Scout Energy Management LLC and its affiliates respect your right to privacy. We have always been
committed to secure the confidentiality and integrity of your personal information. We are proud of
our privacy practices and want our current and prospective customers to understand what information
we collect and how we use it.
Why We Collect Your Information
We gather 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 and improve the products and services we
offer and (iii) comply with the laws and regulations that govern us.
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.
What Sources We Obtain Your Information
We collect nonpublic personal information about Scout Energy Management LLC clients such as you
from the following sources:
• Information we receive from you on applications or other forms;
• Information about your transactions with us, our affiliates, or others, and
• If you visit our web site, information we collect via a web server, often referred to as a
“cookie.” Cookies indicate where a site visitor has been online and what has been viewed.
No mobile information gathered through the “Contact Us” page on our website will be shared with third parties/affiliates for marketing/promotional purposes
What Information We Disclose
We do not disclose any nonpublic personal information about our customers or former customers to
anyone, except as permitted by law. Moreover, we will not release information about our customers or
former customers unless one of the following conditions is met:• We receive your prior written consent.
• We believe the recipient to be you or your authorized representative.
• We are required by law to release information to the recipient.
We only use information about you and your account to help us better serve your investment needs or to
suggest services or educational materials that may be of interest to you.
Confidentiality And Security
We maintain physical, electronic and procedural safeguards to guard your personal account information.
To further protect your privacy, our website uses the highest levels of Internet security, including data
encryption, user names and passwords, and other tools. We also restrict access to your personal and
financial data to authorized Scout Energy Management LLC associates who have a need for these
records. We require all nonaffiliated organizations to conform to our privacy standards and are
contractually obligated to keep the information provided confidential and used as requested.
Furthermore, we will continue to adhere to the privacy policies and practices described in this notice
even after your account is closed or becomes inactive.
We will continue to conduct our business in a manner that conforms with our pledge to you, your expectations and all applicable laws.
The California Consumer Privacy Act
California enacted the California Consumer Privacy Act, California Civil Code § 1798.100 et seq., (with
any implementing regulations and as may be amended from time to time, “CCPA”), in 2018 and it is
effective as of January 1, 2020. The CCPA imposes certain obligations on Scout Energy Management
LLC, and its affiliates (together, “we” or “us”) and grants certain rights to California residents (“California
Resident,” “you” or “your”) with regard to “personal information.” If you are a California Resident, please
review the following information about your potential rights with regard to your personal information under the CCPA. The rights described herein are subject to exemptions under the CCPA and other limitations under applicable law.
Terms used herein have the meaning ascribed to them in the CCPA. Scout Energy Management LLC and
its affiliates are a “business.” “Personal information” under the CCPA means information that identifies,
relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly
or indirectly, with a consumer or a household. It does not include deidentified information, aggregate
consumer information or publicly available information, as those terms are defined in the CCPA.
The CCPA does not restrict our ability to do certain things like comply with other laws or comply with
regulatory investigations. In addition, the CCPA does not apply to certain information like personal
information collected, processed, sold or disclosed pursuant to the federal Gramm-Leach-Bliley Act and its
implementing regulations.
Business or Commercial Purpose for Collecting Personal Information
We may have collected your personal information for the following business or commercial purposes.
• Performing services on behalf of the fund, including, for example, maintaining or servicing
accounts, providing investor relation services, processing subscriptions and withdrawals, verifying
information, processing payments, or providing similar services on behalf of the fund.
• Performing our contractual obligations to a California Resident as a subscriber to the fund,
including, processing initial subscriptions and providing updates on the fund’s performance,
providing tax reporting and other operational matters.
• Detecting security incidents and protecting against malicious, deceptive, fraudulent, or illegal
activity, including, preventing fraud and conducting “Know Your Client,” anti-money laundering,
terrorist financing, and conflict checks.
• Enabling or effecting commercial transactions, including, using your bank account details to remit
funds and process distributions.
Categories of Personal Information We Collect and Categories of Personal Information We Have Disclosed
for a Business Purpose
In the preceding 12 months, we may have collected the following categories of personal information from
or about a California Resident.
• Identifiers such as, your name, address, date of birth, email address, social security number, driver’s
license number, passport number, or other similar identifiers.
• Personal information subject to Cal. Civ. Code Section 1798.80(e), including, your education,
credit card number, state identification card number, signature or bank account or other financial
information.
• Characteristics of protected classifications under federal or certain state law, including, your
gender, national origin, or marital status.
• Commercial information, including records of products or services purchased, obtained, or
considered, or other purchasing histories or tendencies. For example, funds invested, investments
considered, or sources of wealth.
• Internet or other electronic network activity information, including, for example, information
regarding your interaction with our website or use of certain online tools.
• Professional or employment-related information, including occupation, compensation, employer,
and title.
• Inferences drawn from any of the information identified above to create a profile reflecting your
preferences or similar information, including your potential interest in investing in new funds.
In the preceding 12 months, we may have disclosed for a business purpose all of the above categories
of personal information to all of the categories of third parties discussed below in “Sharing Personal
Information with Third Parties.”
