We recognize that you trust us with your information, and we are committed to respecting your privacy and safeguarding that information. This Privacy Policy explains how we ("we," "us," "our," or the "Fund") collect, use, disclose, and protect information in connection with this website and the related online services to which a copy of this Privacy Policy is posted (collectively, the "Site"), whether you access the Site through a computer, smartphone, tablet, or other device.

This Privacy Policy applies to information collected through the Site. Other privacy notices or privacy rights may also apply depending on how you interact with us, the products or services you obtain from us, and the jurisdiction in which you reside. This Privacy Policy does not apply to your relationship with other financial service providers, such as broker-dealers, that may serve you in connection with the products offered through the Site. Review those organizations’ privacy notice for their practices.

To the extent permitted by applicable law, by using the Site you acknowledge that you have read and understood this Privacy Policy.

1. Information We Collect

We may collect the following categories of information, depending on how you interact with us.

- Identifiers, such as your real name, alias, postal address, email address, telephone number, account name, unique personal identifier, online identifier, Internet Protocol (IP) address, Social Security number, driver's license number, or passport number.

- Financial and account information, such as account and transaction history, beneficiary information, and banking information

- Internet or other electronic network activity information, such as browsing history, information regarding your interaction with the Site, and log information collected automatically when you visit the Site (see “Online Tracking” section below).

- Geolocation data, such as general location derived from your IP address.

- Inferences drawn from the information above to create a profile reflecting your preferences and characteristics.

2. How We Collect Information

We collect information from the following sources:

- Directly from you, when you provide it to us, request information, or otherwise interact with us or the Site.

- From affiliates, financial intermediaries, and other related parties with whom you have a relationship, and from companies that provide services to you or to us.

- From fraud-prevention, identity-verification, sanctions-screening, public-record, regulatory, and government sources.

- Automatically from your device, through cookies and similar technologies when you use the Site.

3. How We Use Information

We may use the information we collect for the following business purposes:

- To provide, administer, and service products and accounts; process transactions, redemptions, distributions, and tax reporting; maintain records; and communicate about an account or transaction.

- To evaluate eligibility; verify identity, authority, and location; authenticate users; fraud prevention, and other risk-control purposes.

- To send you administrative information, including information about changes to this Privacy Policy.

- To detect, investigate, and prevent activity that may be illegal or violate our policies, and to help ensure the security and integrity of the Site.

- To operate, evaluate, and improve the Site and our products and services, including measuring traffic and usage trends.

- To comply with our legal and regulatory obligations and to enforce our terms and protect our rights and operations.

- Carry out another purpose disclosed at collection or with your consent.

4. How and With Whom We Share Information

We may disclose the information we collect from your use of the Site as follows:

- With service providers and contractors who perform services for us or assist us in operating our business or the Site, such as professional services organizations (including auditors and law firms), financial intermediaries with whom you have an existing relationship, transfer agents and other service providers to the Fund, data analytics providers, and information technology and hosting providers.

- With government, regulatory, and law enforcement agencies, and with organizations working to prevent fraud in financial services, as permitted or required by law (for example, disclosures to the Internal Revenue Service for tax purposes).

- In connection with legal process or to protect rights, including to comply with applicable laws, subpoenas, or other legal requirements, and to protect our rights, property, or the safety of others.

- In connection with a corporate transaction, such as a proposed or actual merger, sale, or transfer of all or part of our business.

- With others at your direction, with your consent, or as otherwise permitted or required by law.

We will continue to adhere to this Privacy Policy with respect to information about you covered by this Privacy Policy even after you are no longer a participant of the Fund, user of the Site, or your account with us is otherwise closed or becomes inactive.

5. Online Tracking

We and our service providers may use cookies, pixels, software development kits, logs, and similar technologies to collect information to operate the Site, remember preferences, measure performance and conduct other analytics, detect fraud, maintain security, and understand use of our services and the Site. These online trackers collect information such as your IP address, device and browser information, pages visited and other online activity. Where required, we provide notice and choices. Browser settings may allow you to block or delete such online trackers, but then some service features may not function properly.

