Important Notice and Disclaimer
The content of this Website is provided for general information only to the public and shall not be construed as legal, financial, securities or immigration advice on any subject matter. General information, as shown, may not reflect current Federal or State Regulations, FINRA publications and guidelines and ongoing legal happenings and events.
Nothing contained in this website should be considered an offer to sell securities. The information contained herein is for informational purposes only. Only a formal, privately distributed offering memorandum and appropriate securities documents, fully executed by an accredited investor, will represent a sale of investment.
Recipients of content from this site, clients, customers or otherwise, should not take action, directly or indirectly on the basis of any content included in the site without seeking the appropriate legal or other professional advice on the particular facts and circumstances at issue from legal counsel or other such professional advisors properly licensed and familiar with those matters.
Winlo Management Group, LLC (the “Firm”) expressly disclaims all liability in respect to actions taken or not taken based on any or all the contents of this Website.
Any information sent to The Firm via e-mail, through the Website or by other means is not secure and is done so on a non-confidential basis. Transmission of information from this Website does not create a client relationship between you and The Firm, nor is it intended to do so. The transmission of the Website, in part or in whole, and/or any communication with us through this site does not constitute or create any relationship between the Firm and any recipients.
This Website and its contents are provided without warranty of any kind howsoever, whatsoever, either expressed or implied, The Firm does not seek to represent anyone based upon viewing this Website in a state where this Website fails to comply in any manner with all laws, guidelines, and conduct rules of that state.
Information Winlo Receives About You
- Information disclosed on your investor qualification questionnaires and subscription agreements
- Other information provided to us by you, including information we may request as part of our Anti-Money Laundering Policy and Customer Identification Program
- Information furnished by third parties, including publicly available information that is lawfully available to members of the general public from one of three sources: official public records (such as real estate records or security interest filings), widely-distributed media (including information obtained over the Internet from public sites on an unrestricted basis), and information required to be made public by federal, state, or local law
Information We May Disclose to Third Parties:
We do not disclose to any third party any nonpublic personal financial information about our customers or former customers without their consent, except: (i) as required by law; or (ii) as described in the following paragraph.
Third Parties to Whom We Disclose Information
Winlo Management Group may only disclose nonpublic financial information to law enforcement agencies or other entities to which we are required by law to disclose such information. Further, when establishing a relationship with new consumers, Winlo may disclose certain nonpublic personal information to third-party information providers contracted by our firm to assist in verifying your identity as part of our Anti-Money Laundering Policy and Customer Identification Program.
Security of Information
Winlo Management Group restricts access to nonpublic personal information about you to our officers only. We maintain physical, electronic, and procedural safeguards that comply with federal regulations to guard your nonpublic personal financial information.
Anti-Money Laundering - USA Patriot Act Requirements
The USA PATRIOT Act requires all financial institutions to obtain, verify, and record information that identifies each person and entity that opens an account. Therefore, for investors that open accounts with fund managers that we represent (i.e., subscribe to funds placed by our firm), certain information must be received prior to accepting an investment in a fund; and either before or after such investment, we must verify this identification information. We will request to view one or more of the following documents in order to verify identification: for an individual, an unexpired government-issued identification evidencing nationality, residence, and bearing a photograph or similar safeguard, such as a driver’s license or passport; and for an entity, documents showing the existence of the entity, such as certified articles of incorporation, a government-issued business license, a partnership agreement, or a trust agreement. Alternatively, we will reference a database or public information source to verify the investor’s identity. Each purchaser will be required to complete an investor qualification questionnaire prior to acceptance of the subscription agreement by the fund manager. The questionnaire will require the investor to disclose information regarding the entity or person that is making the investment in the fund, including a representation that the investor qualifies as either a qualified purchaser or an accredited investor.
Business Continuity Plan Disclosure Statement
Winlo Management Group (the Company) plans to quickly recover and resume business operations after a significant business disruption (SBD) and respond by safeguarding our employees and property, making a financial and operational assessment, protecting the firm’s books and records, and allowing our customers to transact business. In short, our company’s business continuity plan (BCP) is designed to permit us to resume operations as quickly as possible, given the scope and severity of the SBD. The BCP addresses: data backup and recovery; all mission critical systems; financial and operational assessments; alternative communications with customers, employees, and regulators; alternate physical location of employees; critical supplier, contractor, bank and counter-party impact; and regulatory reporting. The fund manager (issuer of the limited partnership interests) maintains all records related to your investments and account holdings and backs up important records in accordance with their business continuity plans. For more information on their contingency plans, please contact the fund manager directly at the telephone number provided on your offering documents or through their website. Significant Business Disruptions: The Company’s plan takes into account two kinds of significant business disruptions, internal and external. Internal SBDs affect only the Company’s ability to communicate and do business, such as a fire or loss electrical power in the office or building. External SBDs prevent the operation of the securities markets or a number of firms, such as a terrorist attack, a natural disaster, or another event that causes a wide-scale, regional disruption in essential services. Internal SBDs: In the event of a disruption in the Company’s business operations due an internal SBD, the Company will attempt to continue to conduct business as usual by utilizing alternative communication methods (if available), such as the Internet, cell phones, etc., or by moving its operations to an alternative location. If personnel or operations must be moved to an alternate location, the Company anticipates that it will resume regular operations promptly. External SBDs: In the event of a disruption in the Company’s business operations due to an external SBD, the Company will attempt to continue to conduct business as usual by moving its operations to an alternative location outside the affected area, if possible, or by providing customers with alternative communication arrangements, as indicated below, to conduct business. The Company will attempt to resume business within 24-48 hours and to keep its customers informed regarding relevant events to the best of its ability based on the circumstances. In all cases, the Company will resume normal business operations as soon as it is able to do so, based on the type and the extent of the disrupting event.
In the event you are unable to reach the Company at our main number, 800.688.3824, please proceed as follows:
- Contact the Company at the following alternate telephone number: 704.756.3072
- Access the Company’s website at winlogroup.com.
- Contact the fund manager directly at the number listed on the applicable offering documents or your most recent statement.
- Contact FINRA’s District office at the following telephone number for more information on the company’s status and additional instructions: 561.443.8000.
- Contact information: Any questions regarding the Company’s Business Continuity Plan should be addressed to: Winlo Management Group, Attn: Chief Compliance Officer, 151 Calle San Francisco, Suite 200, San Juan Puerto Rico 00901.
In the event the filing of a customer complaint is necessary, please contact: Winlo Management Group, Attn: Chief Compliance Officer, 151 Calle San Francisco, Suite 200, San Juan Puerto Rico 00901.