Privacy Policies

Table of Contents
Edgestream Privacy Policy

Edgestream Partners, L.P. (the “Firm”) and the pooled investment vehicles it advises (each, a “Client” or “Fund” and collectively the “Clients” or “Funds”) provide current and prospective clients and investors with the following information about their privacy policies for protecting the personal information of their current, former and prospective clients and investors.

The Fund, the Firm and the Funds’ administrator (the “Administrator”) collect personal information (which includes public and non-public personal information), such as name, address, social security number, birth date, assets, income and investment experience, about current, former and prospective clients and investors. This information is compiled from: (i) subscription documents and related forms and agreements completed by such persons; (ii) transactions between such persons and the Firm or the Fund ( e.g. , account activity and balances); and (iii) other third-party sources ( e.g., credit reporting agencies).

Personal information is not shared with any unaffiliated third parties for their marketing purposes. The Fund and the Firm will use, disclose and otherwise process personal information for their business, administrative, and marketing purposes. The Fund, the Firm and the Administrator also may reveal personal information in their possession about the Fund, including but not limited to all investor details, to their regulators and appropriate government agencies, as necessary and permissible under applicable laws, in connection with legal proceedings, or otherwise to assert and protect their legal interests or as part of a corporate transaction with a successor or affiliate. The Fund, the Firm and the Administrator restrict access to such personal information to their personnel, their affiliates and affiliates’ personnel, their service providers, and their outside counsel, auditors, and other independent professionals who need to know that information. To improve services and for security and the other purposes of the Fund as described herein, the Firm and the Administrator may also monitor or record telephone calls or electronic communications involving the Firm, the Fund or the Administrator.

The Fund and the Firm maintain, and the Administrator has represented that it maintains, appropriate administrative, technical, and organizational controls to safeguard such personal information, although such safeguards may not prevent all breaches of information security. If the security of personal information is compromised, the affected individuals will receive notice of the data security incident where required by and consistent with applicable law.

Individuals may exercise their rights under applicable law to access such personal information as is held by the Firm or the Fund, to rectify or delete any personal information which is factually incorrect, incomplete or irrelevant for the purpose for which it is processed and to raise any queries or concerns as to the use of their personal information, including making a request not to receive marketing materials, by contacting the Firm or the Fund.

In order to use and disclose such personal information for the purposes described above, such personal information may be transferred internationally to countries which the European Union has deemed not to provide adequate‖ data protection. Current, former and prospective clients and investors recognize the necessity of such international processing of personal information and consent to such international transfers of personal information, including social security and taxpayer identification numbers, as the Fund, the Firm or the Administrator deems appropriate. The Fund and the Firm will ensure, and the Administrator has represented that it will ensure, application of the same standards of privacy protection as set out in this privacy policy regardless of the country in which such personal information is processed.

If, at any time in the future, it is necessary to disclose any investor’s personal information in a way that is materially inconsistent with this policy, the Fund, the Firm and the Administrator will give such investor written notice of the change and, where required under applicable law, obtain consent to such change.

June 2020

California Privacy Policy

California enacted the California Consumer Privacy Act ( CCPA ”) in 2018, and it is effective beginning in 2020. The CCPA imposes certain obligations on Edgestream Partners, L.P. and its affiliates (“ Edgestream , ” “ we ,” or “ us ”) and grants certain rights to California residents (“ you ” or “ your ”) with regard to “personal information.” If you are a California resident, please review the following information about your potential rights with regard to your “personal information ” under the CCPA. The rights described in this Supplement are subject to exemptions and other limitations under applicable law.

Terms used in this Supplement have the meanings ascribed to them in the CCPA. Edgestream is a “business.” “Personal information” under the CCPA means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a California resident or a household. It does not include de-identified information, aggregate consumer information or publicly available information, as those terms are defined in the CCPA.

Purposes for Collecting and Using Personal Information

Edgestream may collect or use your personal information for the following business or commercial purposes:

  • Performing Service Individuals may exercise their rights under applicable law to access such personal information as is held by the Firm or the Fund, to rectify or delete any personal information which is factually incorrect, incomplete or irrelevant for the purpose for which it is processed and to raise any queries or concerns as to the use of their personal information, including making a request not to receive marketing materials, by contacting the Firm or the Fund. In order to use and disclose such personal information for the purposes described above, such personal information may be transferred internationally to countries which the European Union has deemed not to provide adequate‖ data protection. Current, former and prospective clients and investors recognize the necessity of such international processing of personal information and consent to such international transfers of personal information, including social security and taxpayer identification numbers, as the Fund, the Firm or the Administrator deems appropriate. The Fund and the Firm will ensure, and the Administrator has represented that it will ensure, application of the same standards of privacy protection as set out in this privacy policy regardless of the country in which such personal information is processed. If, at any time in the future, it is necessary to disclose any investor’s personal information in a way that is materially inconsistent with this policy, the Fund, the Firm and the Administrator will give such investor written notice of the change and, where required under applicable law, obtain consent to such change. June 2020s on behalf of the funds managed by us (the “ Funds ”), including maintaining or servicing accounts, providing investor relations services, processing subscriptions, withdrawals/redemptions, verifying information, processing payments, or providing similar services.
  • Performing our contractual obligations to a California resident as a subscriber to the Funds, including providing updates on the Funds’ performance, providing tax reporting, and other operational matters.
  • Detecting security incidents and protecting against malicious, deceptive, fraudulent, or illegal activity, including preventing fraud and conducting “Know Your Client” anti-money laundering, terrorist financing, and conflict checks.
  • Enabling or effecting commercial transactions, including using bank account details to remit funds and process distributions.

