Privacy Policy

Last Updated and Effective January 2024

This Privacy Policy sets forth the privacy practices of Birnam Oak Advisors, LP (“Birnam Oak,” “we,” “our,” or “us”) with respect to our collection, use, sharing, and disclosure of Personal Information, including, but not limited to, Personal Information collected through this website (the “Site”), how it is used, and the circumstances under which it may be shared and disclosed. This Privacy Policy constitutes a legally binding agreement between you and Birnam Oak that conditions your use of the Site, where and as permitted by applicable law.

If you are a California resident, please read our Privacy Notice for California Consumers below.

Personal Information We Collect
When you visit the Site and during our ordinary business activities, Birnam Oak may collect or ask you to provide certain nonpublic personal information (“Personal Information”) in order to help us manage our relationship with you and serve your investment needs. The Personal Information we may collect from you may include personally identifiable information including names, residential or business addresses, or other contact details, signature, nationality, tax identification or passport number, date of birth, place of birth, photographs, copies of identification documents, bank account details, information about assets or net worth, credit history, information on investment activities, or other personal information. We do not generally seek to collect Personal Information relating to race or ethnicity, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, sexual life, criminal offences or any other information deemed to be sensitive under applicable privacy law (“sensitive personal data”). However, we may do so when there is an appropriate basis for this such as (as applicable and depending on the type of sensitive personal data) where such data have been made manifestly public, or the processing is necessary for reasons of substantial public interest.
Sources of Personal Information
We may collect Personal Information from:
- Your communications with us;
- Your transactions with us;
- Your use of our website and mobile app (including cookies and IP addresses)
- Services providers;
- Affiliates;
- Your agents and representatives;
- Fraud prevention and detection agencies;
- Nonprofit organizations; and
- Government entities and other governmental sources and records, credit agencies, and other publicly available information.
How We Use Personal Information
We use Personal Information for the following business purposes:
- To provide our products and services;
- To process your requests and inquires;
- To offer new products and services;
- To process transactions;
- For account maintenance;
- To confirm your identity;
- To communicate with you;
- To improve the Site;
- To protect the security and integrity of the Site;
- To prevent or investigate fraud or other unlawful activity, and detect security incidents; and
- To comply with and enforce applicable legal requirements.
How We Share Personal Information
Your privacy is important to us. Birnam Oak does not disclose any Personal Information to nonaffiliated third parties, except to service or manage a client’s account or as permitted or required by law. We do not sell any Personal Information.
How We Protect Personal Information
Birnam Oak seeks to carefully safeguard Personal Information. We will use commercially reasonable efforts to ensure that Personal Information is kept secure and safe from any loss or unauthorized disclosure or use. We restrict access to our client’s Personal Information to employees requiring that Personal Information to provide our products or services.
Use of Cookies
We may send text files (e.g., “cookies” or other cached files) or images to your web browser to collect and/or store information on your computer. Such text files and images are used to support the operation of our digital offerings and for the technical convenience to store information on your computer. We may use information stored in such text files and images to customize your experience on our Site and to monitor use of our Site. You may set your browser to notify you when you receive a cookie. Many web browsers also allow you to block cookies. If you block cookies you may not be able to access certain parts or use all features of our Site. You can disable cookies from your computer system by following the instructions on your browser.
Notice for Residents of the European Economic Area and United Kingdom
Birnam Oak does not currently offer its products or services to natural persons resident in the European Union or the United Kingdom (“EEA/UK”) and, accordingly, is not required to comply with the EU General Data Protection Regulation (“GDPR”). Any personal data provided to us by you will be processed in the United States or other jurisdictions outside the EEA/UK which may not afford the same protections of personal data as under the GDPR.
You Are Responsible for the Use and Security of Your Password
The password-protected areas of the Site are established for investors and their representatives only. If you wish to access the password-protected areas of our website, you will need to apply for a password. If you apply for a password to access password-restricted areas on the Site, you must provide us with your name, mailing address, email address, phone number, investor affiliation and other relevant information, in addition to the information you have provided to us as an investor (if applicable).

You are responsible for all actions taken with your username and password. Therefore, we recommend that you do not disclose your password to anyone. You may not allow others to use your username or password to access or use any part of our Site. If your password has been compromised for any reason, you should contact us immediately for a new password.

On your request, we will deactivate your password and remove your contact information and financial information from our active databases. Your password will be deactivated promptly based on your account activity and in accordance with our deactivation policy.
Contact Us
If you have any questions or comments about this Privacy Policy, please feel free to contact Birnam Oak at

investors@birnam-oak.com or 212-970-5800.

