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Maintaining the confidentiality of client personal financial information is very important to KWK Management, LLC (“KWK Management”).  To provide clients with superior service, KWK Management may collect several types of nonpublic personal information about clients, including:

●   Information from forms that clients may complete and send to KWK Management in connection with KWK Management’s services (such as name, address, and social security number).

●   Information a client may verbally communicate to KWK Management.

●   Information about the dollar amount clients have invested with KWK Management or in a private investment fund (such as initial investment and any additions to and withdrawals from a capital account).

●   Information about any bank account clients may use for transfers between a bank account and KWK Management’s managed accounts or a capital account of a private investment fund.

KWK Management does not sell or disclose client personal information to anyone except as permitted or required by law.  For example, KWK Management may share information collected about its clients with KWK Management’s independent auditors.  KWK Management may share this information with KWK Management’s legal counsel as it deems appropriate and with regulators.  Additionally, a copy of the client’s tax Form K-1 is included in a private investment fund’s tax return filed with the Internal Revenue Service.  Finally, KWK Management may disclose information about clients at the client’s request (for example, by sending duplicate account statements to someone designated by the client), or as otherwise permitted or required by law.

Within KWK Management, access to information about clients is restricted to those employees who need to know the information to service client accounts.  KWK Management employees are trained to follow our procedures to protect client privacy and are instructed to access information about clients only when they have a business reason to obtain it. KWK Management reserves the right to change its privacy policy in the future.



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