Federal privacy laws require that we explain to you how we handle "nonpublic personal information. " We have always been committed to safeguarding your information and we appreciate this opportunity to share our privacy practices with you.

In the course of our relationship with you, we receive or develop nonpublic personal information about you. We obtain this information from you in the following ways: 1) you provide us with certain information in writing, on forms such as subscription agreements, 2) you may provide us with information orally, by phone or in meetings with us, 3) you may send information to us by e-mail or written mail and 4) we may develop information about you in the course of providing services to you, such as the amount and type of your assets under management.

As a general rule, we do not disclose this private information to others. As you might imagine, however, we rely on certain third parties for services that are necessary to enable us to provide our investment services to you. These may include our attorneys, auditors, prime brokers and custodians who, in the ordinary course of providing their services to us, may require access to information containing your nonpublic personal information. In addition, we may disclose your nonpublic personal information to others with your consent, where required by law or judicial process (such as a court order), or otherwise to the extent permitted under the Federal privacy laws.

We also restrict access to your nonpublic personal information among our own personnel. Access is available only to those who need the information in order to help us provide investment advisory services to you. It is our policy that, when we are not comfortable that a service provider is already bound by duties of confidentiality (such as attorneys and auditors), we will require contractual assurances that they will maintain the confidentiality of any of your information they obtain. We also maintain physical, electronic and procedural safeguards to protect your information.

Please let us know if you have any questions regarding our procedures for safeguarding your information.