400 Capital Management LLC (the “Adviser”) does not disclose non-public personal information about our clients/investors or former clients/investors to third parties other than as described below. We may obtain non-public personal information about our clients/investors, including but not limited to your name, e-mail address, social security number or tax identification number, bank or brokerage account numbers, financial situation, subscription commitments, withdrawals, transaction history and other personal information (the “Information”), from our discussions with you or through documents you deliver to us. The Adviser is committed to the protection and privacy of Information and will not share such Information with any affiliated or nonaffiliated third party except:

  • When necessary to complete a transaction in a customer account, such as with the clearing firm or account custodians;
  • When required to maintain or service a customer account;
  • To resolve customer disputes or inquiries;
  • With persons acting in a fiduciary or representative capacity on behalf of the customer;
  • With rating agencies, persons assessing compliance with industry standards, or to the attorneys, accountants and auditors of the Adviser;
  • In connection with a sale or merger of the Adviser’s business;
  • To protect against or prevent actual or potential fraud, identity theft, unauthorized transactions, claims or other liability;
  • To comply with federal, state or local laws, rules and other applicable legal requirements;
  • In connection with a written agreement to provide investment management or advisory services when the information is released for the sole purpose of providing the products or services covered by the agreement; or
  • In any circumstances with the customer’s instruction or consent.

The Adviser maintains physical, electronic and procedural safeguards that comply with U.S. federal standards to guard the Information.