Privacy Policy

January 1, 2025

Community Investment Management LLC, its affiliate Community Investment Management Emerging Markets LLC, and the funds that they manage (collectively, “we”, “us” or “our”) limit the collection, use, storage and disclosure of personal information to what is necessary to provide you with the services you have requested or authorized. We do not collect, store, use or disclose personal information for any other purpose.

Information We Collect and Disclose. We only collect, use, store and disclose your personal information if we have a lawful basis to do so. We, including parties acting on our behalf or our affiliates behalf (such as our service providers), collect and disclose (for the purposes described below) several types of personal information, including:

  • Information you provide us or that your financial representative provides us on forms used in connection with your investments, in other electronic or written communications and during telephone or in person meetings (such information may include your name, residential and business addresses, citizenship, birthdate, email address, telephone numbers and other contact information, household income and net worth, investment qualification and background, social security number or taxpayer identification number, passport information, driver’s licenses, information on your tax forms, and other information necessary for us to market our services to you or comply with laws and regulations that apply to our investment operations);
  • Information about your investments with us, such as your initial investment, current account balances and any subscriptions or withdrawals;
  • Information about any bank account used to transfer funds between your investment with us and your bank, including information provided for wire transfers; and
  • Information we receive from third parties, including information from referral sources, and information that is generated by our service providers, such as administrators, accountants, bankers and custodians, to service our investors and accounts (such as account statements, tax information reports, transaction records and confirmations of contributions and withdrawals and similar information).

If you provide personal information about any person other than yourself, you must ensure they understand how their personal information will be used and that they have given their permission for you to disclose their personal information.

Use of Your Personal Information. We use your personal information for the following limited business purposes and as otherwise described in this Privacy Notice:

  • To evaluate and effect investment transactions and contracts, manage the investment services we provide you and help maintain the safety, security and integrity of our business and assets;
  • To comply with any applicable legal and regulatory obligations and the compliance obligations required by our service providers;
  • To communicate with you about your investments, our other services and products, and updates regarding our firm; and
  • On occasion, we may ask for your consent to use your personal information for purpose(s) we explain at that time.

Information We Disclose. It is our policy to not disclose your personal information, except we may disclose your personal information as permitted by law to the following types of parties:

  • Our affiliates, for our and our affiliates’ purposes consistent with this Privacy Notice;
  • Service providers that act on our behalf and help us with investment services (for example, administrators or companies that assist us with processing transactions, generating financial reports, data processing, tax filings, technology services and maintaining books and records), provided, that these third parties may use your personal information only as authorized by their contracts with us;
  • Our professional advisors, such as lawyers, bankers, accountants, brokers and insurers in the course of the professional services that they render to us;
  • Another company, in the case of a proposed or actual merger, or acquisition or sale of all or part of our business;
  • Any third party as required to comply with a law, regulation, or legal request (including for anti-money laundering purposes, know your customer requirements, tax reporting, as we believe necessary or appropriate to comply with lawful requests and legal process, such as a request from a government authority, and in response to requests from self-regulatory organizations and non-governmental regulators), for fraud prevention, or to protect the property or rights of us or others (however, nothing in this notice is intended to limit any legal defenses or objections that you may have to a third party or government request to disclose your information); and
  • Any third party to which you direct us to disclose your personal information or which you consent to the disclosure of your personal information.

We do not sell or disclose your personal information.

Information Security. We maintain physical, electronic and procedural safeguards to guard your personal information and the integrity and security of our databases. We have procedures in place for the disposal and protection against unauthorized access or use of your information. Except as described above, access to non-public personal information is restricted to our personnel who need to know such information. If we disclose your personal information, it is made available for limited purposes and under controlled circumstances.

Children. Our services are not directed to and we do not knowingly collect or solicit personal information from anyone under the age of 16 without parental or guardian consent.

Data Retention. We retain your personal information during the period you are an investor with us and for as long as is otherwise permitted by applicable law, necessary to resolve disputes, or necessary for legitimate business or legal purposes.

