Granville Capital, Inc. is committed to protecting the security and confidentiality of the personal information of our clients, including the beneficial owners of the investment funds for which we serve as general partner and/or investment manager.  We provide you with this notice to inform you about our policies with respect to personal client information.

• We collect nonpublic personal information about you from subscription agreements and other written, telephonic or electronic communications with you or your representatives.  This information may include, for example, your name, address, telephone number and tax identification number and information about your net worth, annual income, investments and investment experience.  We do not obtain nonpublic personal information about you from other sources.



• We use personal information to provide you investment advice, to keep you informed about the performance and suitability of your investments and to respond to your requests.



• We do not sell personal client information to anyone.



• We maintain physical, electronic and procedural safeguards to protect the confidentiality and security of personal client information.  Our directors, officers and employees have access to personal client information only for business purposes and only on a need-to-know basis.  All directors, officers and employees are trained to safeguard personal client information and to protect against unauthorized access, use or disclosure.  Third parties who provide services to us are required to adhere to our privacy policies and are contractually obligated to maintain strict confidentiality.  Under no circumstances are third-party service providers permitted to use personal client information for their own purposes.



• We do not disclose personal client information to unaffiliated third parties unless disclosure is required or permitted by law.  For example, we may disclose or report personal client information in limited circumstances where we believe in good faith that disclosure is required or permitted under law and is necessary to cooperate with regulators or law enforcement authorities or to establish the eligibility of our clients to participate in certain investments.



• We make every effort to keep your personal client information accurate and up-to-date.  If you identify any inaccuracies in your personal information, or if you need to make a change to that information, please contact us so that we may promptly update our records.



• We will provide notice of any changes in our privacy policies.  For example, if at any time in the future, we decide to share any of your personal client information in a way that is inconsistent with this notice, we will notify you in advance of the proposed change.



• Even if you are no longer a client of Granville Capital, Inc., we will continue to adhere to the privacy policies described in this notice.