Rotella Capital Management and the Funds collect information about Account Owners and Subscribers provided on subscription and advisory agreements and on other forms and documents delivered to RCM or the Funds by investors.  Neither RCM nor the Funds will disclose any nonpublic personal information about current or former investors to anyone, except as permitted by law.  With respect to internal security procedures, RCM and the Funds restrict access to Subscribers' and Account Owners' nonpublic personal information to those employees, and on rare occasions consultants and/or temporary employees, who need to know that information to operate the Funds and Accounts and to perform related services to the Subscribers and Owners.  In addition, RCM and the Fund maintain physical, electronic and procedural safeguards that comply with Federal Standards to guard Investors' nonpublic personal information.