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VENTURA CAPITAL MANAGEMENT, LLC

PRIVACY POLICY

You are entitled to know how we protect your nonpublic personal information and how we limit its disclosure.  This privacy policy applies to individuals who invest in any of our funds (or have done so in the past) or are otherwise an advisory client.  This privacy policy describes our policies and practices for collecting, disclosing, and safeguarding "nonpublic personal information", which may include financial or other information about you.

Information We Collect

We collect nonpublic personal information about you from the following sources:  

 - Information we receive from you on your investor questionnaire and subscription agreement or other forms.  This information includes, for example, your name, address, social security number, assets and income; and

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

Information We Disclose

We do not disclose your nonpublic personal information to anyone, except as permitted or required by law.  This means, most importantly, that we do not sell client information - whether it is your personal information or the fact that you are our client - to anyone.  Instead, we use your information primarily to complete transactions that you request.  For example:

         - To complete certain transactions or account changes that you request, it may be necessary to provide identifying information to non-affiliated third parties.  

 

In certain instances, we may contract with non-affiliated third parties to perform services for us and, where necessary, disclose your information (described above) to them.  In all such cases, we provide the third party with only the information necessary to carry out its assigned responsibilities and only for that purpose.  Further, we require these third parties to treat your nonpublic information confidentially. 

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. 

Who Has Access to Your Personal Information

We restrict access to your nonpublic information to those employees and third parties who need to know that information to provide products or services to you.  We maintain physical, electronic and procedural safeguards that comply with federal regulations to guard your nonpublic personal information. 

We Will Keep You Informed

This publication replaces all previous statements of our privacy policy.  As required by law, we will notify you annually of our privacy policy.  We reserve the right to modify this policy at any time and will keep you informed of changes.