A. Privacy Regulation
The SEC’s Regulation S-P (Privacy of Consumer Financial Information, herein after the “Privacy Rules”), which was adopted to comply with Section504 of the Gramm-Leach-Bliley Act, requires investment advisers to disclose to their investors the Firm’s policies and procedures regarding the use and safekeeping of investor records (“Privacy Notice”). Among other requirements, the Privacy Rules require financial institutions to send initial Privacy Notices to “consumers”, send Privacy Notices to “customers” upon material change, and provide both customers and consumers the opportunity to opt out of the disclosure of any non-public personal information about a consumer to a nonaffiliated third party. For purposes of this Policy, “consumers” are potential and current investors in the Funds and “customers” are the Funds’ current investors.
B. Collection of Investor Information
The Firm collects personal and/or confidential information about investors mainly through the following sources:·Subscription documents, investor questionnaires 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, tax identification number and financial and investment qualifications.·Transactions within the Firm, including account balances, investments and redemptions.
C. Disclosure of Nonpublic Personal Information
DTA does not sell or rent Investor Information. DTA does not disclose Investor Information to nonaffiliated third parties or to affiliated entities, except as permitted by law. For example, the Firm may share Investor Information in the following situations:·To service providers in connection with the administration and servicing of the Firm, including attorneys, accountants, auditors, and other professionals. The Firm may also share information in connection with the servicing or processing of Firm transactions.·To respond to a subpoena or court order, judicial process or regulatory authorities.·To protect against fraud, unauthorized transactions (such as money laundering), claims or other liabilities.·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.
D. Protection of Investor Information
E. Location and Maintenance of Investor Information
All Investor Information is retained in accordance with the Firm’s “Record Retention Policy, ”as set forth in this Manual. The CCO ensures the security of the Firm’s Investor Information by keeping all Investor Information only in a secure location with limited access designated by the CCO. In the case of all such Investor Information, limited access will be granted to only those Employees who require such information in the course of their specific job responsibilities. If an Employee requires access to Investor Information, they must receive approval from the Firm’s CCO, who will determine if such access will be approved, and if so, the level of access allowed thereto.
F. Initial Privacy Notices
G. Distribution of Privacy Notices.
H. State Privacy Laws
Certain states have adopted privacy regulations that may be applicable to advisers with investors who are residents of those states. To ensure compliance with state privacy requirements, the CCO will periodically review such laws and evaluate whether the Firm’s procedures and controls are sufficient in light of the review. To the extent necessary, the Firm will revise its procedures and institute additional controls in order to comply with applicable state privacy laws