Skylands Capital, LLC
Privacy Policy Notice

When you choose to invest your money with Skylands Capital, LLC (“Skylands”), you not only entrust us with your investments, but also with your personal information and financial data. Just as we are dedicated to managing your money well, we are also committed to respecting your privacy and protecting the personal information that you share with us. Federal law requires us to tell you how we collect, share and protect your personal information. Please read this Privacy Notice carefully.

To provide investment products and services that best suit your needs, we collect and maintain non-public personal information from the following sources:  

• Information we receive from you in conversations over the telephone, in voicemails, through written correspondence, via e-mail and other electronic communications or in subscription agreements, investor questionnaires, account applications, investment advisory agreements or other forms (including, without limitation, any anti-money laundering, identification, and verification documentation); and
• Information about your transactions with us or others.

Such personal information may include your name, address, social security number or taxpayer identification number, birth date, driver’s license data, telephone number, fax number, e-mail address, business affiliations, bank information, assets, income, beneficiaries, and custodial accounts.

We do not disclose any non-public personal information to third party non-affiliates except as necessary to service your account or as permitted or required by law or regulation. To manage and service your account, we may provide certain personal information to various firms that provide trading and execution, settlement and custodial functions, banking, administration, audit, tax and legal work. We may be required to disclose personal information to a government or regulatory body in connection with an examination, investigation or pursuant to legal process. We may share certain account and tax information with your personal accountant, attorney and/or financial consultant per your written or verbal instructions. These non-affiliated third parties have an obligation, contractual or otherwise, to protect the confidentiality of your information and to use it strictly for the purpose for which the disclosure is needed.

We do not share your personal information with third party non-affiliates for marketing or joint marketing purposes, nor do we disclose your creditworthiness to third party non-affiliates unless specifically instructed by you. Note that Skylands does not have any affiliates (i.e., companies related by common ownership or control).

We have established security measures including procedural safeguards, computer and network safeguards and physical safeguards, such as secured files and buildings, which seek to protect your non-public personal information in our possession or under our control. 

We maintain non-public personal information of our former investors and clients and apply the same policies that apply to current investors. We will continue to adhere to the privacy policy described in this notice even after your account is closed or becomes inactive.

We reserve the right to change our privacy policies and this Privacy Notice at any time.  The examples contained within this notice are illustrations only and are not intended to be exclusive. This notice is intended to comply with the requirements of Regulation S-P under the Gramm-Leach-Bliley Act and certain privacy provisions of other laws.  
   
For questions about Skylands’ Privacy Notice, please contact Virginia Shaffar, Chief Compliance Officer at (414) 256-3380.

Privacy Policy Supplement for California Residents

This notice supplements the Privacy Notice set forth above with respect to specific rights granted under the California Consumer Privacy Act of 2018, as amended (the “CCPA”), to natural person California residents and provides information regarding how such California residents can exercise their rights under the CCPA. This supplement is only relevant to you if you are a resident of California as determined in accordance with the CCPA. Information required to be disclosed to California residents under the CCPA regarding the collection of their personal information that is not set forth in this CCPA supplement is otherwise set forth in this Privacy Notice. To the extent there is any conflict with the privacy requirements under the Gramm-Leach-Bliley Act and/or Regulation S-P (“GLB Rights”), GLB Rights shall apply.

Categories of Personal Information We Collect: We have collected some or all of the following categories of personal information from individuals within the last twelve (12) months:

We do not collect or use sensitive personal information other than: 

• To perform services as would reasonably be expected by an average consumer who requests those services;
• As reasonably necessary and proportionate to detect security incidents that compromise the availability, authenticity, integrity, and confidentiality of stored or transmitted personal information;
• As reasonably necessary and proportionate to resist malicious, deceptive, fraudulent, or illegal actions directed at us and to prosecute those responsible for such actions;
• For short-term, transient use (but not in a manner that discloses such information to another third party or is used to build a profile of you or otherwise alter your experience outside of your current interaction with us);
• To perform services on behalf of our business;
• To verify or maintain the quality or safety of a service or to improve, upgrade, or enhance such service; and
• To collect or process sensitive personal information where such collection or processing is not for the purpose of inferring characteristics about a consumer. 

