Privacy Policy

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ACARA Capital Management, LLC

Privacy Policy:

ACARA Capital Management, LLC (ACARA) is committed to integrity and privacy. Trust is

foundational to customer relationships, and responsible handling of customer information is an

important aspect of that trust.

No Selling of Client Information

ACARA affirms that it does not sell any customer information to third parties. Trust is paramount, and ACARA respects the privacy of personal and financial data.

Collection of Data

ACARA may collect a variety of information necessary to provide financial services and for the

administration of its business. This includes data from application forms, telephone communications, the ACARA website, transaction details from customer accounts, custodial information shared with ACARA and from all other sources of information provided by customers.

Use of Information

The information collected by ACARA is used primarily for the following:

1) To assess the suitability of investment strategies and provide advice to customers.

2) To complete transactions at customers’ request or as authorized by them.

3) To group accounts for the efficient organization and management of customers’ assets.

4) To fulfil regulatory requirements as discussed below under “Legal and Regulatory Disclosures”.

5) To utilize the services of select third party service providers as discussed under “Service Provider Data Sharing”.

6) To market ACARA. ACARA uses aggregated and/or anonymized client data to provide prospective customers with insight into its business and the types of customers it serves. Common uses include but are not limited to the disclosure of assets under management, quantity of accounts, composite

performance, securities held, and other aggregated and/or anonymized data deemed useful to provide an accurate characterization of ACARA Capital Management, LLC.

Disclosure Practices

ACARA’s policy is to limit the disclose of non-public personal information about customers and

former customers to select third party service providers as discussed below and as required by law or regulation. ACARA believes that this policy is in line with its commitment to customers. This policy

endeavors to balance the safeguarding of customers’ private information with ACARA’s ability to provide efficient account management and meet regulatory obligations.

Legal and Regulatory Disclosures

ACARA may disclose non-public personal information to government agencies and regulatory organizations when required or permitted by law. This is part of ACARA’s obligation to comply with legal and regulatory standards. ACARA can’t make any representations as to the effectiveness of internal government controls with respect to data privacy.

Service Provider Data Sharing

Information may be shared with affiliated companies and select non-affiliated third-party service providers for marketing, trading, and administrative services. ACARA has entered contractual arrangements that require third party service providers to maintain the confidentiality of customer data. Types of non-public information shared with service providers include custodial account details, ACARA contract details, and customer contact data. ACARA’s third-party service providers are essential to the efficient operations of ACARA. Data sharing with service providers is a standard practice among registered investment advisers and ACARA discloses non-public information to non-affiliated third parties only as permitted by law. Although ACARA endeavors to work with reputable third-party service providers it can’t make any representations as to the effectiveness of third-party privacy controls.

Internal Safeguards

To help protect customers’ non-public information ACARA maintains physical, electronic, and procedural safeguards. Internally, permission to access personal information is limited to ACARA personnel responsible for the administration and management of customer accounts.

Conclusion

ACARA believes that it takes reasonable precautions to protect customers’ non-public information while providing desired services. ACARA does not disclose and does not reserve the right to disclose its customers’ non-public information except as discussed herein. As with all of data management there are inherent trade-offs between the confidentiality, availability, and integrity of data. ACARA endeavors to do the right thing for customers by striking a favorable balance on their behalf.