Welcome to MarvinandPalmer.com. This Web Site is owned and operated by Marvin & Palmer Associates, Inc. (“M&P”). You may use MarvinandPalmer.com only if you agree, without modification, to these terms and conditions (“Terms”). These Terms apply regardless of the channel by which you accessed them. Please read the Terms carefully before continuing. By using this Web Site you signify acceptance of our Terms, and you may not use this Web Site unless you agree with the Terms. You agree to use this Web Site in a manner consistent with applicable laws and regulations and in accordance with these Terms as they may be amended from time to time. M&P reserves the right to modify these Terms without notice. These Terms have been revised as of: May 12, 2020.

The terms “M&P Web Site” and this “Web Site” mean the web site having a Uniform Resource Locator (or URL) of MarvinandPalmer.com and any other web site owned, operated, licensed, or controlled by M&P. The term “Representative” means any director, officer, employee or agent of M&P or any affiliate thereof.

M&P will not treat users of this Web Site as partners, clients, customers or investors by virtue of accessing this Web Site.

1. No Investment Advice or Recommendations
   
2. Jurisdictional Issues and Applicable Law
   
3. Modification of Terms and Web Site
   
4. Monitoring of Web Site
   
5. Trademarks, Copyrights and Restrictions on Use of Materials
   
6. Restrictions on Use of Web Site
   
7. Ownership of Other Materials
   
8. Hyperlinks and Third-Party Content
   
9. Privacy and Security
   
10. Contents of the Web Site – Disclaimer
    
11. Operation of the Web Site – Disclaimer
    
12. Limitation of Liability
    
13. Integration and Severability
    
14. Indemnification
    
15. Choice of English Language

1. No Investment Advice or Recommendations The M&P Web Site and its content are for information and education purposes only. You alone will need to evaluate the merits and risks associated with the use of the M&P Web Site.

Although this Web Site may provide information relating to approaches to investing or types of securities and investments you might buy or sell, no information available through the Web Site is intended or should be construed as an investment recommendation or endorsement from M&P. Nothing on this Web Site shall be considered a solicitation or offer to buy or sell any security, future, option or other financial instrument or to offer or provide any investment advice or service to any person in any jurisdiction where such solicitation or offer would be unlawful under the laws of such jurisdiction. Nothing contained on the Web Site constitutes investment advice and the views expressed on this Web Site should not be taken as advice to buy or sell any security. In preparing the information contained in this Web Site, M&P has not taken into account the investment needs, objectives and financial circumstances of any particular investor. You are advised not to rely on any information contained on this Web Site in the process of making an informed decision. Furthermore, no information or materials contained on this Web Site should be construed or relied upon as investment, legal, accounting, tax or other professional advice. Decisions based on information contained within the Web Site are your sole responsibility, and before making any decision on the basis of the information, you should consider with or without the assistance of a securities adviser or other adviser, whether the information is appropriate in light of your particular investment needs, objectives and financial circumstances. If you wish to obtain further details about any information contained on this Web Site, please contact M&P.

The Web Site may contain forward-looking statements, which reflect our current views with respect to, among other things, the operations and performance of our businesses. You can identify these forward-looking statements by the use of words such as “outlook,” “believe,” “expect,” “potential,” “continue,” “may,” “should,” “seek,” “approximately,” “predict,” “intend,” “will,” “plan,” “estimate,” “anticipate” or the negative version of these words or other comparable words. Forward-looking statements are subject to various risks and uncertainties. Accordingly, there are or will be important factors that could cause actual outcomes or results to differ materially from those indicated in these statements. We undertake no obligation to publicly update or review any forward-looking statement, whether as a result of new information, future developments or otherwise.

The views expressed on this Web Site were prepared by M&P based upon the information available at the time such views were written. Changed or additional information could cause such views to change.

Any past performance shown is not indicative of future results. No representation is being made that any investment or transaction will or is likely to achieve profits or losses similar to those achieved in the past, or that significant losses will be avoided. The investment return and principal value of an investment will fluctuate and, as a result, your redemption value may be more or less than original cost.

