Privacy Policy

This Privacy Policy sets forth guidelines concerning how Cloverlay Partners Management Company, LLC (together with its subsidiaries and affiliates “Cloverlay”, “us”, “we” or “our”) gathers and uses information about your interaction with this website (the “Site”). This Privacy Policy concerns only this Site, and does not concern any website to which this Site may link.

What Does Cloverlay Do With Your Personal Information?
Financial companies choose how they share your personal information. Federal law gives our clients the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do. We do not disclose nonpublic personal information about our clients or former clients to third parties other than as described below.

Personal information we collect.
We collect personal information about you in connection with our providing advisory services to you. This information includes your social security number and may include other information such as your:

• Assets;
• Investment experience;
• Transaction history;
• Income; and
• Wire transfer instructions.

How we collect this information.
We collect this information from you through various means. For example when you give us your contact information, enter into an investment advisory contract with us, buy securities (i.e., interests in a fund) from us, tell us where to send money, or make a wire transfer. We also may collect your personal information from other sources, such as our affiliates or other non-affiliated companies.

How we use this information.
All financial companies need to share customers’ personal information to run their everyday business and we use the personal information we collect from you for our everyday business purposes. These purposes may include for example:

• To provide advisory services to you.
• To open an account for you.
• To process a transaction for your account.
• To market products and services to you.
• To respond to court orders and legal investigations.

Disclosure to others.
We may provide your personal information to our affiliates and to firms that assist us in servicing your account and have a need for such information, such as a broker or fund administrator. We may also disclose such information to service providers and financial institutions with whom we have joint marketing arrangements (i.e., a formal agreement between nonaffiliated financial companies that together market financial products or services to you, such as placement agents). We require third-party service providers and financial institutions with which we have joint marketing arrangements to protect the confidentiality of your information and to use the information only for the purposes for which we disclose the information to them. These sharing practices are consistent with Federal privacy and related laws, and in general, you may not limit our use of your personal information for these purposes under such laws. We note that the Federal privacy laws only give you the right to limit the certain types of information sharing that we do not engage in (e.g., sharing with our affiliates certain information relating to your transaction history or creditworthiness for their use in marketing to you, or sharing any personal information with non-affiliates for them to market to you).

How we protect your personal information.
To protect your personal information from unauthorized access and use, we use security measures that comply with Federal law. These measures include computer safeguards and secured files and buildings.

Who is providing this Privacy Notice?
This Privacy Notice relates to the following entities and their affiliates:

• Cloverlay Partners Management Company, LLC;
• Cloverlay Investment Management, LLC;

Who to contact with questions.
If you have any questions about this Privacy Notice, contact us at (484) 262-5020 or