Notice Pursuant to Connecticut Public Act 08-167

In accordance with Connecticut law, it is the policy of Columbus Circle Investors to:

  • safeguard the data, computer files and documents containing personal information provided to it by its employees, vendors, clients, and others from misuse by third parties, and destroy, erase or make unreadable such data, computer files and documents prior to disposal,
  • protect the confidentiality of Social Security numbers by maintaining a comprehensive information security program to ensure the safeguarding of personal information it regularly obtains from clients, employees, vendors, and others;
  • prohibit unlawful disclosure of Social Security numbers by not disclosing any personal information about its clients, employees, vendors, and others, to anyone, except as permitted by law; and
  • limit access to Social Security numbers of our clients, employees, vendors, and others to only those employees who have a valid legitimate reason to have such information.

As used in this notice, “personal information” means information capable of being associated with a particular individual through one or more identifiers, including, but not limited to, a Social Security number, a driver’s license number, a state identification card number, an account number, a credit or debit card number, a passport number, an alien registration number or a health insurance identification number, and does not include publicly available information that is lawfully made available to the general public from federal, state or local government records or widely distributed media.

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