AFFINITY CAPITAL, L.P. PRIVACY NOTICE 

Affinity Capital, L.P. (“Affinity Capital”) maintains physical, electronic, and procedural safeguards

that comply with federal standards to protect its clients’ nonpublic personal information (“information”).

Through this policy and its underlying procedures, Affinity Capital attempts to secure the confidentiality

of customer records and information and protect against anticipated threats or hazards to the security or

integrity of customer records and information.

It is the policy of Affinity Capital to restrict access to and/or the sharing of all current and former

clients’ information (i.e., information and records pertaining to personal background [including social

security number and address], investment objectives, financial situation, financial planning issues, tax

information/returns, investment holdings, account numbers, account balances, etc.) to those employees and

affiliated/nonaffiliated entities who need to know that information in furtherance of the client’s engagement

of Affinity Capital.

Affinity Capital shall disclose, as necessary, the client’s information: (1) to unaffiliated service

providers and vendors in furtherance of establishing, maintaining, and reporting on the client’s Affinity

Capital relationship (i.e., broker-dealer, account custodian, record keeper, technology, performance

reporting, customer relationship management software [CRM], proxy voting, insurance, independent

managers, sub-advisers, etc.); (2) required to do so by judicial or regulatory process; or (3) otherwise

permitted to do so in accordance with applicable federal and/or state privacy regulations.

However, Affinity Capital does not, and shall not, disclose or share information with any affiliated

or nonaffiliated persons, entities or service providers for marketing or any other purposes or reasons not

referenced above.

ANY QUESTIONS OR CONCERNS:  Should you have any questions regarding the above,

please contact Ann I. Miller, President and Chief Compliance Officer at (713) 238-6730.