Privacy Practices

StableRiver Capital Management Web Privacy Statement

StableRiver Capital Management LLC ("StableRiver") its directors, officers and employees are strongly committed to protecting the online privacy of all clients and/or visitors. In accordance with the Privacy Act of 1974, the Gramm-Leach-Bliley Act and the Securities and Exchange Commission's Privacy of Consumer Financial Information Regulations (Regulation S-P), this web site uses standard encryption and password-protected protocols.

In the ordinary course of doing business, and in order to provide customized services and products, it may be necessary for StableRiver to procure certain [personal] information from clients and/or visitors to this web site. In addition, StableRiver may also periodically request other [personal] data in order to initiate and maintain accounts and relationships and to provide for supplemental products or services specifically tailored to meet its clients' and/or visitors' ongoing needs.

StableRiver is committed to ensuring the security of all [personal] information and as an integral part of its compliance program, StableRiver has designed its privacy control policies and procedures to prevent (to the extent possible) unauthorized disclosure and/or use of all such information. StableRiver does not generally make use of cookies or other web originated electronic forms of information tracking to procure personal information but it reserves the right to do so.

StableRiver will, to the best of its abilities, limit the sharing of any accumulated [personal] data to select business affiliates, partners, vendors and other parties authorized to act on its behalf and on behalf of its clients and/or visitors. All such groups and individuals will, of course, be bound by similar confidentiality agreements prior to StableRiver releasing any information. In addition, there are currently several states that require clients and visitors to provide "opt-in" permission for StableRiver to share any information. To the extent that StableRiver is made fully aware of the residency of such individuals, it will do its utmost to share any [personal] information with no other parties without consent. Currently, several states require firms to provide "opt-in" releases. Individuals should, therefore, provide StableRiver with a state of residence along with any initial contact information. StableRiver may not be held responsible in instances where the individual does not provide sufficient state of residency information. Everyone must realize however, that restricting StableRiver's ability to share information with certain parties may negatively impact its ability to perform its duties on behalf of those clients.

Occasions may arise wherein the StableRiver web site may include links to third party web sites. These transfers are provided solely as a convenience to clients and/or visitors and should not be construed as part of the StableRiver organization and StableRiver cannot guarantee or be held responsible for any [personal] information transported by the client through any such links. Although StableRiver makes every attempt to limit linking to reputable sites, StableRiver does not review or control other sites and makes no representation that those sites are competent, experienced or compliant with current industry and government regulations.

StableRiver reserves the right to change this statement at any time by posting revisions on the official StableRiver web site. Although StableRiver will make every attempt to prevent the unauthorized use of client and/or visitor information, it can make no guarantees. This privacy policy is not intended to, and does not create any contractual or other legal rights in or on behalf of any party.

For further information regarding StableRiver's Privacy Policies and Procedures and depending on the state of residency, to either "opt-in" or "opt-out," please contact StableRiver Capital Management LLC 50 Hurt Plaza, Atlanta, Georgia 30303, or at (404) 724-3409.

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