2. Jurisdictional Issues and Applicable Law M&P is an investment adviser registered with the United States Securities and Exchange Commission under the Investment Advisers Act of 1940. Unless otherwise specified, M&P controls and operates this Web Site from our offices within the State of Delaware, United States of America. The services and products described and information provided on this Web Site are directed to, and are intended to be made available only to, persons in the United States and are not intended for distribution to, or use by, any person in any other country or any jurisdiction where such distribution or use would be contrary to law or regulation or that would subject M&P to any registration requirement within such jurisdiction or country. Unless otherwise expressly stated herein, M&P makes no representation that transactions, products or services discussed on or accessible through the Web Site are available or appropriate for sale or use in all jurisdictions or by all users, or that access by any user in the place it is located is not illegal or prohibited. Persons who access this Web Site do so on their own initiative and are responsible for compliance with applicable local laws or regulations. M&P reserves the right to limit access to this Web Site to any person, geographic region or jurisdiction.

M&P’s investment adviser Representatives only may transact business in any state or province if they first are registered, or excluded or exempted from registration, under applicable laws of that state or province. Individualized, follow up responses will not be made, and additional information about M&P’s investment advisory services will not be provided, to persons in any state or province absent compliance with applicable laws or an exemption or exclusion therefrom.

The laws of the State of Delaware and applicable U.S. federal law shall govern these Terms. If you take legal action relating to these Terms, you agree to file such action only in state or federal court within the State of Delaware, and you consent and submit to the personal jurisdiction of those courts for the purposes of litigating any such action. If any part of these Terms is or becomes unlawful, void or unenforceable, that part will be deemed severable and will not affect the validity and enforceability of any remaining provisions. You agree that any cause of action you may have with respect to your use of this Web Site must be commenced within one (1) year after the claim or cause of action arises, or it will be deemed to have been waived.

3. Modification of Terms and Web Site M&P reserves the right, at our discretion, to change these Terms at any time. We suggest that you review these Terms periodically for changes. The Terms can be accessed from links on the home (or index) page and other pages of the M&P Web Site. If you use this Web Site after we post changes to these Terms, you accept the changed Terms. M&P may also offer other services from time to time that are governed by different terms and conditions. If you have an account with M&P, your customer relationship with M&P is also governed by other agreements, including your account agreement. M&P reserves the right to modify, suspend or discontinue this Web Site temporarily or permanently and with or without notice. M&P assumes no liability for any such modification, suspension or discontinuance.

4. Monitoring of Web Site M&P expressly reserves the right to monitor any and all use of this Web Site and to retain and review records of such use. M&P is under no obligation to do so and assumes no responsibility or liability arising from the use or operation of this Web Site, including any decision to undertake or not to undertake monitoring activities, either generally or in specific instances. Our communications via email are not encrypted. You acknowledge that there is a risk that data, including email, electronic communications, including wireless communications, and personal data, may be accessed by unauthorized third parties when communicated between you and M&P.

5. Trademarks, Copyrights and Restrictions on Use of Materials M&P owns and operates this Web Site. MARVIN & PALMER, MPA CAPITAL, MARVIN & PALMER ASSOCIATES, INC. GLOBAL EQUITY MANAGEMENT and Design are trademarks or registered trademarks of Marvin & Palmer Associates, Inc. in the United States and other jurisdictions. All other product names, company names, marks, logos, and symbols are trademarks of their respective owners, as explicitly noted below under “Ownership of Other Materials.” Nothing contained in this Web Site should be construed as granting, by implication, estoppel, or otherwise, any license or right to use any trademark displayed on this Web Site without the written permission of M&P or such third party that may own the trademarks displayed in this Web Site. Images displayed in this Web Site are either the property of, or used with permission by, M&P. You are prohibited from using or authorizing the use of these images without the prior approval of M&P.

