MJL Capital Management firmly believes that investors are entitled to the very best service it can offer – and that includes the right to feel comfortable about the personal non-public information investors share with us.

In the normal course of business, investors give MJL Capital Management personal non-public information. MJL Capital Management uses this information to manage each investor’s account, direct transactions and provide each investor with valuable information. MJL Capital Management may collect this information through forms, interviews, transaction history of an investor’s account, or third parties. The information includes each investor’s name, address, telephone number, social security number, transactional and financial information, as well as other personal non-public information MJL Capital Management may need to service an investor’s account. MJL Capital Management maintains physical, electronic and procedural safeguards that comply with federal standards to protect confidentiality.

MJL Capital Management does not provide customer names and addresses, or other non-public information, to outside firms, organizations or individuals, except as necessary to service investor accounts or as permitted by law. For example, in the course of regular business, MJL Capital Management may share relevant information with service providers that support MJL Capital Management in servicing investor accounts. These companies may use this information only for the services for which they are hired, and are not permitted to use or share this information for any other purpose.

MJL Capital Management requires service providers to maintain policies and procedures designed to assure that access to non-public personal information about investors is restricted to employees who need to know that information in order to provide products or services to those investors, and that the use of such information is limited to the purposes for which it was disclosed or as otherwise permitted by law. MJL Capital Management also requires that service providers maintain strict physical, electronic and procedural safeguards designed to protect the personal information of investors that comply with federal standards.

MJL Capital Management will continue to adhere to the privacy policies and practices described herein with respect to information about former investors who have closed their accounts with MJL Capital Management.