Cadence Capital Management LLC

Privacy Notice

Clients, Prospective clients, Investors and related parties

• We do not sell information about you.

• We do not share your information with anyone for their marketing purposes.

• We only use your personal information to help maintain and grow the business relationship you have with us.

Privacy Notice to Our Clients, Prospective Clients, Investors and Related Parties

As our client, prospective client, or as an investor, you have entrusted us to help you achieve your unique financial life goals.  You may also be designated by a client, prospective client, or investor as a related party. We are providing this privacy notice to assist you in understanding the types of personal information we may collect, where we receive it, how we use it, and how we protect the privacy of the personal information you share with us.

What Personal Information Do We Collect, Where Do We Get It, and Why Do We Collect It?

Most of the personal information we collect is obtained from you, with your consent, or from one of our clients. We collect personal information needed to service and manage your relationship with us.  The type of information that we collect depends on the type of product or service you request, and includes:

• Information we receive from you on your investor questionnaire and subscription agreement or other forms (for example, name, address, social security number, wire transfer instructions or income);

• Information about your business relationship and history with us;

• Information about your transactions with us, our affiliates or others, such as capital account balances and parties to transactions.

• Information about you from third parties in order to verify your identity, and to prevent fraud.

The primary use of your information is to complete transactions requested by, or on behalf of, you and to provide certain required reporting to you concerning your account or investment in the private funds we advise. Cadence will provide you an updated notice if the types of personal information we collect, or use, is materially different, unrelated, or incompatible with this notice.

How Do We Use and Disclose Your Information?

We may share information within our corporate family to service and grow the business relationship we have with you.  Additionally, we may provide information to individuals and entities with whom you authorize us to share such information. If necessary, we disclose information when it is required by law. We may also disclose certain information to other entities to help us report or prevent fraud, including reports to regulatory or law enforcement agencies.

Cadence may disclose your personal information to a third party for a business purpose. This may include administrators, regulatory compliance consultants, attorneys, accountants and auditors in the course of running the day-to-day business of Cadence and as otherwise required or permitted by law. We may also provide your confidential information to other service providers, such as brokers, who may have a need for the information in connection with providing services to clients. When we disclose personal information for a business purpose, we require the recipient to keep that personal information confidential and not use it for any purpose except performing the service.  Categories of third parties that may be given access to your personal information include:

• Consultants and contractors (e.g., external auditors)

• Financial services professionals

• Software service providers

• Attorneys and other legal professionals

• Cloud service providers

• Regulatory agencies

• Third party administrators

Finally, we will release your nonpublic information if you direct us to do so, if we are required by law to do so or in other limited circumstances permitted by law – for example, to protect your account from fraud or to comply with anti-money laundering requirements.

What Happens If You Close Your Account?

If you decide to close your account(s), we will continue to follow the privacy policies described in this notice to the extent that we retain information about you. If we no longer need to retain that information, we will dispose of it in a secure manner.

How Do We Protect the Security of Your Information?

We have policies that maintain the physical, electronic, and procedural safeguards to protect the confidentiality of your personal information. Access to your personal information is limited to those who need to know it to help service our relationship with you.

Do You Need to Do Anything?

It is not necessary for you to take any action. This is because we do not share your information except to service and grow the business relationship you have with us. You do not need to “opt-out” or “opt-in” as you may have done with other financial companies because we do not sell your information.

You May Request Your Information

You may request what information Cadence has collected about you and its purpose.  We will provide a response once we receive and confirm your request.  Your request must provide sufficient information to allow us to reasonably verify your identity.  You do not need to create an account to request your information.  For more information about submitting a request, please use one of the following methods:

• Call us at 877-722-7848, or

• Visit [Link this URL]

You may request Cadence to delete personal information that we have collected and retained. Once we receive and confirm the request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. We will not discriminate against you for exercising any of your rights.

Residents of California

The information below supplements Our Privacy Promise and applies to residents of the State of California. The California Consumer Privacy Act of 2018 (CCPA) defines categories of personal information as the following:

Information Categories and Examples

Personal Identity, Financial, and Personal Health

·         Name

·         Alias

·         Address

·         Signature

·         Driver’s license

·         Email address

·         Social Security number

·         Medical information

·         Health insurance information

Protected Classification Characteristics

·         Race

·         Ancestry

·         Citizenship

·         Marital status

·         Medical condition

·         Physical or mental disability

·         Sex (including gender, gender identity)

Commercial Information

·         Personal property

·         Products or service purchased

Biometric Information

·         Genetic characteristics

·         Physiological characteristics

·         Biological characteristics

Internet or Other Similar Network Activity

·         Information on your interaction with our websites

Sensory Data – Audio, Electronic, Visual, Thermal, Olfactory or similar information

·         Voice Recordings

Professional or Employment-Related Information

·         Current or past job history

Inferences Drawn from Personal Information

·         Profile created by analyzing information provided (for example, underwriting analysis)

Pacific Life obtains the categories of personal information listed above from the following categories of sources:

• Directly from you

• Healthcare professional or firm

• Financial service professional or firm

• Publicly available records

• Third parties that are not healthcare professionals or financial services professionals (e.g., consumer reporting agency, credit reporting agency, staffing agency, companies that provide services to us)

• Family member, dependent or beneficiary

• Analytical technology (e.g., internet usage, cookies, or automated underwriting technology)

You may request Pacific Life to delete personal information that we have collected and retained. Once we receive and confirm the request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. We will not discriminate against you for exercising any of your rights.  Please see You May Request Your Information section above for more information on how to submit a deletion request.

Privacy Notice dated: December 20, 2019