Privacy Policy

Pinnacle is committed to protecting your privacy and maintaining the security of your personal information.  This Privacy Policy explains the manner in which Pinnacle collects, utilizes and maintains nonpublic personal information about the investors in the clients for which it provides an administrative service (“Investors”), as required under applicable law.  This Privacy Policy only applies to products and services provided by Pinnacle to individuals (including regarding investments in any Funds that Pinnacle administers) and which are used for personal, family or household purposes (not business purposes).

Collection of Investor Information

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

1. Subscription forms, investor questionnaires, account forms and other information provided by the Investors in writing, in person, by telephone, electronically or by any other means.  This information includes name, address, date of birth, nationality, identification documents and numbers (such as passport, driving license, social insurance etc.) employment information and financial and investment qualifications;

2. Transactions within each Fund, including account balances, investments, withdrawals/redemptions and fees; or

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

Disclosure of Nonpublic Personal Information

Pinnacle may share nonpublic personal information about its Investors or potential Investors with affiliates as permitted by law.  Pinnacle 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, the Investor’s account or a Fund).

Pinnacle 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), law suits, claims or other liabilities;

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

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

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

Former Customers and Investors

The same Privacy Policy applies to former Investors.

Protection of Investor Information

Pinnacle maintains physical, electronic and procedural safeguards that comply with applicable standards to protect customer information.  Pinnacle 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.

Communication

Pinnacle has openly made available this Privacy Policy to employees and regularly gives training to employees and informs them of any changes in its policies and practices. Investors and clients are provided a copy of this Privacy Policy upon request.

Accessing and Updating the Personal Information

Investors or their authorized representatives are provided with the summary of their personal information under the control of Pinnacle upon request.

Further Information

Pinnacle 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 current federal law regarding privacy.  You may have additional rights under other foreign or domestic laws that may apply to you.