PRIVACY NOTICE

We respect your privacy and are committed to providing the highest standards of confidentiality and safeguarding of your financial and other personal information. In that regard, we are providing this Privacy Notice to all clients.

Use of Personal and Financial Information by Us and Third Parties

We may share nonpublic personal information about you with any third party managers whom the adviser (with your consent) or you have selected to manage your account and with other third parties who provide services for your account. We do not disclose any non-public personal information about our clients or former clients to anyone, except such third party managers and service providers that manage your account. The information that we share may include:

· Information that you provide on the client profile, applications or other forms or through oral, written or electronic communications (for example, your name, address, social security number, birth date and restrictions on investments)
· Information derived from your transactions, including amounts, account balances and account numbers
· Information that we receive from non-affiliates (such as your bank account or brokerage account number(s) or account balances)

The types of third parties to whom we may disclose-nonpublic personal information about you include:

· Financial service providers, such as transfer agents, brokers and reporting services
· Third party managers selected by either the Adviser (with your consent) or you to manage your accounts

Limiting Employee Access to Information

We limit access to your information to those employees and service providers who are involved in offering or administering the products or services that we offer. We train our employees to respect customer privacy and to recognize the importance of confidentiality. If our relationship ends, we will continue to treat your non-public personal information as confidential and safeguard that information.

Security

We maintain physical, electronic, and procedural safeguards that are designed to guard your information.

This policy is effective as of 2007.