Privacy Notice

The privacy of your personal information is very important to us. All financial companies need to share customers’ personal information to run their everyday business. Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some, but not all, sharing. Federal law also requires us to tell you how we collect, share and protect your personal information. This notice (the "Privacy Notice") is provided by Clinton Group, Inc. (the "Investment Adviser"), and sets forth the policies of the Investment Adviser with respect to the collection, sharing and protection of non-public personal information of the Investment Adviser's clients and investors, prospective investors and former investors in funds advised by the Investment Adviser (the "Funds"). These policies apply to individuals only and may be changed at any time, provided a notice of such change is given to you. Please read this Privacy Notice carefully to understand what we do.

The types of personal information we collect and share depends on the product or service we provide to you. This information can include social security number and assets, account balances and transaction history, and investment experience and wire transfer instructions. For example, we typically collect your address, assets, transaction and/or income information when you: (i) provide it to us in the Subscription Agreement for a Fund investment and related documents; (ii) provide it to us in correspondence and conversations with the Investment Adviser's representatives; or (iii) make transactions with the Investment Adviser or the Funds, such as when you pay investment management fees, purchase securities in the Funds, tell us where to send money or make a wire transfer. We also may collect your personal information from other sources, such as credit bureaus, affiliates, or other companies.

We may disclose information about our clients and investors, prospective investors or former investors in the Funds to affiliates (i.e., financial and non-financial companies related by common ownership or control) or non-affiliates (i.e., financial or non-financial companies not related by common ownership or control) for our everyday business purposes, such as to process your transactions, maintain your account(s), report to credit bureaus, or respond to court orders and legal investigations. Thus, it may be necessary, under anti-money laundering and similar laws, to disclose information about a Fund's investors in order to accept subscriptions from them. We will also release information about you if you direct us to do so. We do not share your information with non-affiliates for them to market to you. We may disclose your information for our own marketing purposes, such as to offer our products and services to you. We may also disclose information about your transactions and experiences with us to our affiliates for their everyday business purposes. You cannot limit these types of sharing. Federal law gives you the right to limit only: sharing information about your creditworthiness for affiliates’ everyday business purposes; affiliates’ use of your information to market to you; and sharing your information for nonaffiliates to market to you. State laws and individual companies may give you additional rights to limit sharing.

We may also share information with our affiliates to market to you. You may prevent this type of sharing by calling us at (212) 739-1834. If you are a new investor, we can begin sharing your information 30 days from the date we sent this Privacy Notice. When you are no longer a client or an investor in a Fund, we may continue to share your information as described in this Privacy Notice. However, you may contact us at any time to limit our sharing. If you limit sharing for DOC ID - 25356206.2 2 an account you hold jointly with someone else, your choices will apply to everyone on your account. State laws may give you additional rights to limit sharing.

To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings.

If you have any questions about this Privacy Notice, call 212.825.0400.