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PRIVACY POLICY

PLEASE READ THIS PRIVACY STATEMENT CAREFULLY BEFORE USING THIS SITE. THIS WEBSITE IS FOR INFORMATIONAL PURPOSES ONLY.

THIS WEBSITE IS NOT AN OFFER TO SELL INTERESTS IN ANY FUND. ANY OFFER TO SELL OR SOLICIATION TO BUY INTERESTS IN ANY FUND WILL BE MADE ONLY BY CONFIDENTIAL MEMORANDUM.

While conducting business Carmel Asset Management, LLC may obtain information about you. We understand that you expect us to treat this information appropriately. Our privacy policy describes the information we may collect, how we use the information and the situations where we might disclose the information. The term “CAM” refers to Carmel Asset Management, LLC.

CONSENT
By using this website and by providing us with your information, you freely consent to CAM’s use of the information in the United States and in other countries in accordance with applicable laws and regulations. If you do not wish for CAM to collect information please do not use or visit this website and do not provide information to CAM.

INFORMATION SECURITY
CAM works to protect the privacy of information. Only permissioned CAM employees or agents have access to information. We maintain physical, electronic, and process safeguards to protect the information against loss or misuse. CAM’s information security procedures include technology such as firewalls, filtering, anti-virus and mal-ware software and the use of encryption.

COOKIES
To provide better security, we may use a ‘cookie’ on our website. A cookie is information a website stores on your computer which can be accessed later. Cookies are employed to improve website functionality. You can control the use of cookies through settings in your browser.

INFORMATION SOURCES
Information we receive comes from forms and materials you submit to CAM. We also collect information about your investments with CAM and wire instructions to your banking or investment accounts. Also subject to compliance with applicable laws and regulations, information may be collected from monitoring conversations, phone calls, email, and other electronic communications. The information collected may be used for compliance.

PRIVATE INFORMATION
CAM does not sell information. If you conduct business with CAM as an individual or as a trustee or beneficiary or as a principal of a company we typical collect the following:

• Name, address. and contact information;
• Information, including objectives, risk tolerance, and representations required under applicable law or regulation;
• Social Security Number, National Insurance Number, Tax File Number; and
• Information regarding wire transfers to banking or investment accounts.

While you are not required to supply the information requested, failure to do so may prevent us from conducting business with you. We work to ensure that information we hold about you is accurate.

Use of Personal Information We may use your information to:
• Manage our business relationship including sharing information internally and with third parties;
• Contact you by mail, phone, email, or fax;
• Provide you with information or recommendations.

INSIDE CAM
To provide for our business relationship more than one person within CAM may be given access to your information. When sharing your information internally we follow applicable legal standards and employee safeguards.

THIRD PARTIES
CAM does not disclose your information to third parties except as described here. Third party disclosures include sharing information with our auditors, administrators, bankers and prime brokers. Third parties that assist CAM in providing services are required to maintain information confidentiality and to use your personal information only in providing services and only for the purposes that CAM directs.

We may also disclose information to fulfill instructions and to protect our rights and those of our partners. Information may be disclosed to comply with applicable laws and regulations and to cooperate with law enforcement, regulatory authorities, and with exchanges and clearinghouses.

CAM WEBSITE AND PRIVACY
As a visitor to http://www.carmelasset.com please remember that users of CAM’s website are required to identify and authenticate themselves. Identification and authentication require the use of a user name and a password.

This policy provides a statement of how CAM protects information. This policy may be changed from time to time. The revised policy will be effective immediately upon posting to our website.

In Europe, Switzerland, Hong Kong, Japan, and Australia you are entitled to access any personal data about you held by CAM by sending a written request to CAM. You may be required to supply a means of identification to prevent the unauthorized disclosure of information.

If you want more information regarding our privacy policies, please contact CAM in writing:

CONTACT INFORMATION
Carmel Asset Management, LLC
1120 Avenue of the Americas, Suite 1503
New York, NY 10036
646-201-5200

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