Privacy Notice

This notice describes the Privacy Policy of BANCARIBE CAPITAL LLC (“BANCARIBE”), how we handle and protect personal information that is received about our prospective, current, or former clients. BANCARIBE collects personal information primarily to provide investment management services, communicate information about its products and services and process subscriptions in private investment vehicles that it may advise or sub-advice. Personal information, which may be obtained from discussions with you and documents you may deliver BANCARIBE, may include your name, address, telephone number, social security number or tax identification number, assets, net worth, income, bank account information and occupation (collectively, “Personal Information”).

BANCARIBE permits only authorized individuals, who have been advised as to the proper handling of investor information, and who need to access this information to perform services, to have access to this information. These authorized individuals are required to maintain and protect the confidentiality of Personal Information. BANCARIBE maintains physical, electronic and procedural safeguards to protect Personal Information.

In order to service your investments and process transactions for your investments, BANCARIBE may provide Personal Information to its affiliates and to non-affiliated third-party financial service providers that assist BANCARIBE in servicing your investments and have a need for such information, such as a broker-dealer, administrator, or registrar and transfer agent. In addition, BANCARIBE may share Personal Information with non-affiliated third-party non-financial service providers, in order to process or service transactions or products. Unaffiliated third parties in this instance may include service providers such as word processors and printers. Any such contract entered into by BANCARIBE will include provisions designed to ensure that the third-party will uphold and maintain BANCARIBE privacy standards when handling Personal Information. BANCARIBE may also disclose Personal Information to regulatory authorities as required or permitted by applicable law. BANCARIBE does not otherwise provide information about you to outside firms, organizations or individuals except at your request or to our attorneys, accountants and auditors and as permitted by law.

Except as described in this Privacy Notice, BANCARIBE will not use Personal Information for any other purpose unless BANCARIBE describes in advance how such Personal Information will be used and you are given an opportunity to decline approval of such use of your Personal Information.