Privacy Policy

MANTEIO CAPITAL Asset Management, LLC and the investment companies that are advised by MANTEIO CAPITAL Asset Management, LLC (collectively the "Funds" or "we") consider privacy to be fundamental to our relationship with our investors. We are committed to maintaining the confidentiality, integrity and security of our current and former investors' non-public information. Accordingly, we have developed internal policies to protect confidentiality while allowing investors' needs to be met.

We respect your right to privacy. We also know, however, that you expect us to conduct our investment program in an accurate and efficient manner. To do so, we must collect and maintain certain non-public information about you and our other investors. This information may include your name, address, e-mail address, social security number, account number, assets, income, financial situation, transaction history and other personal information.

We may collect nonpublic information about your from the following sources including but not limited to:

Information we receive on applications, forms, questionnaires, websites, agreements or in the course of establishing or maintaining a customer relationship

Information about your transactions with us, our affiliates, or others

We will not disclose any non-public personal information about investors who are individuals, except to our affiliates and service providers as allowed or required by applicable law or regulation. However, in cases where we believe that additional products and services may be of interest to you, we may share the information described above with our affiliates. We also may share this information with companies that perform various services on our behalf, such as our accountants, auditors, attorneys, broker-dealers and fund administrators.

Any party that receives this information will use it only for the services required and as allowed by applicable law or regulation, and is not permitted to share or use this information for any other purpose. To protect the personal information of individuals, we permit access only by authorized employees who need access to that information to provide services to us and investors. In order to guard investors' non-public personal information, we maintain physical, electronic and procedural safeguards that comply with U.S. federal standards. An individual investor's right to privacy extends to all forms of contact with us, including telephone, written correspondence and electronic media, such as the Internet.

We note, however, that notwithstanding the foregoing, we reserve the right to disclose non-public personal information about investors to any person or entity, including without limitation any governmental agency, regulatory authority or self-regulatory organization having jurisdiction over us or our affiliates, if we determine in our discretion that such disclosure is necessary or appropriate pursuant to or in connection with any United States federal, state or local, or non U.S., law, rule, regulation, executive order or policy, including without limitation any anti-money laundering law and the USA PATRIOT Act of 2001.

Manteio Capital may process, disclose and transfer this information to its subsidiaries and affiliates outside the jurisdiction where you have your banking relationship with Manteio Capital, as well as to service providers performing services in connection with the operation of the site, who are bound by confidentiality agreements to protect such data, and as otherwise permitted or required by law. Information that Manteio Capital shares across national borders, including information from which third parties may conclude the existence of a banking relationship between you and particular Manteio Capital location, may no longer be covered by the banking secrecy, data protection or other confidentiality laws or regulations applicable in the jurisdiction of your banking relationship. It will be subject to the laws of the countries to which the information has been transferred and where it is held or processed, including those of the United States. Such foreign laws and regulations may offer different levels of confidentiality or data protection than those of the jurisdiction of your banking relationship, and may require Manteio Capital to disclose information to authorities or third parties. Manteio Capital does not sell this information to any non-affiliated companies.

This Statement is not intended to be incorporated in any offering materials but is merely a statement of our current Privacy Policy and may be amended from time to time. The date of the notice is February 28, 2011.