6. Restrictions Without limiting the generality of the foregoing, users and other web sites may not:

1. Copy, reproduce, republish, upload, post, transmit, or distribute in any way material from this Web Site in any manner inconsistent with the purposes for which it is offered by M&P to its clients, prospective clients or members of the general public.
2. Without M&P’s express written permission, copy, modify, or display M&P’s name or logo, or any text, graphic images, or other content from the M&P Web Site. (To obtain express written permission, you can send us an e-mail by clicking on the email address on the “Contact Us” page.)
3. Redeliver any of the pages, text, images, or other content of the M&P Web Site using “framing” technology without M&P’s express written permission.
4. Use devices (including software) that are designed to provide repeated automated access to MarvinandPalmer.com other than those made generally available by M&P.
5. Include “M&P”, “Marvin & Palmer”, any other M&P trademark, the name of any M&P personnel, or any variation of any of the foregoing, as a metatag, hidden textual element, or any other indicator that may create a false or misleading impression of affiliation, sponsorship, or endorsement between any user and/or site and M&P.
6. Collect or store personal data about other users of this Web Site.
7. Upload, e-mail or otherwise transmit any advertising, promotional or other material in a manner that would constitute a violation of the CAN-SPAM Act of 2003 (Controlling the Assault of Non-Solicited Pornography and Marketing Act) or similar state law.
8. Upload, email or otherwise transmit any material that contains viruses, worms, time bombs or any other similar system or computer code, files or programs that might interrupt, limit or interfere with the functionality of any computer software or hardware or the telecommunications equipment that is owned, leased or used by M&P.
   • Interfere with the functioning of this Web Site or restrict or inhibit others from using this Web Site.
   • Create a link to the M&P Web Site unless any such link satisfies all of the following requirements:
   • Resolves to M&P’s homepage at www.MarvinandPalmer.com.
   • Indicates clearly that the link will lead to the web site of “Marvin & Palmer Associates, Inc.”
   • Does not falsely or misleadingly represent or suggest any relationship between the linking site and M&P (including suggestions of affiliation, endorsement, or sponsorship).
   • Delivers M&P’s content outside of a framed environment.
   • Maintains the integrity of M&P’s layout, content, and look and feel.
   • Delivers users to the M&P Web Site, unaltered, unmodified, unadulterated in any way by the linking site.
9. Gain or attempt to gain access (or encourage others to gain or attempt to gain access) to the identities, information or computers of others through this Web Site.
10. Violate or attempt to violate (or encourage others to violate or attempt to violate) any law, regulation, rule, the intellectual property or contractual rights of others, or the security of this Web Site.

7. Ownership of Other Materials

• The Standard and Poor’s 500 is the product of The McGraw-Hill Companies, Inc.
  
• GIPS^® are the trademarks of the CFA Institute.

8. Hyperlinks and Third-Party Content
M&P does not review or monitor any websites linked from or to this Web Site and is not responsible for the content of any such websites. Accordingly, M&P cannot be held responsible for the information, materials, products or services obtained on or from such other websites, nor will we be liable in any respect whatsoever for any damages arising from your access to such websites. Any links from or to other websites are provided merely for the convenience of the users of this Web Site and the inclusion of these links does not imply an endorsement, representation or warranty by M&P with respect to any such linked websites or the content, products or services contained or accessible through such websites or their operators. M&P DISCLAIMS RESPONSIBILITY FOR THE PRIVACY POLICIES AND CUSTOMER INFORMATION PRACTICES OF THIRD- PARTY INTERNET WEBSITES HYPERLINKED FROM THIS WEB SITE. M&P is not responsible for content that appears on MarvinandPalmer.com that may be provided by a third party. Your following links from or to such websites is at your sole risk.

9. Privacy and Security
Subject to any applicable Terms in M&P’s Web Site Privacy & Security Statement, any communication or other material that you send to us through the Internet or post on this Web Site by electronic mail or otherwise, is and will be deemed to be non-confidential as between you and M&P. M&P shall have no obligation of any kind with respect to such information. M&P will be free to use, for any purpose, and without compensation due or payable to you, any ideas, concepts, know-how or techniques provided by you to M&P through this Web Site. For information on how M&P uses and protects the personal information you may provide on this Web Site, please click on this link to M&P’s Web Site Privacy & Security Statement. You may not use this Web Site to collect or harvest personal information about other persons or otherwise use this Web Site in a manner that is inconsistent with their privacy or personal data protection rights.

Click here to view the General Privacy & Security Statement.

