The Advisor has adopted internal procedures designed to protect investors’ confidential
personal information from inappropriate disclosure to third parties.
The Advisor and the Fund receive personal investor information in subscription forms and other documents furnished by investors, information relating to investors’ transactions with the Fund and its affiliates, and investors’ bank and brokerage account information.
The Advisor and the Fund do not disclose nonpublic personal information about investors to any third parties, except as necessary or appropriate in connection with operations of the Fund or as required by law. Neither the Advisor nor the Fund will sell or profit in any way from disclosure of confidential investor information.
The Advisor and the Fund restrict access to confidential investor information to those employees and agents of the Advisor and the Fund who need to know such information in order to provide services to the investors. The Advisor and the Fund maintain physical, electronic and procedural safeguards in order to ensure security of confidential investor information and to prevent unauthorized disclosure of such information.
Each subscriber will also be required to acknowledge in its subscription application that the Fund, the Advisor and/or the Administrator may disclose to each other, to any service provider to the Fund or to any regulatory body in any applicable jurisdiction copies of the subscriber’s subscription application and any information concerning the subscriber provided by the subscriber to the Fund, the Advisor and/or the Administrator and any such disclosure shall not be treated as a breach of any restriction upon the disclosure of information imposed on such
person by law or otherwise.