PRIVACY NOTICE
OF
NORTH MOUNTAIN CAPITAL, LLC
Dated: February 03, 2025
Introduction
This Privacy Notice describes the policies of North Mountain Capital, LLC (“North Mountain Capital”) regarding the collection, use, and protection of nonpublic personal information of investors in the funds it manages (each, a “Fund”; collectively, the “Funds”), as well as prospective and former investors (collectively, “Investors”). These policies apply to all Investors to the extent applicable and may be updated from time to time at North Mountain Capital’s sole discretion.
By investing in a Fund managed by North Mountain Capital, Investors acknowledge and agree to the terms set forth in this Privacy Notice.
Information We Collect
North Mountain Capital collects and maintains nonpublic personal information about Investors, including, but not limited to:
- Information provided in subscription agreements, investor questionnaires, and other forms, such as names, addresses, phone numbers, Social Security numbers, and employment, asset, income, and financial details;
- Information related to an Investor’s account, including capital contributions, withdrawals, redemptions, profit and loss allocations, and distributions;
- Information about an Investor’s transactions with one or more of the Funds, including securities transactions and investment holdings;
- Information received from an Investor’s financial advisor, consultant, attorney, accountant, or other authorized representative;
- Information collected through our website, including via “cookies,” which help facilitate website functionality, track usage analytics, and diagnose technical issues.
Information Sharing and Disclosure
North Mountain Capital does not disclose nonpublic personal information about Investors to third parties except as required or permitted by law. We may share such information with affiliates and service providers that assist in managing the Funds, including:
- Financial service providers such as banks, prime brokers, administrators, and custodians;
- Professional advisors including legal counsel, accountants, auditors, and compliance consultants;
- Fiduciaries or authorized representatives acting on behalf of an Investor (e.g., IRA custodians, trustees);
- Regulatory and governmental agencies in response to legal obligations, subpoenas, court orders, or regulatory inquiries; and
- Other parties authorized by the Investor.
When sharing information, we require third parties to use it solely for the intended purpose and to maintain strict confidentiality.
No Sale of Personal Information
North Mountain Capital has not sold and does not sell nonpublic personal information of Investors.
Data Security and Confidentiality
North Mountain Capital takes the privacy and confidentiality of Investor information seriously. We maintain industry-standard physical, electronic, and procedural safeguards to protect nonpublic personal information from unauthorized access, disclosure, or misuse.
Third parties with whom we share Investor data are required to adhere to appropriate security and confidentiality standards.
Legal Disclaimer
Nothing in this Privacy Notice shall be interpreted as creating a contractual obligation between North Mountain Capital and any Investor beyond what is required by applicable law. North Mountain Capital reserves the right to amend this Privacy Notice at any time without prior notice, except where legally required.
Policy Updates and Investor Rights
We provide prospective Investors with this Privacy Notice as part of their subscription materials. Existing Investors will receive an updated notice when material changes are made. If changes allow for additional information sharing beyond what is stated here, Investors will be notified in advance and, if required by law, given an opportunity to opt out.
The examples in this Privacy Notice are for illustrative purposes only and are not exhaustive.