Privacy Policy

Protecting your privacy is important to us. We want you to understand what nonpublic personal information we collect and how we use it. “Nonpublic Personal Information” is nonpublic information about you that we obtain in connection with providing a financial product or service to you, such as that described in the examples below.

Why We Collect Your Information: We gather nonpublic personal information about you and your accounts so that we can (i) know who you are and thereby prevent unauthorized access to your information; (ii) design, deliver and improve the products and services we offer; and (iii) comply with the laws and regulations that govern us.

Confidentiality and Security: We limit access to your nonpublic personal information to those of our employees and service providers who are involved in offering or administering the products and services that we offer. We maintain physical, electronic, and procedural safeguards to protect your nonpublic personal information.

What Information We Collect: We may collect the following types of nonpublic personal information about you:

  • Information about your identity such as your name, address, and social security number;
  • Information about your transactions with us;
  • Information we receive from you on applications such as your beneficiaries or income; and
  • Information we receive from a consumer reporting agency after we obtain your consent to seek this information.

What Information We Disclose
: We are permitted by law to disclose nonpublic personal information about you to third parties in certain circumstances. For example, we may disclose nonpublic personal information about you to affiliated and nonaffiliated third parties to assist us in servicing your account with us (e.g., mailing of account related materials), to government entities (e.g., IRS for tax purposes) and in response to a subpoena or court order, judicial process or regulatory inquiry.

Rights To Opt Out: You have the right to direct us to not disclose non-public information about you to nonaffiliated third parties if its disclosure is beyond rendering services to you. Limiting our disclosure of such information may limit the services we are able to provide to you. We will not share non-public information unless compelled to do so by order of a court or in response to a subpoena.

To limit our sharing of your non-public information, please contact us at (610) 251-2820.

Modifications: We may amend this privacy notice at any time, and we will inform you of changes as required by law.

Notwithstanding the foregoing, please be aware that any and all non-public personal information received by the Millrace Funds, the General Partners of the Funds and/or Millrace Asset Group, Inc. (collectively, the “Millrace entities”) with respect to investors in the Funds who are natural persons, including the information provided to the Funds by an investor in subscription documents, will not be shared with any non-affiliated third parties that are not service providers to the  entities. Such service providers include, but are not limited to, the Millrace entities’ administrator, auditors, and legal advisors. Additionally, the Millrace entities may disclose such non-public personal information as required by law.

Former Investors and Clients: We will continue to adhere to the privacy policies and practices described in this notice even after your account is closed or becomes inactive. Should you have any questions regarding our Privacy Policy, please contact us at (610) 251-2820.