Privacy Policy

Reviewed & Updated 4-14-2025
 
Introduction and Purpose
Provenio Capital (the “Firm”) provides current and prospective clients with the following information about their privacy policies for protecting the personal information of their current, former and prospective clients. 
 
Information We Collect
The Firm collects personal information (which includes public and non-public personal information), such as name, address, social security number, birth date, assets, income and investment experience, about current, former and prospective clients.  This information is compiled from:
(i)       Client Questionnaires;
(ii)      Investment Management Agreements completed by such persons;
(iii)     Transactions between such persons and the Firm (e.g., account activity and balances);
(iv)     Subscription Documents for clients investing in private funds managed by third party advisers; and 
(v)      Other third-party sources (e.g., credit reporting agencies). 
 
How We Use Your Information
The Firm will use, disclose and otherwise process personal information for business, administrative and marketing purposes. 
 
Information Sharing and Disclosure
Personal information is not shared with any unaffiliated third parties for their marketing purposes.  The Firm may reveal personal information in their possession about clients to their regulators and appropriate government agencies, as necessary and permissible under applicable laws, in connection with legal proceedings or otherwise to assert and protect their legal interests or as part of a corporate transaction with a successor or affiliate.  The Firm restricts access to such personal information to their personnel, their affiliates and affiliates’ personnel, their service providers and their outside counsel, auditors and other independent professionals who need to know that information. 
 
Safeguarding Your Information
The Firm maintains appropriate administrative, technical, and organizational controls to safeguard such personal information, although such safeguards may not prevent all breaches of information security.  If the security of personal information is compromised, the affected individuals will receive notice of the data security incident where required by and consistent with applicable law. 
 
Your Rights and Choices
Individuals may exercise their rights under applicable law to:
  • Access the personal information held by the Firm
  • Rectify or delete any personal information that is factually incorrect, incomplete, or irrelevant
  • Raise queries or concerns about the use of their personal information
  • Request not to receive marketing materials
 
Such requests may be made by contacting the Firm.
 
International Data Transfers
In order to use and disclose such personal information for the purposes described above, such personal information may be transferred internationally to countries which the European Union has deemed not to provide adequate data protection.  Current, former and prospective clients recognize the necessity of such international processing of personal information and consent to such international transfers of personal information, including social security and taxpayer identification numbers, as the Firm deems appropriate.  The Firm will ensure application of the same standards of privacy protection as set out in this privacy policy regardless of the country in which such personal information is processed. 
 
Policy Updates and Notifications
If, at any time in the future, it is necessary to disclose any investor’s personal information in a way that is materially inconsistent with this policy, the Firm will give such client written notice of the change and, where required under applicable law, obtain consent to such change.
 
Contact Information
To access, correct, or inquire about your personal information or this policy, please contact:
 
Provenio Capital
4400 MacArthur Blvd., Suite 300 | Newport Beach, CA 92660
investments@proveniocapital.com | Office: 949-301-9060