Privacy Notice For California Consumers

Last updated: January 4, 2024

This notice contains disclosures required by the California Privacy Rights Act (“CPRA”). Terms defined in the CPRA have the same meaning when used in this notice. This notice is only relevant to California residents (“consumers” or “you”). If you are a California consumer with a disability and cannot access this Privacy Policy for California Consumers in this format, please call 1-888-Pine-222 or email investors@birnam-oak.com and a paper or electronic version of this notice will be made available to you.

Information We Collect
In the past 12 months, we have collected and shared for a business purpose the following categories of personal information (“Personal Information”):
- Identifiers
  A real name, alias, email address, postal address, Internet Protocol (IP) address, account name, Social Security number, driver’s license number, passport number, or other similar personal identifiers.
- Other personal information categories, as listed in the California Customer Records Statute
  A signature, physical characteristics or description, telephone number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
- Protected classification characteristics under California or federal law
  Age (40 years or older), race, citizenship, marital status, sex, veteran or military status.
- Commercial information
  Account activity, records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
- Internet or other similar network activity
  Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
- Professional or employment-related information
  Current or past job history or performance evaluations.
- Inferences drawn from other personal information
  Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
- Sensitive personal information
  A consumer’s SS, driver’s license, state ID card, or passport number; account log-in or debit/credit card number in combination with any access code, password, or account credentials; contents of mail, email, and text messages.
  
  Personal Information does not include information that is publicly available, de-identified/ aggregated, or subject to HIPAA or GLBA.
We collect Personal Information from the following categories of sources:
- To provide our products and services;
- To process your requests and inquires;
- To offer new products and services;
- To process transactions;
- For account maintenance;
- To confirm your identity;
- To communicate with you;
- To improve the Site;
- To protect the security and integrity of the Site;
- To prevent or investigate fraud or other unlawful activity, and detect security incidents; and
- To comply with and enforce applicable legal requirements.
We do not knowingly collect, solicit or sell Personal Information from anyone under the age of 16 without the prior consent of a parent or guardian.
Purpose for Collection and Use of Personal Information
We may collect or use Personal Information for one or more of the following purposes:
- Providing you with information about our products and services;
- Providing you with performance and other updates;
- One or more of the following business purposes:
  - Performing services (for us or our service provider or contractor) such as account servicing, processing orders and payments, and analytics;
  - Auditing related to our interactions with you;
  - Legal compliance;
  - Detecting and protecting against security incidents, fraud, and illegal activity;
  - Debugging;
  - Internal research for technological improvement;
  - Internal operations;
  - Activities to maintain and improve our services; and
  - Short-term, transient use, such that the personal information is not disclosed to another third party and is not used to build a profile about you.
Sharing Personal Information
We may disclose Personal Information in one or more of the categories identified above to:
- Service providers, including but not limited to: administrators, lenders, banks, brokers, auditors, law firms, consultants, and placement agents;
- Affiliates;
- Business partners;
- Legal or government regulatory authorities as required by applicable law;
- In connection with a potential business transfer; and
- Third parties to whom you or your agents authorize us to disclose such information in connection with services we provide to you.
In the past 12 months, we have not sold Personal Information to third parties.
Length of Time
We will keep your Personal Information for as long as necessary to comply with our regulatory obligations.
Rights of California Consumers
The CPRA provides a California consumer the following rights, subject to certain exceptions and limitations:
- The right to request: (a) the categories and specific pieces of Personal Information we collect about you; (b) the categories of sources from which we collect your Personal Information; (c) our business or commercial purposes for collecting, selling or sharing your Personal Information; (d) the categories of Personal Information disclosed for a business purpose and the categories of persons to whom it was disclosed; (e) the categories of your Personal Information (if any) that we have either sold, shared, or disclosed.
- For certain categories of Personal Information, the right to request a list of what we disclosed to third parties for their own direct marketing purposes in the past 12 months and the names and addresses of those third parties.
- The right to request that we delete your Personal Information, subject to certain exceptions.
- The right to opt out of our sale(s) (if any) of your Personal Information.
- The right to request we correct any inaccurate Personal Information maintained about you.
- The right to limit our use of your sensitive personal information to only use that is necessary to perform the services expected or provide the goods reasonably expected.
- The right not to receive discriminatory treatment for exercising your CPRA rights.
You may submit requests relating to your exercise of CPRA rights to us via:

Phone: (212) 970-5802 or Email: compliance@birnam-oak.com

You may only make a verifiable request for access or data portability twice within a 12-month period. All verifiable requests must provide (1) enough information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative and (2) sufficient detail that allows us to properly evaluate and respond to it.

We endeavor to respond to a verifiable request within 45 days of its receipt. If we require more time, we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option.
Questions
If you have questions regarding this Notice, please contact us at compliance@birnam-oak.com.