Purposes for Collecting Personal Information: We may collect or disclose the personal information we collect about you for one or more of the following business or commercial purposes:

• performing services to you, including: 
• the administrative processes (and related communication) in preparing for the admission of investors to the fund(s) and/or onboarding separately managed account client(s) including administering, managing and setting up an investor’s account(s) to allow such potential investor to purchase interests in the fund(s);
• ongoing communication with potential investors, their representatives, advisors and agents (including the negotiation, preparation and signature of documentation) during the process of admitting potential investors to the fund(s) and/or onboarding separately managed account client(s) and the execution of all relevant agreements; 
• the performance of obligations under the governing documents of the Clients (and all applicable anti-money laundering, Know Your Customer and other related laws and regulations) in assessing suitability of potential investors in the applicable Client(s); 
• ongoing operations, administrative, accounting, reporting, account maintenance and other processes and communication required to operate the business of the Clients in accordance with their governing documents and other documentation between the parties, including customer service, processing or fulfilling transactions, verifying personal information, preparing tax information, processing contributions and distributions and financing;
• keeping investors informed about the business of Skylands or the general partner of the applicable fund, including offering opportunities to make investments to other Skylands funds and related advertising;
• facilitating the execution, continuation or termination of the contractual relationship between an investor and the general partner, the investment adviser and/or the fund(s);
• facilitating the transfer of fund interests, and administering and facilitating any other transaction, between an investor, the general partner, the investment adviser and/or the fund(s);
• auditing and verifications related to investor interactions, including verifying the quality and effectiveness of services and compliance; 
• maintaining the safety, security and integrity of our products and services, databases, technology assets and business, including detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity; 
• enabling any actual or proposed assignee or transferee of the fund(s), to evaluate proposed transactions;
• facilitating business asset transactions involving the funds; and
• complying with U.S., state, local and non-U.S. laws, rules and regulations.
  We collect personal information from the sources set forth in the Privacy Notice above. We retain the categories of personal information set forth above in the “Categories of Personal Information We Collect” section of this Privacy Notice Supplement only as long as is reasonably necessary for those purposes set forth above, except as may be required under applicable law, court order or government regulations.
  Disclosure of Information: We do not share for the purpose of cross-context behavioral advertising or sell (as such terms are defined in the CCPA) any of the personal information we collect about you to third parties. 
  Within the last twelve (12) months, we have disclosed personal information collected from you for a business purpose to the categories of third parties indicated in the chart below. We may also disclose your information to other parties as may be required by law or regulation, or in response to regulatory inquiries.

Rights under the CCPA

Deletion Rights: You have the right to request that we delete any of your personal information that we retain, subject to certain exceptions, including our compliance with U.S., state, local and non-U.S. laws, rules and regulations. We will notify you in writing if we cannot comply with a specific request and provide an explanation of the reasons.

Disclosure and Access Rights: You have the right to request that we disclose to you certain information regarding our collection, use, and disclosure of personal information specific to you. Such information includes:

• The categories of personal information we collected about you;
• The categories of sources from which the personal information is collected;
• Our business or commercial purpose for collecting such personal information;
• Categories of third parties with whom we disclose the personal information;
• The specific pieces of personal information we have collected about you; and
• Whether we disclosed your personal information to a non-affiliated third-party, and if so, the categories of personal information that each recipient obtained.

Correction Right: You have the right to request that we correct any inaccuracies in the personal information that we retain, subject to certain statutory exceptions, including, but not limited to, our compliance with U.S., state, local and non-U.S. laws, rules and regulations. We will notify you in writing if we cannot comply with a specific request and provide an explanation of the reasons.

No Discrimination: We will not discriminate against you for exercising your rights under the CCPA, including by denying service, suggesting that you will receive, or charging, different rates for services or suggesting that you will receive, or providing, a different level or quality of service to you.

How to Exercise Your Rights: To exercise any of your rights under the CCPA, or to access this notice in an alternative format, please submit a request on your behalf using any of the methods set forth below.

Please e-mail us at the following e-mail address: vr@skylandscapital.com

If you would like to contact us by telephone without incurring telephone charges, please submit your request and telephone number by email at the email address above and we will call you between 9 a.m. and 6 p.m. Pacific Time.

We will contact you within 10 business days to confirm receipt of your request under the CCPA and request any additional information necessary to verify your request. We verify requests by matching information provided in connection with your request to information contained in our records. Depending on the sensitivity of the request and the varying levels of risk in responding to such requests (for example, the risk of responding to fraudulent or malicious requests), we may request further information or use existing investor contact information that we have on file in order to verify your request. You may designate an authorized agent to make a request under the CCPA on your behalf, provided that you provide a signed agreement verifying such authorized agent’s authority to make requests on your behalf, and we may verify such authorized person’s identity using the procedures above. If we request you verify your request and we do not receive your response, we will pause processing your request until such verification is received.

For questions about this supplement, please contact Virginia Shaffar, Chief Compliance Officer at (414) 256-3380.