Privacy Policy

This explains the manner in which we collect, utilize, and maintain nonpublic personal information
about each of our prospective, existing or former investors (collectively, ā€œInvestorsā€). Our policy
applies only to Investors who are individuals or to certain entities that are essentially ā€œalter egosā€ of
individuals (e.g., grantor trusts, IRAs, and similar individual selfdirected estate planning or
investment vehicles).


We respect our Investors right to privacy and we are committed to maintaining and safeguarding
nonpublic information. To manage our Investment Managerā€™s Clients in a professional and efficient
manner, certain affiliates must from time to time obtain and disclose certain nonpublic personal
information about an Investor. To protect the confidentiality of such information while making the
necessary disclosures, we have developed the security policies described below.


I. Information Collected


We collect nonpublic personal information about Investors from the following sources: (i)
information received from Investors through subscription agreements, investor questionnaires, (ii)
other documents, such as an Investorā€™s name, address, social security number, assets, income,
employment and amounts or types of such Investorā€™s investments; and (iii) information about
Investor(s) transactions with our Investment Managerā€™s Client(s) or an affiliate, their affiliates and
others, such as an Investorā€™s capital account balance, other account data and participation in other
investments.


II. Information Disclosed


We will only disclose nonpublic personal information to our affiliates and service providers as
permitted by applicable law. In general, our affiliates; including our Investment Manager may share
Investor nonpublic personal information with their affiliates (including those who are involved in the
operation, service, administration or management of, or the sale of interests in a pooled investment
vehicle advised by our Investment Manager) and to unaffiliated third party service providers, only as
permitted by law. For example, our affiliates such as our Investment Manager may share nonpublic
personal information it collects as described above in connection with the administration and
operations of its Client(s) (including disclosure to attorneys, accountants, administrators, service
providers or auditors).


III. Security Procedures


Any service provider receiving an Investorā€™s personal information will be authorized to use such
information only to perform the services required of them on behalf of an Investment Managerā€™s
Client and its affiliates and then only as permitted by applicable law. Our affiliates, including our
Investment Manager, restrict access to nonpublic personal information to those employees who
require access to provide services to our affiliates and Investors. Our Investment Manager maintains
physical, electronic and procedural safeguards to guard Investor nonpublic personal information. An
Investorā€™s right to privacy extends to all forms of contact with the Investment Manager and its
Clients, including telephone, written correspondence and electronic media.
We are committed to safeguarding the nonpublic personal information of our Investors and will
adhere to the foregoing policies for both current and former investors.

 

To learn more about our Privacy Policyclick here