Gladius Capital Management LP ("Gladius", "Adviser", "we", "our", "us") is committed to protecting the privacy of its Clients and Fund Investors. We are providing you with this privacy notice to inform you of how we handle your personal information that we collect, the safeguards we put in place to protect that information and the instances in which we may share it. Gladius will provide a copy of this privacy notice to each prospective investor that is a natural person at, or prior to, the time such investor makes his or her first investment in a Fund and annually thereafter. This privacy notice supersedes any of our previous notices relating to the information you disclose to us.

Gladius generally does not disclose nonpublic personal information about Clients or Fund Investors to nonaffiliated third-parties, other than service providers who need access to that information in order to permit the Client and Adviser to conduct their affairs (e.g., auditors, accountants, prime brokers and attorneys). Such nonpublic personal information is obtained from Fund subscription agreements or managed account agreements, transactions with Funds and accounts (such as additional investments and withdrawals) and other sources and may include, but is not limited to, names, addresses, account numbers, trading history, account balances and social security numbers. Such information also may be disclosed when a Client or Fund Investor specifically authorizes the disclosure and for other purposes required or permitted by law, such as where reasonably necessary to prevent fraud or unauthorized transactions, respond to judicial process or subpoena or comply with federal, state or local laws.

Prospective Clients and Fund Investors must indicate their understanding in a managed account advisory agreement or Fund subscription agreement, as pertinent, that although Adviser will use its best reasonable efforts to keep Clients' and Fund Investors' investments and the information Clients and Fund Investors provide to Adviser confidential, (1) there may be circumstances in which applicable law or regulation Page relating to combating terrorism or money laundering may require the release of information provided to Adviser to law enforcement or regulatory officials, (2) Adviser may present completed subscription agreements or Client documents and/or any information included therein to any service providers of Adviser, the Fund or managed account or to such regulatory bodies or other parties as may be appropriate to establish the availability of exemptions from certain securities and similar laws or the compliance of the Client, its directors, if any, and/or Adviser with applicable laws, (3) Adviser may disclose such completed subscription agreement and managed account agreements, any information included therein or other information relating to a Client's or Fund Investor's accounts or investments when required by judicial process or, to the extent permitted under applicable privacy laws, to the extent Adviser considers that information relevant to any issue in any action, suit or proceeding to which Adviser is a party or by which it is or may be bound and (4) where such disclosure is required by any law or order of any court or pursuant to any direction, request or requirement (whether or not having the force of law) of any central bank or governmental or regulatory or taxation authority. Any Client that instructs Adviser to send duplicate reports to any nonaffiliated third-party may revoke such instructions at any time by sending a written notice to Adviser indicating that a previously authorized nonaffiliated third-party is no longer authorized to receive such reports.

To protect Clients' personal information from unauthorized access and use, Adviser uses security measures that comply with federal law including administrative, technical and physical safeguards to maintain the confidentiality and security of Clients' information. From an administrative standpoint, Adviser restricts access to such information internally to those personnel (and the personnel of affiliates) who need the information in order to conduct Adviser's business. Adviser also endeavors to obtain contractual assurances from nonaffiliated third-party service providers to protect the confidentiality of Clients' and Fund Investors' nonpublic personal information when it is appropriate to do so and takes reasonable measures to verify that such nonaffiliated third-parties maintain safeguards designed to provide reasonable protection for the confidentiality of Clients' and Fund Investors' nonpublic personal information.

Further, Adviser has implemented technical safety measures including, but not limited to, an information security plan, which includes policies and procedures reasonably designed to safeguard the security and confidentiality of personal information, protect against any anticipated threats to the security of such information and guard against unauthorized access to or use of such information. Adviser also implements policies and procedures reasonably designed to ensure the protection of any personal information provided and/or collected in physical form including the transport, storage and access of records containing personal information offsite.