Financial companies choose how they share your personal information. Federal law gives consumers 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 notice carefully to understand what we do.

At Cynosure, we recognize the importance of keeping information about you secure and confidential. Cynosure does not sell or share your nonpublic personal and financial information with marketers or others outside our affiliated group of companies.

Cynosure carefully manages information among its affiliated group of companies to safeguard your privacy and to provide you with consistently excellent service.

Cynosure is providing this notice to you to comply with the requirements of Regulation S-P issued by the U.S. Securities and Exchange Commission.

Our Privacy Policy

Cynosure is committed to protecting the nonpublic personal and financial information of each advisory client, and each investor in the private investment funds and separately managed accounts for which we serve as investment adviser. Cynosure fulfills its commitment by establishing and implementing policies and systems to protect the security and confidentiality of this information.

In our offices, we limit access to nonpublic personal and financial information about you to those personnel who need to know the information in order to provide products or services to you. Cynosure maintains physical, electronic and procedural safeguards to protect your nonpublic personal and financial information.

Categories of Information Cynosure Collects

Cynosure may collect the following types of nonpublic personal and financial information about you from the following sources:

  • Your name, address and identifying numbers, and other personal and financial information, from you and from identification cards and papers you submit to Cynosure, on applications, subscription agreements or other forms or communications.
  • Information about your account balances and financial transactions with Cynosure, its affiliated entities, or nonaffiliated third parties, from Cynosure’s internal sources, from affiliated entities and from nonaffiliated third parties.
  • Investment experience, wire transfer instructions and account transactions; and assets and income level.

When you are no longer our customer, we will continue to safeguard your non-public information and will not share it unless required by law or as necessary for accounting, tax, audit and related purposes.

Categories of Information Cynosure Discloses to Non-Affiliated Third Parties

Cynosure may disclose your name, address and account and other identifying numbers, as well as information about your pending or past transactions and other personal financial information, to nonaffiliated third parties as necessary to administer and service the private funds or managed account in which you are invested or to market our products and services through joint marketing arrangements.

Cynosure may disclose nonpublic personal and financial information concerning you to law enforcement agencies, federal regulatory agencies, self-regulatory organizations or other nonaffiliated third parties, if required or requested to do so by a court order, judicial subpoena or regulatory inquiry.

Cynosure does not otherwise disclose your nonpublic personal and financial information to nonaffiliated third parties, except where Cynosure believes in good faith that disclosure is required or permitted by law. Because Cynosure does not disclose your nonpublic personal and financial information to nonaffiliated third parties, Cynosure’s Privacy Notice does not contain opt-out provisions.

Categories of Information Cynosure Discloses to its Affiliated Entities

Cynosure may disclose your name, address and account and other identifying numbers, account balances, information about your pending or past transactions and other personal financial information to its affiliated entities for any purpose.

Cynosure regularly discloses your name, address and account and other identifying numbers, account balances and information about your pending or past transactions to its affiliates to administer and service the private fund or managed account in which you are invested or to market our products and services to you.

Information about Former Customers

Cynosure does not disclose nonpublic personal and financial information about former customers to nonaffiliated third parties unless required or requested to do so by a court order, judicial subpoena or regulatory inquiry, or otherwise where Cynosure believes in good faith that disclosure is required or permitted by law.