Personal Information Edgestream Collects

In the prior 12 months, Edgestream may have collected the following categories of personal information from or about a California Resident:

  • Identifiers and similar information such as name, address, date of birth, email address, social security number, driver’s license number, passport number, online identifiers or other similar identifiers.
  • Certain information protected under federal or state laws such as a signature or bank account or other financial information.
  • Characteristics of protected classifications under federal or certain state laws, including gender, national origin, or marital status.
  • Commercial information, including records of products or services purchased, obtained, or considered, or other purchasing histories or tendencies, including funds invested, investments considered, or sources of wealth.
  • Internet or other electronic network activity information, including interactions with Edgestream’s website or use of certain online tools.
  • Professional or employment-related information, including occupation, compensation, employer, and title.
  • Inferences drawn from any of the information identified above to create a profile reflecting your preferences or similar information, including your potential interest in investing in new funds.

In the preceding 12 months, Edgestream may have disclosed for a business purpose all or just a few of the above categories of personal information.

Sources of Personal Information

Edgestream may collect personal information about you directly from you and/or your intermediaries through sources such as: (i) account applications, subscription agreements, and other forms or related documentation; (ii) written, electronic, or verbal correspondence with us or our service providers; (iii) investor transactions; (iv) an investor’s brokerage or financial advisory firm, financial advisor, or consultant; and/or (v) from information captured on applicable websites. In addition, Edgestream may collect personal information from different sources, such as: (i) our affiliates, our service providers, or our affiliates’ service providers; (ii) public websites or other publicly accessible directories and sources, including bankruptcy registers, tax authorities, governmental agencies and departments, and regulatory authorities; and/or (iii) from credit reporting agencies, sanctions screening databases, or from sources designed to detect and prevent fraud.

Sharing Personal Information with Third Parties

Edgestream does not sell your personal information. Edgestream may disclose personal information to third parties in circumstances where Edgestream believes in good faith that disclosure is required or permitted under law, to cooperate with regulators or law enforcement authorities, to protect our rights or property, or upon reasonable request by the fund in which you have invested. Edgestream also may disclose personal information about you or your accounts to a third party at your request or direction or with your consent.

Edgestream may disclose your personal information to our service providers, other entities that have agreed to limitations on the use of your personal information, and entities that fit within other exemptions or exceptions in or as otherwise permitted by the CCPA.

California Residents’ Rights under the CCPA

If your personal information is subject to the CCPA, you may have certain rights concerning that information, subject to applicable exemptions and limitations, including the right to: (i) b e informed, at or before the point of collection, of the categories of personal information to be collected and the purposes for which the categories of personal information shall be used; (ii) not be discriminated against because you exercise any of your rights under the CCPA; (iii) request that we delete any personal information about you that we collected or maintained, subject to certain exceptions (“request to delete”); and (iv) request that we, as a business that collects personal information about you and that discloses your personal information for a business purpose, disclose to you (“request to know”): (a) the categories of personal information we have collected about you; (b) the categories of sources from which we have collected the personal information; (c) the business or commercial purpose for collecting the personal information; (d) the categories of third parties with which we share personal information; (e) the specific pieces of personal information we have collected about you; and (f) the categories of personal information we have disclosed about you for a business purpose.

The CCPA does not restrict Edgestream’s ability to do certain things like comply with other laws or comply with regulatory investigations. In addition, t he CCPA does not apply to certain information like personal information collected, processed or disclosed pursuant to the federal Gramm-Leach-Bliley Act and its implementing regulations. We also reserve the right to retain and not to delete certain personal information after receipt of a request to delete from you where permitted by the CCPA.

How to Submit a Request under the CCPA

You may submit a “request to know,” as described above, through the following telephone number: 609-681-2200 and ask for the Director, Product Management or the Chief Compliance Officer, or by sending an email request to or . You may submit a “request to delete” by sending an email request to or .

We are required to provide certain information or to delete personal information only in response to verifiable requests made by you or your legally authorized agent. Any information gathered as part of the verification process will be used for verification purposes only.

Contact for More Information

If you have any questions or concerns about this California privacy Supplement please email or .

June 2020