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US Privacy Notice

Gresham Investment Management LLC regards the protection of your privacy as an important responsibility. In this document, "we", "us" and "our" refers to Gresham Investment Management LLC ("Gresham"), a fund or account managed or advised by Gresham (the "Fund") and its or their affiliates and/or delegates.

To provide you with individualized service, we collect certain nonpublic personal information about you from information you provide to us during the due diligence and/or subscription processes (such as your address and social security number), and information about your account transactions with us (such as purchases, sales, and account balances). We may also collect such information through your account inquiries by email, telephone, mail, or client portal. This privacy notice should not be construed as establishing a contractual relationship.

We do not disclose any nonpublic personal information about you to anyone, except as permitted by law. So that we may continue to offer you Gresham’s products and services that best meet your investing needs, and to effect transactions that you request or authorize, we may disclose the information we collect, as described above, to companies that perform administrative or marketing services on our behalf (such as administrators to our private funds or third party placement agents that we hire to sell our products). These companies will use this information only for the services for which we hired them, and are not permitted to use or share this information for any other purpose.

If you decide at some point to redeem your investment with Gresham, we will continue to adhere to the privacy policies and practices described in this notice.

With regard to our internal security procedures, we restrict access to your personal and account information to those employees who need to know that information to service your account. We maintain physical, electronic and procedural safeguards to protect your nonpublic personal information.

If you have any questions about this notice, please contact investorrelations@greshamllc.com.

If you are a natural person who is resident in the European Union and/or the UK who is any of the following: an investor or prospective investor in any fund or account managed or advised by Gresham, a member, distributor, sales representative, business affiliate, or other representative of any client or prospective client of Gresham, a business contact working with service providers and vendors, or an individual on a Gresham mailing list whose personal information Gresham collects, controls and processes in the conduct of its business, please click here to view Gresham’s GDPR privacy notice.

For information on our use of personal data in accordance with the Data Protection Law of the Cayman Islands, please click here to view Gresham’s Cayman privacy notice.

For information on our use of personal data in accordance with the California Consumer Privacy Act, please click here to view Gresham’s Privacy Notice for Individuals Residing in California.

For individuals located in Brazil, please visit the following link: Privacy notice for Individuals Located in Brazil

Use of Cookies (all jurisdictions)

We use cookies on our website to provide you with a better user experience when you browse our website. Using cookies also enables us to improve our website.

A cookie is a small text file that we store on the browser or the hard drive of your desktop, tablet, or smartphone when you first visit our website. The cookie helps our website, recognize your desktop, tablet, or smartphone the next time you visit. A cookie can contain personal information.

Cookies may be required to operate our website, allow us to recognize and count the number of visitors and to see how visitors move around our website which may help us improve the design of our website. Cookies may also recognize you when you return to our website, enabling us to personalize our content and remember your preferences, and may be used to record your visit to our website, the pages you visited and the links you followed. We may use this information to provide you with targeted advertising and content we think may interest you. In some cases, we may use information from third party cookies to help us with market research or improving the design of our website (for example, allowing us to determine where traffic to our website comes from).

If you wish to manage your cookies preferences visit .