10. Contents of the Web Site – Disclaimer
THE MATERIALS IN THIS WEB SITE (INCLUDING ANY GRAPHICS) AND ANY MATERIALS MADE AVAILABLE THROUGH THIS WEB SITE ARE PROVIDED “AS IS” AND “AS AVAILABLE” AND WITHOUT WARRANTIES OF ANY KIND, EITHER EXPRESS OR IMPLIED. TO THE FULLEST EXTENT PERMISSIBLE PURSUANT TO APPLICABLE LAW, M&P DISCLAIMS ALL WARRANTIES, EXPRESS OR IMPLIED, INCLUDING, BUT NOT LIMITED TO, ALL IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, TITLE AND NON-INFRINGEMENT. THE DATA PROVIDED IN THIS WEB SITE IS OBTAINED FROM A VARIETY OF SOURCES THAT ARE BELIEVED TO BE ACCURATE. HOWEVER, THE ACCURACY OR COMPLETENESS CANNOT BE GUARANTEED. M&P DOES NOT WARRANT OR MAKE ANY REPRESENTATIONS REGARDING THE USE OR THE RESULTS OF THE USE OF THE MATERIALS IN THIS WEB SITE IN TERMS OF THEIR COMPLETENESS, ACCURACY, TIMELINESS, RELIABILITY, OR OTHERWISE. THE MATERIALS IN THIS WEB SITE COULD INCLUDE TECHNICAL INACCURACIES OR TYPOGRAPHICAL ERRORS. THESE MATERIALS COULD BECOME INACCURATE AS A RESULT OF DEVELOPMENTS OCCURRING AFTER THEIR RESPECTIVE DATES. M&P UNDERTAKES NO OBLIGATION TO MAINTAIN THE CURRENCY OF SUCH INFORMATION.

CERTAIN LINKS IN THIS WEB SITE MAY LINK YOU TO OTHER SITES ON THE WORLD WIDE WEB. THE LINKED SITES ARE NOT UNDER THE CONTROL OF M&P AND M&P IS NOT RESPONSIBLE FOR THE CONTENTS OF ANY LINKED SITE OR ANY LINK CONTAINED IN A LINKED SITE OR ANY CHANGES OR UPDATES TO SUCH SITES. M&P IS NOT RESPONSIBLE FOR WEBCASTING OR ANY OTHER FORM OF TRANSMISSION RECEIVED FROM ANY LINKED SITE. M&P IS PROVIDING THESE LINKS TO YOU ONLY AS A CONVENIENCE, AND THE INCLUSION OF ANY LINK DOES NOT IMPLY A REFERRAL BY M&P TO, OR AN ENDORSEMENT BY M&P OF, THE LINKED SITE.

11. Operation of the Web Site – Disclaimer
M&P ENDEAVORS TO MAINTAIN THIS WEB SITE AND ITS OPERATION, BUT IS NOT, AND CANNOT BE, RESPONSIBLE FOR THE RESULTS OF ANY DEFECTS THAT MAY EXIST IN THE WEB SITE OR ITS OPERATION. AS TO THE OPERATION OF THE WEB SITE, M&P EXPRESSLY DISCLAIMS ALL WARRANTIES OF ANY KIND, WHETHER EXPRESS OR IMPLIED, INCLUDING, BUT NOT LIMITED TO, THE IMPLIED WARRANTIES OF MERCHANTABILITY AND FITNESS FOR A PARTICULAR PURPOSE. M&P MAKES NO WARRANTY THAT (i) THE OPERATION OF THE WEB SITE WILL MEET THE USER’S REQUIREMENTS; (ii) ACCESS TO THE WEB SITE WILL BE UNINTERRUPTED, TIMELY, SECURE, FREE OF VIRUSES OR OTHER HARMFUL COMPONENTS, OR FREE OF ERRORS; (iii) THE RESULTS THAT MAY BE OBTAINED FROM THE USE OF THE WEB SITE WILL BE ACCURATE OR RELIABLE; OR (iv) DEFECTS WILL BE CORRECTED. YOU (AND NOT M&P) ASSUME THE ENTIRE COST OF ALL SERVICING, REPAIR, OR CORRECTION THAT MAY BE NECESSARY FOR YOUR COMPUTER EQUIPMENT AND SOFTWARE AS A RESULT OF ANY VIRUSES, ERRORS OR OTHER PROBLEMS YOU MAY HAVE AS A RESULT OF VISITING THIS WEB SITE.

12. Limitation of Liability
UNDER NO CIRCUMSTANCES SHALL M&P OR ANY REPRESENTATIVE BE LIABLE FOR ANY DAMAGES OR INJURY, INCLUDING ANY DIRECT, SPECIAL, INCIDENTAL, CONSEQUENTIAL OR PUNITIVE DAMAGES OR ANY LOSS OF PROFITS, GOODWILL, USE, DATA OR OTHER INTANGIBLE LOSSES, THAT MAY RESULT FROM THE USE OF, OR THE INABILITY TO USE, THE MATERIALS IN THIS WEB SITE, WHETHER IN AN ACTION OF CONTRACT, NEGLIGENCE OR OTHER TORTUOUS ACTION, ARISING OUT OF OR IN CONNECTION WITH THE USE OR PERFORMANCE OF INFORMATION AVAILABLE IN THE WEB SITE. NEITHER M&P NOR ANY REPRESENTATIVE SHALL BE LIABLE EVEN IF M&P OR A REPRESENTATIVE HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES. THESE INCLUDE, BUT ARE NOT LIMITED TO, DAMAGES OR INJURY CAUSED BY ERROR, OMISSION, INTERRUPTION, DEFECT, FAILURE OF PERFORMANCE, DELAY IN OPERATION OR TRANSMISSION, LINE FAILURE OR COMPUTER VIRUS OR OTHER HARMFUL COMPONENT.

