Your privacy is important to us. This Policy discusses the information we collect about you, how we treat it, with whom we share it, and how we protect it.

We may collect personal information about our investors from a variety of sources, including: information from you, such as information we receive from you on account applications or other forms (such as your name, address, social security number, marital status, employment, assets and income); and information about you, your accounts, and your holdings and transactions that we receive from you or others, such as account custodians, brokers, and other financial services firms, banks, or ERISA plan sponsors.

We do not sell information about current or former clients to third parties. We may disclose your personal information as necessary to: effect, administer, or enforce a transaction that you request or authorize; process or service a financial product or service that you request or authorize; or maintain or service your account with us or with another entity.

We may also disclose personal information for everyday business purposes to: organizations or firms who provide consulting, technology or other services for us and agree to maintain its confidentiality; others, such as attorneys, trustees, family members, or others who are authorized to represent you, your estate, or a joint or co-owner of your account; regulatory agencies; or as we are otherwise permitted or required by law or process of law.

We restrict access to your personal information to our employees and to permitted third-parties who need to know that information to provide products or services for us, or to provide, process, or maintain any security, account, or investment product, service or program for you or your benefit. To protect your personal information from unauthorized access and use, we have adopted administrative, technical, and physical security procedures that comply with federal law.

We are required by law to annually provide a notice describing our privacy policies. We will inform you promptly if there are changes to our policy. Our privacy policies, as amended from time to time, apply to all current and former investors and partners. We reserve the right to amend our privacy policies at any time, without prior notice, subject to compliance with applicable regulatory requirements. Please do not hesitate to contact us with questions about this notice.