Privacy Policy

PRIVACY POLICY

Our Commitment to Your Privacy: We are sensitive to the privacy concerns of our individual advisory clients and fund investors. We have a long-standing policy of protecting the confidentiality and security of information we collect about you. We are providing you with this notice to help you better understand why and how we collect certain personal information, the care with which we treat that information, and how we use that information.

Sources of Non-Public Information: In connection with managing separately managed accounts of our clients and private investment funds for our investors, we collect and maintain non-public personal information from the following sources:

1. Information we receive from you in conversations in person and over the telephone, in voice mails, through written correspondence, via email, in investment management agreements, subscription agreements, investor questionnaires or other forms;
2. Information about your transactions with us or others; and
3. Information captured on our website, including registration information and any information captured via cookies, if any.
This information includes, without limitation, your address, social security number, assets, investment experience, transaction history, income and wire transfer instructions.

Disclosure of Information: We do not knowingly disclose non-public personal information about you to any other person or entity except our personnel, third-party professional service providers who are provided access to such information in order to carry out our operations, or as otherwise required by law or regulation. These sharing practices are consistent with federal privacy and related laws, and in general, you may not limit the use of your personal information for these purposes under such laws. We note that the federal privacy laws only give you the right to limit the certain types of information sharing that we do not engage in (e.g., sharing with affiliates certain information relating to your transaction history or creditworthiness for their use in marketing to you, or sharing any personal information with non-affiliates for them to market to you).

Former Clients and Fund Investors: We maintain non-public personal information of our former clients and fund investors and apply the same policies that apply to current clients and fund investors.

Information Security: We consider the protection of sensitive information to be a sound business practice, and to that end we employ physical, electronic and procedural safeguards to protect your non-public personal information in our possession or under our control.

Further Information: We reserve the right to change our privacy policies and this Privacy Policy Notice at any time. The examples contained within this notice are illustrations only and are not intended to be exclusive. This notice is intended to comply with the privacy provisions of applicable U.S. federal law. You may have additional rights under other foreign or domestic laws that may apply to you.

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