PRIVACY POLICY

Policy

Arcadia Funds’ policy is to ensure the privacy and security of Fund and limited partner records. Arcadia will comply with the procedures set forth below to the extent that they are applicable to Arcadia.

Background & Description

Client and limited partner information in the possession of an investment adviser is governed by federal law and, in some cases state law. The Gramm-Leach-Bliley Act (GLB) and Regulation S-P require financial institutions, including investment advisers, to provide a notice to each customer that describes the investment adviser's policies and practices regarding the disclosure to third parties of nonpublic personal information. In general, the privacy notice must describe an investment adviser's policies and practices with respect to disclosing nonpublic personal information about a Fund or limited partner to both affiliated and nonaffiliated third parties and provide a Fund or limited partner a reasonable opportunity to opt out of the sharing of nonpublic personal information about the Fund with nonaffiliated third parties. As part of its privacy notice, the privacy rule requires an investment adviser to include specific items of information, such as the categories of nonpublic personal information that the investment adviser collects and the categories of third parties to which the investment adviser may disclose the information.

Responsibility

The CCO is responsible for the implementation and monitoring of Arcadia’s Privacy Policy and Procedures, including associated practices, disclosures and recordkeeping. The CCO may delegate responsibility for the performance of these activities (provided it maintains records evidencing individual delegates) but oversight and ultimate responsibility remain with the CCO.

Procedure

Arcadia has adopted various procedures to implement the firm’s Privacy Policy and reviews to monitor and ensure that the firm’s policy is observed, implemented properly and amended or updated, as appropriate. The procedures are as follows:

These privacy procedures are designed to:
 

• Ensure the security and confidentiality of Fund and limited partner information;
   

• Protect against any anticipated threats or hazards to the security or integrity of Fund and limited partner records and other Fund and limited partner information; and
   

• Protect against unauthorized access to, or use of, Fund or limited partner information that could result in substantial harm or inconvenience to any Fund or limited partner.

Privacy Notice

The CCO on the behalf of Arcadia will maintain an updated privacy notice ("Privacy Notice") for the adviser and, the current versions of which is attached below. The Privacy Notices will describe:

• The categories of nonpublic personal information that Arcadia collects;
   

• The categories of nonpublic personal information that Arcadia discloses;
   

• The categories of affiliates and nonaffiliated third parties to whom Arcadia discloses nonpublic personal information, other than those parties to whom Arcadia discloses information under exceptions to notice and opt out requirements for processing and servicing transactions and certain other exceptions in Regulation S-P;
   

• The categories of nonpublic personal information about Arcadia's former Funds that it discloses and the categories of affiliates and nonaffiliated third parties to whom Arcadia discloses nonpublic personal information about its former Funds, other than those parties to whom Arcadia discloses information under exceptions to notice and opt out requirements for processing and servicing transactions and other exceptions in Regulation S-P;
   

• Whether Arcadia discloses information under exceptions to notice and opt out requirements for processing and servicing transactions and other exceptions in Regulation S-P; Arcadia Funds, LLC Compliance Manual 47
   

• If Arcadia discloses nonpublic personal information to a nonaffiliated third party under the exception to opt out requirements for service providers and joint marketing, the notice will contain a separate statement of the categories of information it discloses and the categories of third parties with whom it has contracted;
   

• An explanation of the consumer's right under Regulation S-P to opt out of the disclosure of nonpublic personal information to nonaffiliated third parties, including the method(s) by which the consumer may exercise that right at that time;
   

• Any disclosures that Arcadia makes under the Fair Credit Reporting Act (that is, notices regarding the ability to opt out of disclosures of information among affiliates); and
   

• Arcadia's policies and practices with respect to protecting the confidentiality and security of nonpublic personal information.

Privacy Notice Delivery

A copy of the Arcadia’s or the Fund’s Privacy Notice as applicable shall be provided to an individual who becomes a "customer" of Arcadia not later than when Arcadia establishes a customer relationship, or a "consumer," before Arcadia discloses any nonpublic personal information about the consumer to any nonaffiliated third party. This will include any private fund investor and separately managed account that meets the definition. Any changes to the Privacy Notice will be delivered to each customer.

Security Measures

The following securities measures will be implemented and maintained to protect the confidentiality of Fund and limited partner information:

Encryption and Identity Theft

Any e-mail being sent that has investor information included must be encrypted.

Arcadia will take other measures to prevent outsiders from gaining access to Funds' and limited partners’ personal information, including preventing outsiders from obtaining information under false pretenses. Arcadia will consider the use of passwords and other measures to ensure the correct identity of any person seeking information.

