Campbell believes that you are entitled to the best service Campbell can offer – and that includes the right to feel comfortable about the personal non-public information you share with Campbell.

In the normal course of business, you give Campbell non-public personal information. Campbell uses this information to manage your account, direct transactions and provide you with valuable information. Campbell may collect this information through forms, interviews, transaction history of your account, or third parties. The information includes your name, address, telephone number, social security number, transactional and financial information, as well as other personal non-public information Campbell may need to service your account. Campbell maintains physical, electronic, and procedural safeguards that comply with federal standards to protect confidentiality.

The personal non-public information you share with Campbell may be subject to privacy standards different from the standards applicable in the jurisdiction where you are domiciled. By doing business with Campbell you acknowledge and agree that Campbell or its respective agents may collect, process and store materials, data, information and content relating to your account (“Data”), and such Data may be transferred, disclosed, stored, processed and maintained by Campbell or its respective agents electronically on servers, or in hard copy or original format, in a number of different jurisdictions, including within the U.S.A., the Cayman Islands and/or any of the other jurisdictions where Campbell or its respective agents have a presence. In this regard, you will be required to explicitly consent to the transfer, and processing of all materials, Data, information and content relating to your account in and outside of any such jurisdictions. You well be further required to agree in the investment management agreement that you acknowledge and agree that Campbell or its respective agents may be obliged to retain such Data for a period of time after you are no longer a client, and may be requested, required, or compelled to disclose such Data to third parties.

Campbell does not provide client names and addresses, or other non-public information, to outside firms, organizations or individuals, except as necessary to service client accounts or as permitted by law. For example, in the course of regular business, your account may share relevant information with service providers that support Campbell in servicing your account. These companies may use this information only for the services for which they are hired, and are not permitted to use or share this information for any other purpose.

Campbell requires service providers to your account to maintain policies and procedures designed to assure that access to non-public personal information about you is restricted to employees who need to know that information in order to provide products or services to those your account, and that the use of such information is limited to the purposes for which it was disclosed or as otherwise permitted by law. Campbell also requires that service providers maintain strict physical, electronic and procedural safeguards designed to protect the personal information of your account that comply with federal standards.

Campbell will continue to adhere to the privacy policies and practices described herein with respect to information about former clients who have closed their accounts with Campbell.