As required under applicable federal law, this notice informs you of the privacy policies of Infinity Capital Partners, LLC (ICP) and its affiliated investment funds.

ICP does not disclose nonpublic personal information about its clients or former clients to third parties other than as set forth below. As you know, ICP obtains information about you in connection with the advisory/investment management services that ICP provides to you. This information may include your name, address, social security number, tax identification number, net worth, total assets, income and other financial information necessary to determine required accreditation standards (as well as financial sophistication). This information may be obtained through discussions, documentation (such as subscription agreements or advisory service agreements) and in the course of the advisory/investment management services ICP provides to you. ICP may use this information to provide advisory/investment management services to you, which can include the opening of accounts and other actions necessary to effect your advisory transactions. In connection with providing you with such services and effecting client transactions, ICP may provide your personal information to its affiliates and other firms that assist ICP in providing you with advisory/investment management services and effecting client transactions (such as fund administrators and compliance/operational support service providers). ICP may also provide such information to services providers and financial institutions with which the ICP has joint marketing relationships.

It should be noted, that ICP requires or will require all such external service providers and other financial institutions (that ICP discloses your personal information to) to protect the confidentiality of your personal information and to use such information only for the purposes for which it was disclosed to them. Except as noted above, ICP does not, and will not, provide nonpublic personal information about you to outside firms, organizations, groups or individuals except to ICP’s attorneys, accountants and auditors and as required or permitted by law.

ICP restricts access to nonpublic personal information about you to its employees who need to know such information to provide advisory/investment management or administrative services to you. ICP will maintain such safeguards that comply with federal standards to protect your nonpublic personal information.