Physical Records

The CCO will cause Arcadia to implement physical safeguards to protect non-public personal information that is in hard copy. Such safeguards will be designed to protect physical records against destruction, loss, or damage due to potential environmental hazards, such as fire and water damage or technological failures.

Firewalls

Electronic files containing Fund and limited partner information will operate under a "lock out" system whereby passwords or some other form of verification will be required to access Fund or limited partner data. In addition:

• Passwords will be periodically changed;
   

• Internal systems will be put in place that are designed to ensure that only authorized Arcadia personnel can access the information contained in the system;
   

• Website servers (if any) used to gather and transmit personal data will be stored in secure and environmentally controlled locations; and
   

• Computer systems will be equipped to provide warnings of possible attacks or intrusions into information systems, accompanied by response mechanisms that take appropriate action when unauthorized access to protected information is suspected or detected.

Sharing Information With Third Parties

No nonpublic personal information of a Fund or limited partner may be provided to a nonaffiliated third-party service provider until the CCO has determined that there is a contractual agreement prohibiting the third party from disclosing or using the information other than to carry out the purposes for which the information is to be disclosed.

The CCO shall require, by contract, that each service provider implement appropriate measures designed to meet the objectives of these procedures and shall monitor its compliance therewith, and no service provider may be retained without the approval of the CCO.

Reports

The CCO shall report to the senior officers of Arcadia on the condition and status of the Privacy Procedures not less frequently than annually. Access Persons of Arcadia shall report any breaches or violations of these Privacy Procedures to the CCO.

ARCADIA FUNDS, LLC PRIVACY POLICY

To protect your privacy and provide our clients with a broad range of financial products and services as efficiently as possible, we use technology to manage and maintain client information. We want you to understand what information we collect and how we use it.

Information We Collect
We may collect personally identifiable information about you from the following sources:
 

• Information we receive from you on applications or other account forms;
   

• Information about your transactions with us, our affiliates or others;
   

• Information we receive from outside sources such as your financial consultant;
   

• Information obtained electronically, such as from our Website.

Information We Disclose

We do not disclose any confidential information about our clients or former clients to anyone, unless:

• such disclosure is required or permitted by law, statute or regulation;
   

• such disclosure to service or information providers is required in order to deliver our products and services to our clients. (e.g., custodians, transacting brokers, etc.)

For example, we use information to administer your accounts with us through such activities as sending you quarterly reports.

Our Security Procedures

We take steps to safeguard customer information. We restrict access to your personal and account information to those Covered Persons who need to know that information to provide products or services to you. We also maintain physical, electronic, and procedural safeguards that comply with federal standards to guard your nonpublic personal information.

Should you need any further information please feel free to contact Arcadia's Chief Compliance Officer at cco@arcadiafunds.com.

CIRRIX CAPITAL, LP NOTICE REGARDING PRIVACY OF FINANCIAL INFORMATION

We recognize and respect the privacy expectations of the investors in the Partnership and its affiliated funds. The following describes the kinds of information we collect about our investors and the circumstances in which that information may be disclosed to affiliated and non-affiliated third parties.

We collect nonpublic personal information about investors from the following sources:

• Subscription Documents, Investor Questionnaires and other forms, which may include an investor’s name, address, social security number and other personally identifiable financial information.
   

• Account History, including information about an investor’s capital account, such as capital contributions, profit and loss allocations and distributions and withdrawals with us and our affiliates.
   

• Transactions with us and our affiliates, including information we receive and maintain relating to securities transactions with and through us and our affiliates.
   

• Correspondence, written, telephonic or electronic, between an investor and us or any of our affiliates or service providers.

In addition to the sources listed above, we may also collect information about an investor from the investor’s websites.

Disclosure of Information

• As Authorized – if an investor requests or authorizes disclosure of the information.
   

• As Required by Law – to cooperate, for example, with regulators or law enforcement authorities.
   

• As Permitted By Law – for example, sharing information with companies that maintain, process or service customers accounts of financial products and services or who effect, administer or enforce customer transactions is permitted. Among other activities, we may share information with persons acting in a representative or fiduciary capacity on an investor’s behalf. We believe that sharing of information for these purposes is essential to providing investors with necessary or useful services with respect to their accounts.

Information Safeguarding Policy We restrict access to non-public personal information about investors to those of its employees and its agents who need to know the information to enable us to provide services to the investors. We maintain physical, electronic and procedural safeguards to guard investors’ nonpublic personal information selected.