13. Integration and Severability
THESE TERMS REPRESENT THE ENTIRE AGREEMENT BETWEEN M&P AND THE USER RELATING TO THE SUBJECT MATTER HEREIN.

APPLICABLE LAW IN SOME JURISDICTIONS MAY NOT ALLOW THE EXCLUSION OF CERTAIN WARRANTIES OR THE LIMITATION OR EXCLUSION OF LIABILITY FOR INCIDENTAL OR CONSEQUENTIAL DAMAGES. ACCORDINGLY, SOME OF THE ABOVE LIMITATIONS OR EXCLUSIONS MAY NOT APPLY TO YOU. HOWEVER, IN SUCH CIRCUMSTANCES THE LIABILITY OF M&P OR ANY REPRESENTATIVE IS LIMITED TO THE GREATEST EXTENT ALLOWABLE UNDER APPLICABLE LAW IN SUCH JURISDICTIONS AND IN NO EVENT SHALL THE TOTAL LIABILITY TO YOU OR M&P OR ANY REPRESENTATIVE FOR DAMAGES, LOSSES, AND CAUSES OF ACTION (WHETHER IN CONTRACT, TORT (INCLUDING, BUT NOT LIMITED TO, NEGLIGENCE), OR OTHERWISE) EXCEED THE AMOUNT PAID BY YOU, IF ANY, FOR ACCESSING THIS SITE.

14. Indemnification
AS CONSIDERATION FOR ACCESSING THIS WEB SITE, YOU AGREE TO INDEMNIFY AND HOLD M&P AND ITS REPRESENTATIVES HARMLESS FROM ANY CLAIM, DEMAND, LOSS, COSTS OR EXPENSE, INCLUDING ATTORNEYS’ FEES, MADE BY ANY PERSON ARISING OUT OF YOUR VIOLATION OF THESE TERMS, STATE OR FEDERAL SECURITIES LAWS OR REGULATIONS, OR ANY OTHER PERSON’S RIGHTS, INCLUDING, BUT NOT LIMITED TO, INFRINGEMENT OF ANY COPYRIGHT OR VIOLATION OF ANY PROPRIETARY OR PRIVACY RIGHT.

15. Choice of English Language
The parties have requested that these Terms and Conditions and all documents contemplated hereby be drawn up in English. Les parties aux présentes ont exigé que cette entente et tous autres documents envisagés par les presésentes soient rédigés en anglais.

16. COPYRIGHT NOTICE.
Copyright© 2001-2023 Marvin & Palmer Associates, Inc., 200 Bellevue Parkway, Suite 220, Wilmington, Delaware 19809. All rights reserved.

Revised on May 12, 2020

The Web Site you have entered is operated by and on behalf of Marvin & Palmer Associates, Inc. (“M&P”). M&P provides global equity investment management services and manages and advises certain limited partnerships and commingled funds. Currently M&P collects only minimal Personal Information through its Web Site. However, this General Privacy & Security Statement is posted on this Web Site because of the great importance M&P places on the privacy and information security of its current and former investors and clients, as well as prospective investors and clients.

Click here for an Overview of M&P

This General Privacy and Security Statement (this “Statement”):

• outlines the types of Personal Information that is collected by M&P through this Web Site and by other means;
  
• tells you how we use and protect Personal Information;
  
• tells you what to do if you do not want your Personal Information collected when you visit this Web Site or otherwise provide information to us; and
  
• tells you how you can change Personal Information you have already provided to us.

By using this Web Site, you signify that you agree with the terms of this Statement as amended from time to time and as posted in this area of this Web Site. By using this Web Site and providing your Personal Information to us you consent to our collection of your Personal Information and our use of it in accordance with this Statement. If you do not agree with any term in this Statement, please do not use this Web Site or otherwise provide Personal Information to us.

