Gladstone

US Privacy Policy

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Privacy Policy Notice

Financial companies choose how they share your personal information. Federal law gives our clients the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this “Privacy Policy Notice” carefully to understand what we do.

Gladstone Capital Management LLP (“Gladstone” or the “Firm“) does not disclose nonpublic personal information about its prospective, existing or former clients to third parties other than as described below.

This notice complies with the privacy provisions of Regulation S-P under the Gramm-Leach-Bliley Act and certain privacy provisions of other laws.

Personal information we collect. Gladstone collects personal information about you in connection with providing advisory services to you. This may be collected when you contact us directly, when using our website (via your IP, device ID, browser, usage data and browsing behavior using cookies and tracking technologies), or from third parties (financial institutions and identity verification providers, public data bases and service providers). This information includes your name, social security number and ID verification, and may include other information such as, but not limited to, your:

How Gladstone collects this information. Gladstone collects this information from you through various means. For example, when you give the Firm your contact information, enter an investment advisory contract with the Firm, buy securities (i.e., interests in a fund) from the Firm, tell the Firm where to send money, or make a wire transfer. Gladstone also may collect your personal information from other sources. The Firm maintains physical, electronic, and procedural safeguards that comply with federal standards to safeguard your nonpublic personal information which the Firm believes are adequate to prevent unauthorized disclosure of such information.

How Gladstone uses this information. All financial companies need to share customers’ personal information to run their everyday business, and the Firm uses the personal information collected from you for everyday business purposes. These purposes may include, for example:

Disclosure to others. Gladstone may provide your personal information to firms that assist the Firm in servicing your account and have a need for such information, such as a broker or fund administrator. Gladstone may also disclose such information to service providers and financial institutions with whom Gladstone has joint marketing arrangements (i.e., a formal agreement between financial companies that together market financial products or services to you, such as placement agents). Gladstone requires third-party service providers and financial institutions with which the Firm has joint marketing arrangements to protect the confidentiality of your information and to use the information only for the purposes for which the Firm discloses the information to them.

These sharing practices are consistent with Federal privacy and related laws, and in general, you may not limit our use of your personal information for these purposes under such laws. Gladstone notes that the Federal privacy laws only give you the right to limit the certain types of information sharing that the Firm does not engage in (e.g., sharing any personal information with others for them to market to you).

How Gladstone protects your personal information. To protect your personal information from unauthorized access and use, Gladstone maintains physical, electronic, and procedural safeguards that comply with Federal law to safeguard nonpublic personal information which the Firm believes are adequate to prevent unauthorized disclosure of such information. These measures include computer safeguards and secure files and buildings. We retain personal information for as long as necessary to meet our legal and regulatory obligations; retention periods may vary depending on the specific circumstances.

Clients have the right to opt out of the registrant sharing their nonpublic personal information with nonaffiliated third parties under the GLBA.

Who to contact with questions or to Opt Out. This Privacy Policy Notice relates to the following entities:

Who to contact with questions. If you have any questions about this Privacy Notice, please contact Justine Ayling-Kenrick by email at jak@gladstone-management.com.

State Privacy Rights (Including California). If you are a resident of certain states (e.g., California, Colorado, Virginia, Connecticut, Utah, Texas, etc.), you may have additional rights, including:

To exercise your rights, contact us via the details outlined above.

We may update this Privacy Policy periodically. If we make material changes, we will notify you by updating the “Last Updated” date and, where required by law, provide additional notice.