Vexa Investment Management LLC ("Vexa") is committed to protecting your privacy and maintaining the confidentiality and security of your personal information. This Privacy Policy explains the manner in which Vexa collects, utilizes and maintains nonpublic personal information about its investors in accordance with the Gramm-Leach-Bliley Act (“GLBA”). “Vexa” collectively refers to Vexa Investment Management LLC and each investment account, partnership, limited liability company or fund (individually a “Fund,” and collectively, the “Funds”) for which Vexa Investment Management LLC serves as general partner, manager, managing member, director, trading manager and/or investment adviser. This Privacy Policy only applies to products and services provided by Vexa to individuals (including regarding investments in the Funds) and which are used for personal, family, or household purposes (not business purposes), or if required under the GLBA, those individuals’ legal representatives (collectively, the “Investors”).

Collection of Investor Information

Vexa collects personal information about its Investors from the following sources: 

1. Subscription forms, investor questionnaires, account forms, and other information provided by the Investor in writing, in person, by telephone, electronically or by any other means. This information includes name, address, nationality, employment information, and financial and investment qualifications; 

2. Transactions within the Fund, including account balances, investments, withdrawals and fees; and

3. Other interactions with Vexa (for example, discussions with our staff).

Vexa may share nonpublic personal information about its Investors or potential Investors with affiliates, as permitted by law. Vexa does not disclose nonpublic personal information about its Investors or potential Investors to nonaffiliated third parties, except as permitted by law (for example, to service providers who provide services to the Investor or the Investor’s account).

Vexa may share nonpublic personal information, without an Investor’s consent, with affiliated and nonaffiliated parties in the following situations, among others:

1. To respond to a subpoena or court order, judicial process or regulatory inquiry;

2. In connection with a proposed or actual sale, merger, or transfer of all or a portion of its business;

3. To protect or defend against fraud, unauthorized transactions (such as money laundering), lawsuits, claims or other liabilities;

4. To service providers of Vexa in connection with the administration and operations of Vexa, the Fund and other Vexa products and services, which may include brokers, attorneys, accountants, auditors, administrators or other professionals;

5. To assist Vexa in offering Vexa affiliated products and services to its Investors; and

6. To process or complete transactions requested by an Investor.

Vexa maintains physical, electronic and procedural safeguards that comply with federal standards to protect customer information. Vexa restricts access to the personal and account information of Investors to those employees who need to know that information in the course of their job responsibilities. Vexa will destroy, erase or make unreadable data, computer files and documents containing nonpublic personal information prior to disposal.

Further Information

Vexa reserves the right to change this Privacy Policy at any time. The examples contained within this Policy are illustrations and are not intended to be exclusive. This Policy complies with federal law regarding privacy. You may have additional rights under other foreign or domestic laws that may apply to you. If you have any questions about this Privacy Policy, please contact us.