Privacy and Information Security Policy

Protection of Nonpublic Personal Information

Background: OMX Ventures is subject to the rules promulgated under the Gramm-Leach Bliley Act (“GLB Act” or “GLBA”) that govern maintenance of investors’ personal information. The GLBA, also known as the Financial Modernization Act of 1999, is a federal law enacted in the United States to control the ways that financial institutions deal with the private information of individuals. The Firm, as an ERA, is subject to privacy regulations issued by the Federal Trade Commission (FTC). The FTC privacy rules require ERAs to “develop, implement and maintain a comprehensive information security program that is written in one or more readily accessible parts.” In particular, ERAs must identify reasonably foreseeable risks to the security, confidentiality, and integrity of customer information. They must design and implement information safeguards, test and monitor these safeguards, and make adjustments as needed.

Policy: OMX Ventures has adopted policies and procedures to protect “nonpublic personal information” about investors. OMX provides Investors with applicable privacy notices.

Safeguarding Non-Public Information 
Security of Client Information

OMX Ventures maintains safeguards that comply with federal standards to protect Client and Investor information. OMX Ventures restricts access to the account information of Funds and Investors to those Employees who need to know that information in the course of their job responsibilities, and requires that third parties with whom OMX Ventures shares Investor information agree to follow appropriate standards of security and confidentiality.

Disposal of Nonpublic Personal Information

OMX Ventures will shred, deliver to a document destruction firm, or otherwise render illegible hard copies of any customer or consumer nonpublic personal information in its possession when OMX Ventures deems possession of the information to no longer be necessary.

Nonpublic personal information stored on disk, CD, tape or other electronic media shall be cleared, purged, declassified, overwritten and/or encrypted in such a manner so that any information contained therein cannot be restored or decrypted. After the electronic media is cleared, purged, declassified, overwritten or encrypted, OMX Ventures shall ensure that the original information is not backed-up or saved on a hard drive, recycle bin, or other memories.

OMX Ventures shall require or takes reasonable steps to confirm that each third-party service provider engaged by the Firm that necessarily obtains access to customers’ nonpublic personal information during the course of their services on behalf of OMX Ventures has implemented and maintains appropriate safeguards relating to the secure disposal of nonpublic personal information.

Physical Facilities

OMX Ventures’ physical office space is secure and accessible only by authorized personnel who have keys and/or electronic access cards.

Training

To assist Employees in understanding their obligations with respect to non-public personal financial information, OMX Ventures will:

  • Inform Employees regarding OMX Ventures’ confidentiality and security standards for handling Client and Investor information by giving them a copy of this Manual.
  • Instruct Employees to take basic steps to maintain the security, confidentiality and integrity of Client and Investor information, including:
    • not leaving files, notes or correspondence in the open;
    • changing passwords periodically, and not posting passwords near computers;
    • conversing behind closed doors and not in the presence of any persons not authorized to hear or receive such information;
    • avoiding the use of speaker phones and discussions in hallways, elevators, and any public places; and
    • recognizing any fraudulent attempt to obtain Client and Investor information and reporting it to the Chief Compliance Officer.
    • access to Client and Investor information only to Employees who have a business reason for seeing it.
    • Keep access to computer files containing Client and Investor information restricted by password.
  • Inform Employees not to leave open files that hold Client and Investor information on the computer while they are not at their desk.
  • Keep back-up computer files locked at alternate sites allowing access only by authorized persons.
  • Oversee service providers by taking reasonable steps to select and retain service providers that are capable of maintaining appropriate safeguards and requiring service providers to agree contractually to implement and maintain such safeguards.
  • Evaluate and adjust this information security program in light of results of testing and monitoring, any material changes to OMX Ventures’ operations or business arrangements or any other circumstances that would impact OMX Ventures ‘ information security program.

Outside service providers, including OMX Ventures’ attorneys, consultants, auditors, brokerages and administrators, may be given access to non-public personal financial information concerning Investors in connection with the provision of services to OMX Ventures and its Clients. It is the OMX Ventures’ responsible belief that such service providers are capable of maintaining and have in place appropriate safeguards to protect Client and Investor information. How to Submit a Security Issue.

Contact help@invario.com to submit a security issue to OMX Ventures. Please include a description of the security issue. We may contact you with a request for more information.