Privacy Policy

GRAMERCY PRIVACY POLICY

Gramercy is deeply committed to preserving your privacy. All information that is provided to Gramercy, including, but not limited to, information transmitted while visiting our website and nonpublic personal information about our clients and former clients, is treated as restricted, sensitive information and is not disclosed to third parties other than as described below. If desired, a visitor can visit our website without disclosing who they are or revealing any personal information. Set forth below is a full disclosure of our policies regarding the collection, sharing, and protection of your personal information.

What information Gramercy collects
In connection with the investment advisory services that Gramercy provides, we are obligated to collect certain personal information. This information may include, but is not limited to, assets, social security number, tax identification number, photo identification, investment experience, transaction history, income and wire transfer instructions. Additionally, Gramercy collects and maintains a database of less sensitive personal information relating to our clients and prospects including name, phone number, address and e-mail address. We do not sell or trade any of this data.

How Gramercy collects this information
Gramercy collects this information through various means, including, without limitation, when you give us contact or other personal information, enter into an investment advisory contract with us, buy securities (i.e., interests in a fund) from us, and tell us where to send money, or make a wire transfer. We may also collect personal information from other sources, such as our affiliates. Our affiliates are companies related to us by common ownership or control and can include both financial and non-financial companies.

How Gramercy uses the information that it collects
Gramercy utilizes the personal information we obtain from investors and prospects solely for purposes of facilitating our day to day business. For example, these purposes may include: to provide advisory services, to open an account, to process a transaction for an account, to market products and services, and to respond to court orders and legal investigations. We maintain such information in our databases to ensure our compliance with regulations requiring thorough identification of investors. Under no circumstances does Gramercy share this information with any outside organization other than to facilitate the servicing of investor accounts (described below) or as required by law.

What security measures Gramercy has in place
Because we regularly deal with sensitive information, we have appropriate security measures in place over our electronic network and in our physical facilities to protect against the loss, misuse, or alteration of information that we have collected verbally, in writing, from our website or otherwise.

Disclosure of information to others
We may provide your personal information to our affiliates and to firms that assist us in servicing your account and have a need for such information, such as a broker, custodian and/or fund administrator. We may also disclose such information to our other service providers or as otherwise required by law.

How this Privacy Policy may be modified
From time to time, Gramercy may change this notice. If we do, we will not use any material nonpublic personal information we have already collected in any new manner without first obtaining consent.

How can you contact Gramercy about this policy
We work hard to ensure that your experience with us and on our website is a positive one. If you have any questions about this privacy notice or your dealings with our website, please contact:br />

Lacie Smith, Managing Director, Head of Investor Relations
lsmith@gramercy.com

Last updated March 1, 2018