Privacy Policy

In appointing IRON CAPITAL ADVISORS, hereafter referred to as “ICA”, as the investment manager of the account(s) for which you are the owner, custodian, or otherwise have investment authority with respect to securities, cash, and other property held therein, it is and has been necessary for you to provide ICA with financial information necessary to ensure that the account(s) is/are managed in a manner consistent with the investment objectives set forth by you and/or the institution for which you are acting as an agent. This information has been and generally will be derived from the following sources:

• Information ICA received from you on the Client Investment Questionnaire or other forms, and

• Information about your securities transactions with ICA and/or any of the third party money managers selected by ICA and managed by ICA.

It is the policy of ICA that we do not disclose any non-public, confidential or personal financial information regarding you, the institution for which you are acting as an agent, the membership of that institution and your institution’s account(s) to anyone, except as required by law. ICA provides access to any such information only to ICA employees who need such information in order to provide necessary services to you and/or your institution and its members.

ICA maintains electronic, physical and procedural safeguards to protect the privacy of your non-public, confidential or personal financial information.

If you decide to close your account(s) with ICA or become an inactive customer, ICA will adhere to the privacy policies and practices as described in this notice.