This Web Site promotes financial services offered in accordance with the laws and regulations of the United States and is intended for viewing only by residents of that jurisdiction.

You may be able to access other web sites by clicking on links that we have provided on this Web Site. You should be aware that other web sites are not subject to our privacy standards and procedures. You will need to contact those web sites or their operators directly to ascertain their privacy standards.

M&P reserves the right to change or remove this Statement at our discretion. If we decide to change this Statement, we will post those changes at an appropriate place on our Web Site. We encourage you to visit this area frequently to stay informed. If you access this Web Site after we have posted changes to this Statement, you are agreeing to accept the changes.

Who is Covered by This Statement:
This Statement applies to individuals who provide Personal Information through this Web Site to M&P or otherwise, who apply to invest in or who invest in one of the limited partnerships or commingled funds sponsored by M&P (“Investment Funds”) or who are prospective clients of, or who have accounts managed by, M&P.

What is Personal Information:
This Statement describes our policies and practices for collecting, using, disclosing, retaining, and safeguarding “nonpublic personal information”, which may include information about investors and clients as identifiable individuals, such as name, street address, social security number or other national identification number, income, assets information, financial interests and objectives, account balances, and investment history (“Personal Information”).

Where the Personal Information Comes From:
We collect Personal Information from the following sources: (1) Personal Information provided to us on subscription agreements, other agreements and related forms that investors and clients complete and send to us, (2) Personal Information provided to us by using this Web Site and (3) Personal Information that is created about investors and clients as we administer their interest in the Investment Funds or their account. Some of this information may be obtained from third-party providers.

Our Assurances about Privacy and Security for Personal Information

1. Priority:
Protecting privacy is a top priority. We are committed to protecting privacy. If you have any questions or concerns about how we treat your Personal Information, please let us know using one of the methods listed under How to Reach Us so that we can address them

2. Notice:
We will give investors and clients notice of our privacy policy annually, and we will provide prompt notice if we make material changes. In addition to providing this Statement, we distribute a written Privacy Policy to investors and clients when they open an account with us and at least annually thereafter. We reserve the right to change this Statement and our Privacy Policy at any time. If we make material changes to this Statement or to the Privacy Policy, including material changes or additions to the purposes for which we collect, use, disclose or retain Personal Information, we will post the changes or additions here. We also will tell investors and clients promptly and, if required, seek their consent.

3. Choice:
We will give investors and clients certain choices regarding our collection, use and disclosure of their Personal Information. We will use Personal Information only as provided in this Statement and our Privacy Policy and only in accordance with the choices our investors and clients have made. We describe below in Section 4 (Limits on Collection, Use and Disclosure) how we may collect, use and disclose Personal Information. Investors and clients can choose, at any time, to opt out of receiving the communications described under the heading “Other Communications” in Section 4. In addition, if we are required to seek their consent, investors and clients can choose to opt out of material changes or additions that we propose to make to the purposes for which we collect, use, disclose or retain their Personal Information. Investors and clients can let us know by printing out, completing and returning the attached Reply Form or by using any one of the other methods listed under How to Reach Us. Investors and clients can change their decision as often as they like.

An investor who holds an interest in an Investment Fund jointly with one or more other persons has the right to make the decisions concerning the use of Personal Information that pertains to himself or herself alone. When investors hold an interest jointly, each acting alone has the right to make decisions concerning the use of the information that pertains to those persons together. If there is a delegation of authority to any one of the joint accountholders, that person, acting alone, may make decisions concerning the use of all Personal Information of all joint accountholders, and any decision by that person will be controlling. A separate form of consent will be needed to set up a delegation of authority.

4. Limits on Collection, Use and Disclosure:
We limit our collection, use and disclosure of Personal Information to what is necessary to run our business and to deliver superior service.

