Your privacy is very important to us. This Privacy Notice sets
forth the policies of Sterling Stamos Capital Management, L.P.
(the "Firm") and its affiliated entities,
including the private funds and managed accounts whose investment
portfolios the Firm manages (each a "Fund" and collectively,
the "Funds") and the general partner(s) of such Funds (the
"General Partner") with respect to non-public personal
information of current, prospective and former investors
(collectively, "Investors"). These policies apply to
investors in each of our Funds and other managed account clients
and may be changed at any time, provided a notice of such change
is given to you.
You provide us with personal information, such as your address,
social security number, assets and/or income information,
(i) in the Subscription Agreement and related documents,
(ii) in investment management agreements,
(iii) in correspondence and conversations with the Funds' representatives and
(iv) through transactions in the Funds.
We do not disclose any of this non-public personal information about our
Investors or managed account clients to anyone, other than to our affiliates,
such as the General Partner and except as permitted by law, such
as to our attorneys, auditors, brokers and regulators and certain
service providers, in such case, only as necessary to facilitate the
acceptance and management of our relationship with you.
Thus, it may be necessary, under anti-money laundering and similar laws,
to disclose information about Investors or managed account clients
in order to accept subscriptions from them. We will also release
information about you if you direct us to do so, if compelled to do
so by law, or in connection with any government or self-regulatory
organization request or investigation.
The Investor acknowledges that under Delaware law, other Investors in
certain of the Funds may be entitled to review the books and records
of the Funds and are entitled to see a list of Investors and their
Capital Commitments and Capital Contributions. The Investor
explicitly consents to disclosure of the fact of his or her
investment in such Funds, his or her mailing address and his or
her Capital Commitment/Capital Contribution to other Investors in such Funds.
We may also disclose information you provide to us to companies that
perform marketing services on our behalf, such as a distribution
or placement agent that we may use from time to time.
If such a disclosure is made, the Firm will require such
third parties to treat your private information with confidentiality.
We seek to carefully safeguard your private information and, to that end,
restrict access to non-public personal information about you to those
employees and other persons who need to know the information to enable
us and the Funds to provide services to you. We maintain physical, electronic
and procedural safeguards to protect your non-public personal information.