Privacy Policy

​The Advisor will collect personal information about its clients on applications and forms, and through different transactions that happen in the client’s investment and trading accounts. The Advisor will not share any information about the clients with anyone, except where permitted or required by law. At times, the Advisor may be required to furnish complete client records to regulators, legal counsel, courts of competent jurisdiction, or other entities as required by law. In addition, the Advisor may be required to furnish tax information to the Internal Revenue Service. The Advisor enters into agreements with external compliance/accounting firms to compile performance data for the Advisor’s Trading Program. The performance calculations are required to comply in accordance with CFTC Regulations and NFA Rules. The Advisor would provide client records (e.g., daily and month end commodity statements generated by the FCM) to the external compliance firm for purposes of compiling the performance data. The Advisor has obtained reasonable assurance that the external compliance firm will not share the clients’ information with third parties. However, a client is permitted to ‘opt’ out and may instruct the Advisor to not provide its daily and month end statements to the external compliance firm. The Advisor will not sell clients’ personal information to anyone, and no client will be permitted to review other clients’ records. The Advisor maintains physical, electronic, and procedural safeguards to protect clients’ nonpublic personal information.