Sources of Personal Information
We may collect personal information about you directly from you and/or your intermediaries through
sources such as:
• Account applications, subscription agreements and other forms or related documents
• Written, electronic, or verbal correspondence with us or our service providers
• Investor transactions
• An investor’s brokerage or financial advisory firm, financial advisor, or consultant; and/or
• From information captured on applicable websites
In addition, we may collect personal information from different sources, such as: (i) our affiliates, our
service providers, or our affiliates’ service providers; (ii) public websites or other publicly accessible
directories and sources, including bankruptcy; and/or (iii) credit reporting agencies, sanctions screening
databases, or from sources designed to detect and prevent fraud.
Sharing Personal Information with Third Parties
We do not sell your personal information. We may disclose personal information to third parties in
circumstances where we believe in good faith that disclosure is required or permitted under law, to
cooperate with regulators or law enforcement authorities, or to protect our rights or property. We also may
disclose personal information about you or your accounts to a third party at your request or direction or
with your consent.
For these reasons, we may disclose any of the categories of personal information discussed above in
“Personal Information We Collect” to any of the following categories of third parties:
• investors and investors’ intermediaries in connection with investments and transactions;
• third parties who deliver our communications, including postal services;
• third parties who assist with our information technology and security programs;
• third parties who assist with fraud prevention, detection and mitigation;
• third parties as needed to complete a transaction, including financial institutions;
• third parties in connection with legal or regulatory matters, including government or regulatory
agencies, courts, opposing counsel and parties to litigation;
• third parties in connection with the sale or transfer of all or any relevant portion of our business
or assets;
• our lawyers, accountants, auditors, and consultants; and
• other third parties as permitted or required by law.
We may disclose all or just a few of the categories of personal information identified in the paragraph
labelled “Categories of Personal Information We Have Disclosed for a Business Purpose” to our service
providers or other entities with which we have contracted to provide support and services and that have
agreed to limitations on the use of your personal information for a business purpose or that fit within other
exemptions or exceptions in the CCPA.
California Residents’ Rights Under the CCPA
If your personal information is subject to the CCPA, you may have certain rights concerning your personal
information, subject to applicable exemptions and limitations, including the right to: (i) be informed, at or
before the point of collection, of the categories of personal information to be collected and the purposes for
which the categories of personal information shall be used; (ii) not be discriminated against because you
exercise any of your rights under the CCPA; (iii) request that we delete any personal information about you
that we collected or maintained, subject to certain exceptions (“request to delete”); (iv) opt-out of the
“sale” (as the term is defined in the CCPA) of your personal information if a business sells your personal
information (we do not); and (v) request that we, as a business that collects personal information about you
and that discloses your personal information for a business purpose, disclose to you (“request to know”):
(a) the categories of personal information we have collected about you; (b) the categories of sources from
which we have collected the personal information; (c) the business or commercial purpose for collecting or
selling the personal information; (d) the categories of third parties with which we disclosed personal
information about you for a business purpose; (e) the specific pieces of personal information we have
collected about you; and (f) the categories of personal information we have disclosed about you for a
business purpose.
The CCPA does not restrict our ability to do certain things like comply with other laws or comply with
regulatory investigations. In addition, the CCPA does not apply to certain information like personal
information collected, processed, sold or disclosed pursuant to the federal Gramm-Leach-Bliley Act and its
implementing regulations. We also reserve the right to retain, and not to delete, certain personal information after receipt of a request to delete from you where permitted by the CCPA or another law or regulation.
How to Submit a Request Under the CCPA
You may submit requests to know through the following telephone number (972) 325-1651. You may
submit requests to delete through the following telephone number (972) 325-1651, or by emailing us at
legal@scoutep.com. We are required to provide certain information or to delete personal information only in response to verifiable requests made by you or your legally authorized agent. Any information gathered as part of the verification process will be used for verification purposes only.
We are required to provide certain information or to delete personal information only in response to
verifiable requests made by you or your authorized agent. Any information gathered as part of the
verification process will be used for verification purposes only.
In order to verify requests to know and requests to delete, we may require you to provide clarifying or
identifying information. Such information may include, at a minimum, depending on the information you
are requesting and the type of request you are making, account login credentials or other account
information, answers to security questions, name, government identification number, date of birth, contact
information, or other personal information.
If an authorized agent seeks to submit a request on behalf of a California Resident, the authorized agent
may do so by the aforementioned methods, however, they must provide: (i) signed authorization from the
California Resident authorizing them to act on the California Resident’s behalf, unless they can provide
proof that the California Resident has granted them power of attorney pursuant to California Probate Code
sections 4000 to 4465; and (ii) proof of their registration with the California Secretary of State to conduct
business in California. We also require that the California Resident directly verify their own identity with
us and directly confirm with us that they provided the authorized agent permission to submit the request.
Contact for More Information
If you have any questions or concerns about this California privacy notice please email us
at legal@scoutep.com.
Should you have any questions regarding our policies or about this notice, please contact us at
legal@scoutep.com.