures;
• vendor due diligence and oversight;
• employee training and confidentiality requirements;
• secure record retention and disposal practices; and
• business-continuity and recovery measures.

No security system can eliminate all risk. We therefore cannot guarantee that personal information will never be accessed, used, or disclosed without authorization.

Where required by applicable law, we will investigate security incidents and provide appropriate notice to affected individuals and governmental or regulatory authorities.

Protecting Your Information

You should promptly inform us of changes to your contact information or authorized representatives.

Do not send passwords, authentication codes, wire instructions, government identification numbers, or other highly sensitive information through ordinary email or general website forms.

Before acting on any request involving account access, funds, securities, payment instructions, or changes to account information, Mebanewood or an applicable custodian may require additional verification.

Retention and Disposal

We retain personal information for as long as reasonably necessary to:

• provide services;
• administer current or former relationships;
• maintain required business and regulatory records;
• satisfy contractual, legal, tax, accounting, and regulatory obligations;
• resolve disputes;
• enforce agreements; and
• protect our rights and legitimate business interests.

When records are no longer required, we use measures reasonably designed to dispose of personal information securely, subject to applicable record-retention requirements.

Other Institutions and Services

Custodians, brokers, banks, administrators, and other financial institutions involved in an account or transaction may collect and process personal information under their own privacy notices and legal obligations.

This notice does not govern the independent privacy practices of those institutions.

Changes to This Notice

We may revise this Adviser Privacy Notice to reflect changes in our practices, services, legal obligations, or regulatory requirements.

We will provide an updated notice when required by applicable law. The effective date shown at the beginning of the notice identifies the most recent revision.

Questions

Questions concerning this notice or Mebanewood Management’s privacy practices may be directed to:

+1 (615) 854-8585
contact@mebanewood.com