Privacy Policy and Practices of Alternative Capital Advisers, LLC and its Affiliates (herein called the “Company”)

The Securities and Exchange Commission and the Federal Trade Commission have adopted rules that require financial institutions, like Alternative Capital Advisers, LLC (the “Company”), to provide privacy policy notices to their customers, which includes the Company’s investors. The Company believes that protecting the privacy and personal information of the Company’s current, former, and prospective investors is of utmost importance and the Company is fully committed to maintaining the privacy of such information in the Company’s possession. In accordance with applicable rules, the Company is providing current and prospective investors with the following information.

The Company’s privacy policy (the “Privacy Policy”) covers the practices of the Company and applies to all nonpublic personally identifiable information, including information contained in consumer reports, of the Company’s current and former investors. The Company collects nonpublic personal information about current and prospective investors from the following sources: (i) information the Company receives on Fund Subscription Agreements and related forms (for example, name, address, social security number, birth date, assets, income, and investment experience); and (ii) information about investor transactions with the Company (for example, account activity and balances).

The Company is responsible for ensuring the security and confidentiality of investor records and information; protecting against any anticipated threats or hazards to the security or integrity of investor records and information; and protecting against unauthorized access to or use of investor records or information that could result in substantial harm or inconvenience to any investor.

Each of the Company’s associated persons has a duty to: (1) protect the nonpublic personal information of clients collected by the Company; (2) ensure that nonpublic personal information of the Company’s clients is shared only with associated persons of the Company and others in a way that is consistent with the Company’s Privacy Policy; and (3) ensure that access to nonpublic personal information of the Company’s investors is limited as provided in the Privacy Policy. No associated person is authorized to sell, on behalf of the Company or otherwise, nonpublic information of the Company’s clients.

The Company only discloses nonpublic personal information about the Company’s current, former, and prospective investors as permitted by law or regulation and in accordance with the Company’s rules and procedures. The Company restricts access to such nonpublic personal information to our personnel, the Company’s affiliates and their personnel, the Company’s service providers, the Company’s outside counsel, and the Company’s outside auditors who need to know that information in order to (i) ensure compliance with applicable laws and regulations or (ii) when it is necessary to effect, administer, or enforce a transaction requested or authorized by clients. Accordingly, the Company maintains physical, electronic, and procedural controls in keeping with federal standards to safeguard the nonpublic personal information about current, former, and prospective investors that is in the Company’s possession.

If, at any time in the future, it is necessary to disclose any of your personal information in a way that is inconsistent with this policy, the Company will give you advance written notice of the proposed change so that you will have the opportunity to “opt out” of such disclosure.

Please email or call 646-412-7111 if you have any questions regarding this notice. Thank you.