In General. We will collect, use and disclose Personal Information for the following purposes: (1) to respond to inquiries received through the e-mail facility in our Web Site, (2) to establish and maintain an account, (3) communicate with clients and investors about their account, related matters and other matters, (4) to effect, administer and enforce a transaction involving or related to an account that the client or investor requests or authorizes, (5) to identify the client or investor in order to protect against fraud and guard against unauthorized access to their accounts, (6) to keep our information about clients and investors current and accurate, (7) to determine whether prospective investors are qualified under the securities laws to purchase an interest in the Investment Funds, (8) to facilitate the preparation and filing of tax information and financial statements, (9) to perform necessary credit checks or collect or report debts owed to us, (10) to protect our rights or property, (11) upon reasonable request by the Investment Fund in which an investor has chosen to invest and (12) otherwise to provide quality service to our clients and investors (including processing and storage of their Personal Information in any of our offices world-wide). To do these things we may share Personal Information with service providers, such as accountants, lawyers, trustees, custodians and registered agents, which may be based anywhere in the world. Information will be used only for the purposes for which it is disclosed and will be retained by those service providers, and by us, for as long as may be necessary to fulfill these purposes or for a longer time if required by applicable law. To better service our investors and clients, we may combine information they give to us through various communications channels.

Our Investors and Clients.
We communicate with our investors and clients by mail, overnight service, telephone, fax and e-mail. We use these communications to fulfill our obligations to our investors and clients under our agreements with them. Our use of these communications reflects any consents our investors and clients may have given in those agreements. We reserve the right to use any of these means to send to them information relating to their account, including communications required by law.

Marketing Lists.
We do not sell, rent, or otherwise transfer lists of our investors and clients who are individuals to another party for the marketing purposes of that party. Sometimes we may create and transfer such lists of our investors and clients that are institutions for those purposes. We do not use Personal Information about investors or clients to conduct market research. We use the names of investors and clients that are institutions in our presentations and as references, but only when we have their permission to do so.

Other Communications.
At times we may send information to investors and clients that does not concern their accounts. If investors and clients do not want to receive these communications from us, they may let us know by printing out, completing and returning the Reply Form or by using any one of the other methods listed under How to Reach Us. We will also include in each of these communications information on how investors and clients may opt out of receiving further communications of this type.

5. Releasing Personal Information:
We will protect the confidentiality of Personal Information. We do not sell, rent or give away Personal Information to anyone. We do not exchange Personal Information with anyone. We will release Personal Information about an investor or client only (1) to a person we believe to be them or their authorized representative, (2) to someone else if investor or client directs us to do so, (3) to a service provider, such as an accountant or another third party for the purposes of administering investor’s or client’s application or account, or (4) in the limited circumstances described below. We expect the service providers who receive Personal Information from us to comply with our privacy and information security standards.We reserve the right to disclose or report Personal Information when (1) we believe in good faith that reporting is required or permitted under law, (2) to cooperate with regulators or law enforcement authorities, (3) to perform necessary credit checks or collect or report debts owed to us, (4) to protect our rights or property or (5) upon reasonable request by the Investment Fund in which an investor have chosen to invest.

Applicable laws give people who are involved in lawsuits or other legal proceedings the right to require us to provide information to them. In such cases, we provide only the information that we are required or authorized to provide.

6. Access and Accuracy:
We will provide investor and clients with access to their Personal Information, and we will work with them to keep their Personal Information accurate. Investors and clients may let us know by using any of the methods listed under How to Reach Us (1) if they wish to access their Personal Information that we hold, (2) if they find an error in their Personal Information, or (3) if they need to make a change in their Personal Information. We will provide access or update our records promptly after hearing from them. Please allow approximately 10 business days for any information to be received or any changes to be made.

7. Security:
We maintain safeguards to protect Personal Information. We employ physical, electronic and procedural safeguards to help protect Personal Information. Personal Information about investors and clients is normally used only by those employees of M&P who need to know it in order to provide services to the investor or client. We require all employees not to use or disclose Personal Information except for our business purposes, and we require employees to safeguard such information. Any employee who violates these requirements or our Privacy Policy will be subject to discipline.When we share Personal Information with our service providers, we expect them (1) not to use such information for their own purposes, (2) to keep such information confidential, and (3) to retain such information no longer than is necessary to provide the product, service, or information.We employ user authentication systems (such as passwords) and access control mechanisms to secure access to our computer systems and files. We employ isolation equipment for our Internet-based systems. Please note that our communications by e-mail are not encrypted.Any investor or client who becomes aware of any suspicious activity regarding his or her account should let us know immediately.

8. Cookies:
This Web Site does not use cookies or any similar technology, such as “clear gifs,” “web beacons” or “web bugs.” A cookie is a small file that is sent to your computer by a web site’s server. A cookie can be a record of your visit to a site, including information such as your User Name, registration information, time of last visit, and pages viewed.

REPLY FORM