PRIVACY POLICY

Halo Investing does not disclose nonpublic personal information about its
clients or former clients to third parties other than as described below.
Halo Investing collects information about its clients (such as name, address,
social security number, assets and income) from the Firm’s discussions with
clients, from documents that clients may deliver to the Firm (such as
subscription documents) and in the course of providing services to clients.
In order to service clients’ accounts and effect investment transactions,
Halo Investing may provide clients’ personal information to the Firm’s
affiliates and to firms that assist Halo Investing in servicing client
accounts and have a need for such information, such as brokers, distributors,
legal counsel, fund administrators, or accountants. Halo Investing does not
otherwise provide information about clients to outside firms, organizations,
or individuals except as required or permitted by law. Any party that receives
this information will use it only for the services required and as allowed by
applicable law or regulation, and is not permitted to share or use this
information for any other purpose.