California Residents. If you are a resident of California, you may have certain rights with respect to your personal information that is protected by applicable California law (including the CCPA), including the following rights (subject to certain exceptions and limitations):

  • Right to Know. You have the right to request (a) the categories and specific pieces of personal information we collect and disclose; (b) the categories of sources from which we have collected your personal information; (c) the categories of third parties to whom your personal information was shared or disclosed for a business purpose; and (d) the business purposes for such collection and disclosure of your personal information.
  • Right to Request. You have the right to request a list of the personal information (if any) disclosed to third parties for direct marketing purposes in the prior 12 months.
  • Right to Delete. You have the right to access and then delete your personal information that we have collected from you or maintained about you (except to the extent we are required by law to retain any record).
  • Right to Correct Inaccurate Information. If we maintain inaccurate information about you, you have the right to request correction of that inaccurate personal information, taking into account the nature of the personal information and the purposes of the personal information processing. We will use commercially reasonable efforts to correct this information.
  • Right to Limit. We do not use or disclose sensitive personal information for purposes other than those permitted by CCPA regulations section 7027(m).
  • Right to Opt-Out. You have the right to opt-out of the sale or sharing of personal information for targeted advertising purposes. However, we do not sell or share your personal information.

California residents also have the right to not be discriminated against for exercising any of the rights described above. However, to the extent your personal information is required to meet any anti-money laundering or other legal requirements, failure to provide that information or a request that we delete such information may make you ineligible to do business with us or continue investing with us.

We may have disclosed for a business purpose the following categories of personal information to the following categories of third parties, as described in this chart:

Category of Personal Information Category of Third Party
Identifiers (for example these could include your name, address, DOB, SSN, driver’s license, passport number and online identifiers)
  • Counterparties and/or intermediaries in connection with investments and transactions or for operational purposes.
  • Entities who assist with fraud prevention, detection and mitigation and to assist with anti-money laundering or anti-terrorism checks.
  • Third parties as needed to complete a transaction, including financial institutions or lenders to or creditors of a fund.
Additional information subject to Cal. Civ. Code § 1798.80(e) (for example, these include a signature, state identification card number, financial information, or bank account information)
  • Counterparties and/or intermediaries in connection with investments and transactions or for operational purposes.
  • Entities who assist with fraud prevention, detection and mitigation and to assist with anti-money laundering or anti-terrorism checks.
  • Third parties as needed to complete a transaction, including financial institutions or lenders to or creditors of a fund.
Characteristics of protected classifications under certain federal or state laws (for example this could include gender, age or marital status)
  • Counterparties and/or intermediaries in connection with investments and transactions or for operational purposes.
  • Entities who assist with fraud prevention, detection and mitigation and to assist with anti-money laundering or anti-terrorism checks.
Commercial Information (for example records of products or services purchased, obtained or considered or purchasing histories or tendencies including funds in which you are invested, investments considered or sources of wealth)
  • Counterparties and/or intermediaries in connection with investments and transactions or for operational purposes.
  • Entities who assist with fraud prevention, detection and mitigation and to assist with anti-money laundering or anti-terrorism checks.
  • Third parties as needed to complete a transaction, including financial institutions or lenders to or creditors of a fund.

In addition, we may have disclosed for a business purpose personal information to the following categories of third parties: (i) judicial courts, regulators, or other government agents purporting to have jurisdiction over us, our subsidiaries or our affiliates, or opposing counsel and parties to litigation; and (ii) other third parties as may otherwise be permitted by law.

We may share your personal information with our service providers such as IT, certain professional service organizations (i.e. administrators and third-party law firms), or other entities that have agreed to limitations on the use of your personal information, or entities that fit within other exemptions or exceptions in or as otherwise permitted by the CCPA.

If you are a California resident and which to exercise these rights, please contact us at (415) 857-3233 or email at privacy@cim-llc.com. There are circumstances where we are not required to comply with consumer requests and we will let you know if one of those situations is applicable.

We will confirm receipt of your request within 10 business days. If you do not receive confirmation within the 10-day timeframe, please contact privacy@cim-llc.com.

To help protect your privacy and maintain security, we will verify your identity before granting access to your personal information or complying with your request. If you request to access or delete your personal information, we will verify your identity by comparing information we have on file against information you may provide us. If you designate an authorized agent to make a request to access or delete your personal information on your behalf, we may require you to (1) provide the authorized agent written permission to do so, and (2) verify your own identity directly with us (as described above).

We endeavor to substantively respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.

Please contact us if you are disabled and need a copy of this Privacy Notice prepared for you in a manner that is accessible. Any such request may be made via phone at (415) 857-3233 or via e-mail at privacy@cim-llc.com.

Changes to this Privacy Notice. We reserve the right to change our Privacy Notice in the future. If we make changes that materially affect how we collect, use, store and disclose your personal information, we will notify you.