Privacy Policy

KPC Terrapin Group LLC and Kelly Park Investment LLC (together, “KPC”) have adopted this policy in recognition that protecting the privacy and security of the personal information KPC obtains from its clients is an important responsibility.

KPC understands that its clients and prospective clients expect KPC to provide its services in an accurate and efficient manner. To do so, KPC must collect and maintain certain personal information about its clients. KPC wants its clients to know what information KPC collects and how KPC uses and safeguards that information.

What information the firm collects:

KPC collects certain nonpublic personal identifying information about its clients (such as the client’s name, address, social security number, etc.) from information that the client provides in account applications or other forms as well as communications (electronic, telephone, written or in person) with the client or the client’s authorized representatives (such as an attorney, accountant, etc.).

What information the firm discloses:

KPC does not disclose the nonpublic personal information KPC collects about its clients and prospective clients to anyone except: (i) in furtherance of KPC’s business relationship with them and then only to those persons necessary to effect the transactions and provide the services that they authorize (such as broker-dealers, custodians, independent managers etc.); (ii) to persons assessing Firm’s compliance with industry standards (e.g., professional licensing authorities, etc.); (iii) Firm’s attorneys, accountants and auditors; or (iv) as otherwise provided by law. KPC is permitted by law to disclose the nonpublic personal information about its clients to governmental agencies and other third parties in certain circumstances (such as third parties that perform administrative or marketing services on KPC’s behalf or for joint marketing programs). These third parties are prohibited from using or sharing the information for any other purpose. If a client decides at some point to terminate its advisory relationship with KPC, KPC will continue

to adhere to its privacy policy, as may be amended from time to time.

Security of client information:

KPC recognizes the need to prevent unauthorized access to the information collected, including information held in electronic format. KPC restricts access to client nonpublic personal information to those personnel who need to know that information to provide its services to the client. KPC maintains physical, electronic and procedural safeguards that comply with applicable federal or state standards to protect each client’s nonpublic personal information. Former clients can be assured that nonpublic personal information will continue to be treated according to KPC’s privacy policies and practices, as amended from time to time.

Limiting Sharing:

As KPC’s disclosure of clients’ nonpublic personal information is limited to sharing necessary to everyday business purposes, or as permitted or required by law, clients cannot further limit how we share your information. It is necessary for us to share certain nonpublic personal information in order to effectively manage your account.

Changes to the firm’s privacy policy or relationship with you:

KPC’s policy about obtaining and disclosing information may change from time to time. KPC will provide its clients with notice of any material change to this policy before KPC implements the change.

If you have any questions concerning any information in this privacy notice or how we collect, share or protect your information, please call 212-710-4111 or email investorrelations@kellyparkcapital.com.

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