COGENTHEDGE PRIVACY POLICY

Cogent Alternative Strategies, Inc., CogentHedge.com and Cogent Investment Research LLC (collectively, CogentHedge) are committed to protecting your privacy and maintaining the confidentiality and security of your personal information. This Privacy Policy explains the manner in which CogentHedge collects, utilizes and maintains nonpublic personal information about its customers, consumers and users, as required under U.S. federal law. This Privacy Policy only applies to products and services provided by CogentHedge to individuals and which are used for personal, family, or household purposes.

Collection of Customer Information

CogentHedge collects personal information about you from (i) your questionnaires, account forms and other information provided by you electronically, in writing, by telephone, in person or by any other means (this information includes name, address, employment information and financial and other information); (ii) your activity on this web site and transactional activity in your accounts, including account balances, investments, withdrawals and fees/commissions; and (iii) other interactions with CogentHedge (for example, discussions with our staff).

Disclosure of Nonpublic Personal Information

CogentHedge may share nonpublic personal information about you with its affiliates, as permitted by law. CogentHedge does not disclose nonpublic personal information about you to nonaffiliated third parties, except as permitted by law (for example, to service providers who provide services to you or your account).

CogentHedge may share nonpublic personal information, without your consent, with affiliated and nonaffiliated parties in the following situations, among others: (i) to respond to a subpoena or court order, judicial process or regulatory inquiry; (ii) in connection with a proposed or actual sale, merger, or transfer of all or a portion of its business; (iii) to protect or defend against fraud, unauthorized transactions (such as money laundering), law suits, claims or other liabilities; (iv) to service providers of CogentHedge in connection with the administration and operations of CogentHedge’s products and services, which may include brokers, attorneys, accountants, auditors, administrators and other professionals; (v) to assist CogentHedge in offering CogentHedge-affiliated products and services to you; and (vi) to process or complete transactions requested by you.

Protection of Customer Information

CogentHedge will maintain the security and confidentiality of your records and information, protect against any anticipated threats or hazards to the security or integrity of your records and information, and protect against unauthorized access to or use of your records or information that could result in substantial harm or inconvenience to you. Therefore, it is the policy of CogentHedge (i) to restrict access to nonpublic personal information about you to those who need to know that information to provide products and services to you; (ii) to maintain physical, electronic, and procedural safeguards that comply with U.S. federal standards to guard nonpublic personal information about you; (iii) to share nonpublic personal information about you with its affiliates, subject to you expressly prohibiting such sharing; (iv) not to share nonpublic personal information about you with nonaffiliated third parties other than as permitted by law or unless otherwise authorized to do so by you.

Further Information

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