Privacy Policy


Peloton Investments, LLC, on behalf of itself and the funds it manages (the "Company"), has adopted the following privacy policy in order of safeguard the personal information of the Company's clients in accordance with applicable law:

1. The Company is committed to protecting the confidentiality and security of the information it collects and will handle nonpublic personal information about clients only in accordance with all applicable laws rules and regulations. The Company shall ensure: (a) the security and confidentiality of client records and information; (b) that client records and information are protected from any anticipated threats and hazards; and (c) that authorized access to, or use of, client records or information is protected against.

2. The Company will maintain policies and procedures that are reasonably designed to safeguard nonpublic personal information about clients and only permit appropriate and authorized access to and use of, nonpublic personal information about clients through the application of appropriate administrative, technical, and physical protections.

3. To the extent required by applicable law, the Company shall direct each of the Company's service providers to adhere to the privacy policy of the Company with respect to all nonpublic personal information about clients provided to such service providers.

4. The Company shall not disclose any nonpublic personal information about its clients or former clients to anyone, except as permitted or required by law.

5. The Company shall issue notices of its privacy policy to its clients initially and on an annual basis thereafter to the extent required by law.