PRIVACY POLICY

Sova Management, LLC
PRIVACY POLICY

This policy applies to current and former clients of Sova Management, LLC (“Sova Group” or the “Firm”) and investors in Sova Group’s private funds.

The practices and policies contained in this disclosure are subject to change, but we will communicate any material changes to you when required by applicable laws.  The practices and policies contained in this disclosure supersede all previous notices or statements with respect to the same subject matter.

All financial institutions are required by law to disclose to clients their policies regarding the collection and disclosure of information considered to be “nonpublic personal information” under applicable federal law.

Because certain information about our clients and their account(s), and investors in our private funds, is necessary to administer and service our clients’ accounts, we obtain nonpublic personal information from information that is provided on subscription documents and related forms, and from transactions in client account(s). We do not collect nonpublic personal information about our clients or investors in our private funds from any other sources.

We may disclose some or all of the nonpublic personal information described above about current or former clients or investors to independent contractors and service providers but only for the purposes of servicing and administering client account(s).  Our agreements with these service providers contain confidentiality provisions and restrictions on using this information for any other purposes.  Unless we have obtained express consent, we do not disclose nonpublic personal information about our clients or investors in our private funds for the purpose of marketing or soliciting products or services.  We may also disclose certain information as required or permitted under applicable law, for example, to government agencies.

Access to nonpublic personal information about our clients or investors in our private funds or their account(s) is restricted to employees, independent contractors or service providers who need to have access to that information to service or administer client accounts or fund investments.  We maintain physical, electronic, and procedural safeguards that comply with federal standards to guard our clients’ and fund investors’ nonpublic personal information.