Confidentiality of Personal Information

Spectrum Group Management LLC ("Spectrum") maintains the confidentiality of nonpublic personal information that a client provides. Spectrum maintains physical, electronic and procedural safeguards to guard a client's nonpublic personal information. All third parties that handle information must agree to follow the standards for confidentiality that Spectrum has established. In addition, all people who work for Spectrum are trained to handle a client's information properly in order to maintain its security, and only employees who need to know nonpublic personal information about a client to provide services to such client have access to such information.

Categories of Nonpublic Personal Information that Spectrum Collects

Spectrum collects nonpublic personal information about clients from the following sources: (i) information it receive from clients on applications or other forms; and (ii) information about clients' transactions with Spectrum or others.

Disclosure of Nonpublic Personal Information to Non-Affiliates

Spectrum does not sell or market a client's personal information to nonaffiliated third parties. Spectrum's intent is to respect the clients' expectations that their personal information will be kept confidential. However, in order to serve the clients better, Spectrum will disclose personal information to nonaffiliated third parties (including service providers to Spectrum), but only to the extent necessary or appropriate for such third parties to perform services for the benefit of the client and only if Spectrum believes that such personal information will be kept confidential by such third parties after such disclosure.

Additional Information About Categories of Nonpublic Personal Information that Spectrum Discloses

Except as required by applicable law and described in this privacy notice, Spectrum will not share any other nonpublic personal information about a client with its affiliates or nonaffiliated third parties.

Nonpublic Personal Information of Former Investors

This privacy notice and Spectrum's policy regarding treatment of nonpublic personal information of clients also apply to former clients.

Changes to Privacy Policy

Spectrum may modify its privacy policy at any time.