6. Data Security

We maintain reasonable administrative, physical, technical, and procedural safeguards designed to protect the confidentiality and security of personal information and to guard against its unauthorized access or use. No system of safeguards can be guaranteed to be completely secure. If you believe your interaction with us is no longer secure, please contact us using the information in the "How to Contact Us" section below.

7. Retention of Information

We retain personal information collected from your use of this Site for as long as necessary to carry out the purposes for which it was collected and for other legitimate business purposes, including to meet our legal, regulatory, tax, accounting, and other compliance obligations.

8. Children’s Privacy

The Site is not directed to children, and we do not knowingly collect personal information from children under the age of 13 without parental consent. If you believe that a child has provided us with personal information without parental consent, please contact us and we will take steps to delete that information.

9. Links to Third-Party Websites

The Site may contain links to websites operated by third parties that we do not control. This Privacy Policy does not apply to those websites, and we are not responsible for their content or privacy practices. We encourage you to review the privacy policies of any third-party websites you visit.

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in the Site, our practices, technology, or legal requirements. If we make changes, we will post the revised Privacy Policy on the Site with a new "Last Updated" date. Any changes become effective when the revised Privacy Policy is posted, unless we indicate otherwise. In connection with material changes, we may provide additional notice, such as by posting a notice on the Site. We encourage you to review this Privacy Policy periodically to stay informed about our information practices.

11. Reviewing and Requesting Changes to Your Information

If you would like to review or request changes to the information we have collected about you, you may contact us using the information in the "How to Contact Us" section below. We will respond to your request as required by applicable law and may take reasonable steps to verify your identity before acting on it.

12. Your State Privacy Rights

Depending on your state of residence, you may have additional rights regarding your personal information. To the extent these state laws apply, we will comply with them.

12.1 California Residents

This section supplements the information above and applies to residents of California. Certain information we collect, process, and disclose is subject to the federal Gramm-Leach-Bliley Act (GLBA) and is therefore exempt from the California Consumer Privacy Act, as amended by the California Privacy Rights Act (together, the "CCPA"). The rights described below apply only to “personal information” of residents of California that is not otherwise exempt.

Categories of personal information. The categories of personal information we collect, the sources of that information, the business purposes for which we use it, and the categories of service providers, contractors, and third parties to whom we disclose it are described in the "Information We Collect," "How We Collect Information," "How We Use Information," and "How and With Whom We Share Information" sections above.

No sale or sharing. This Site does not sell or share personal information for cross-context behavioral advertising; therefore, we do not offer a right to opt out of sale or sharing.

Sensitive personal information. We collect and use sensitive personal information only for purposes permitted under the CCPA, such as providing products and services you request, verifying your identity, detecting security incidents, and protecting against fraud. Because we limit our use of sensitive personal information to these permitted purposes, we are not required to, and do not, offer a right to limit the use of sensitive personal information.

Summary of Personal Information Handling Practices During the Prior 12 Months. During the preceding 12 months, our collection, use, disclosure, retention, and other processing of personal information covered by the CCPA have been consistent with the practices described in this Privacy Policy, and we have not made any material changes to those practices that would require additional disclosure in this section.

Your rights. Subject to certain exceptions, California residents have the right to:

- Know and access the categories and specific pieces of personal information we have collected about them, the categories of sources, the business or commercial purpose for collecting it, and the categories of third parties to whom we disclose it.

- Delete personal information we have collected from them.

- Correct inaccurate personal information we maintain about them.

- Not be discriminated or retaliated against for exercising their privacy rights.

How to exercise your rights. To submit a request to know, delete, or correct, please contact us using the information in the "How to Contact Us" section below. We will use reasonable methods to verify your identity before responding, and we may ask you to provide information related to your recent interactions with us. You do not need to create an account to submit a request. We will respond within the time period required by applicable law (generally within 45 days, subject to any permitted extension). You may use an authorized agent to submit a request on your behalf; if you do, we may require evidence of the agent's authority and may verify your identity directly.

13. How to Contact Us

If you have any questions or comments about this Privacy Policy or our privacy practices, or if you would like to exercise any of the rights described above, please use the Contact Use section of this site.

14. Accessibility

If you need this Privacy Policy in an alternative accessible format, please use the Contact Use section of this site.

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