Financial institutions like 400 Capital Management LLC (“400 Capital”) are required to provide privacy notices to their clients informing them of (1) the categories of non-public personal information that 400 Capital collects from its clients, (2) the non-public personal information that 400 Capital shares with affiliated and unaffiliated parties, and (3) 400 Capital’s general policies and procedures to protect non-public personal information.

400 Capital collects information from its clients through managed account agreements and subscription agreements and related forms, investor questionnaires, and other information provided by the client in writing, in person, by telephone, electronically or by any other means. Examples of such information include name, address, social security number, birth date, assets, income and investment experience. 400 Capital also collects information from your transactions with 400 Capital, such as account activity and balances.

400 Capital is committed to protecting clients’ non-public personal information and maintains administrative, technical and physical safeguards for the protection of such information. Access to physical and electronic records containing non-public personal information is restricted to our personnel who need to know that information in order to provide services to you.

In order to service your accounts and process your transactions, 400 Capital will provide your non-public personal information to our affiliates and to firms that assist us in servicing your account and have a need for such information such as administrators. We require third party service providers to protect the confidentiality of your information.

400 Capital does not disclose any non-public personal information about our clients to anyone other than (1) in connection with the administration, processing and servicing of a client’s accounts as described above, (2) to our accountants, attorneys and auditors, or (3) as otherwise permitted or required by law.

400 Capital does not share non-public personal information with affiliated or unaffiliated third parties except under the circumstances noted above. Since sharing under such circumstances is necessary to service a client’s account or is permitted or required by law, clients cannot limit this sharing.

This privacy notice applies to 400 Capital and each investment vehicle to which 400 Capital serves as investment manager or investment adviser.

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