NOTICE OF PRIVACY POLICY & PRACTICES

Karya (as defined below) is committed to protecting your privacy and maintaining the confidentiality and security of your nonpublic personal information. This Privacy Policy explains the manner in which Karya collects, utilizes and maintains nonpublic personal information about its Investors (as defined below), as required by certain rules and regulations. “Karya” collectively refers to Karya Managing Member LLC (the “Managing Member”), Karya Capital Management LP (the “Investment Manager”) and each investment program, partnership, limited liability company or fund (each a “Fund” and collectively, the “Funds”) for which the Managing Member or Investment Manager serve as general partner, managing member, trading member, portfolio manager or investment manager. As noted above, this Privacy Policy only applies to products and services provided by Karya to individuals (including regarding investments in the Funds) and which are used for personal, family or household purposes and not business purposes (the “Investors”).

Collection of Investor Information

Karya collects nonpublic personal information about its Investors from the following sources:

  1. Subscription forms, investor questionnaires, account forms and other information provided by the Investors or their Representatives in writing, in person, by telephone, electronically or by any other means;
  2. Transactions within each Fund, including account balances, investments, withdrawals/redemptions and fees; or
  3. Other interactions with Karya (for example, discussions with our staff).

The type of nonpublic personal information that Karya may collect from the foregoing sources includes, but is not limited to, name, address, date of birth, nationality, social security number or tax identification number, employment information, financial and/or income information, and investment qualifications and information.

Disclosure of Nonpublic Personal Information

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

Karya may share nonpublic personal information with its affiliates without an Investor’s consent. In addition, Karya may share nonpublic personal information without an Investor’s consent with unaffiliated parties in the following situations, among others:

  1. To comply with federal, state or local laws, rules and other applicable legal requirements;
  2. To comply with a properly authorized civil, criminal or regulatory investigation or subpoena or summons by federal, state or local authorities;
  3. In connection with a proposed or actual sale, merger, or transfer of all or a portion of the business of the Fund in which you are invested;
  4. To protect against or prevent actual or potential fraud, unauthorized transactions (such as money laundering), claims or other liabilities;
  5. To service providers of the Fund in which you are invested in connection with the administration and operations of such Fund, which may include brokers, attorneys, accountants, auditors, administrators or other professionals;
  6. To process or complete transactions requested by an Investor; and
  7. Upon consent of an Investor to release such information, including authorization to disclose such information to persons acting in a fiduciary or representative capacity on behalf of the Investor.

Karya may also disclose nonpublic personal information to unaffiliated third parties that perform marketing services on its behalf, such as placement agents, for the purpose of calculating any amounts due to such placement agents. In such event, Karya will require the unaffiliated third party not to disclose such nonpublic personal information except to carry out the purposes for which Karya made the disclosure to the unaffiliated third party in the first instance.

Former Customers and Investors

The same Privacy Policy applies to former Investors.

Protection of Investor Information

Karya maintains physical, electronic and procedural safeguards that comply with applicable federal standards to protect customer information. Karya 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. Karya will destroy, erase or make unreadable data, computer files and documents containing nonpublic personal information prior to disposal.

Karya also maintains and implements a written information security program to protect Investors’ personal information. The program identifies risks to the confidentiality and security of records containing personal information, and has procedures for assessing the likelihood and potential damage of such threats. Technical, physical and administrative safeguards are in place for the protection of personal information, and are regularly monitored for effectiveness.

Further Information

Karya 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 Privacy 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 call us at (212) 201-1970.

Last Updated: April 1, 2017