FAIRWAY AMERICA INVESTMENT ADVISORS, LLC PRIVACY NOTICE

Fairway America Investment Advisors, LLC (“Fairway America”) adopted this policy with recognition that protecting the privacy and security of the nonpublic personal information we obtain about our investors is an important responsibility. We alsoa know that you expect us to service you in an accurate and efficient manner. To do so, we must collect and maintain certain nonpublic personal information about you. We want you to know what information we collect and how we use and safeguard that information.

WHAT INFORMATION WE COLLECT

We collect certain nonpublic personal information about you (such as your name, address, social security number, etc.) that you provide on subscription agreements, custodian or brokerage applications, or other forms as well as communications (electronic, telephone, written or in person) with you or your authorized representatives (such as your attorney, accountant, etc.). We also collect information about your accounts with us to manage our private funds.

WHAT INFORMATION WE DISCLOSE

Fairway America does not disclose the nonpublic personal information we collect about our investors to anyone except: (1) in furtherance of our business relationship with investors, and then only to those persons necessary to effect the transactions and provide the services that investors authorize (such as broker-dealers, administrators, custodians, independent managers, etc.); (2) to persons assessing our compliance with industry standards (e.g., professional licensing authorities, etc.); (3) our attorneys, accountants, and auditors; or (4) as otherwise provided by law. We are permitted by law to disclose the nonpublic personal information about you to governmental agencies and other third parties in certain circumstances (such as third parties that perform administrative services on our behalf). These third parties are prohibited to use or share the information for any other purpose. If you decide to either terminate our services or become an inactive client, we will continue to adhere to our Privacy Policy, as may be amended from time to time.

SECURITY OF YOUR INFORMATION

We restrict access to your nonpublic personal information to those employees who need to know that information to service your account. We maintain physical, electronic and procedural safeguards that comply with applicable federal or state standards to protect your nonpublic personal information.

CHANGES TO OUR PRIVACY POLICY OR RELATIONSHIP WITH YOU

Our policy about obtaining and disclosing information may change from time to time. We will provide you notice of any material change to this policy before we implement the change.

OPTING OUT

Investors cannot opt out of allowing Fairway America to share their nonpublic personal information with affiliated or non-affiliated third parties which are necessary to service their accounts.

REQUESTS FOR INFORMATION

For a copy of our Privacy Policy, please contact the CCO Lance Pederson at lance.pederson@fairwayamerica.com