PRIVACY POLICY

Mosaic Research Management, LLC

This privacy policy explains the manner in which the Company collects, utilizes and maintains nonpublic personal information (“Personal Information”) about its potential and current Clients and Consultants.  The Company will apply this Privacy Policy to all of its Clients and Consultants- individuals and entities alike.  Personal Information shall mean information that can be used on its own or with other information to identify, contact, or locate an individual or entity Specifically, for the purpose of this policy, Personal Information includes, but is not limited to, name, social security number, contact information, employment or financial information including any list, description, or other grouping that is derived using nonpublic personal information other than publicly available information.

Collection of Personal Information

The Company collects personal information about Clients and Consultants mainly through the following sources:

• Website, questionnaires and other information provided in writing, in person, by telephone, electronically or by any other means. This information includes name, address, nationality, tax identification number.

Disclosure of Nonpublic Personal Information

The Company does not sell or rent Personal Information. The Company does not disclose Personal Information to nonaffiliated third parties or to affiliated entities, except as permitted by law and any non-disclosure agreements.  For example, the Company may share Personal Information in the following situations:

• To service Clients in connection with the administration and servicing of the Company, including attorneys, accountants, auditors and other professionals. The Company may also share information in connection with the servicing or processing of Company transactions.

• To respond to a subpoena or court order, judicial process or regulatory authorities.

• To protect against fraud, unauthorized transactions (such as money laundering), claims or other liabilities.

Protection of Personal Information

The Company’s policy is to require that all Employees, financial professionals and companies providing services on their behalf keep Personal Information confidential. The Company maintains safeguards that comply with federal standards to protect such information. The Company restricts access to the Personal Information to those Employees who need to know that information in the course of their job responsibilities. The Company shall conduct due diligence of any third party service provider that will host or manage sensitive information prior to engagement to ensure it has appropriate data security and privacy policies, procedures, and controls in place.   Third parties with whom the Company shares Personal Information must agree to follow appropriate standards of security and confidentiality. The Company shall adhere to the policies and practices described in this policy with respect to both current and former Clients and Consultants. 

Location and Maintenance of Personal Information

All Personal Information is maintained by the Company’s Compliance Department and is retained in accordance with the Company’s record retention procedures.  The Compliance Department ensures the security of the Company’s Personal Information by keeping all Personal Information electronically in the company’s Salesforce.com database with appropriate data security (available at trust.salesforce.com).  Limited access has been granted to Employees in the course of their specific job responsibilities, whereby Employees may only access Personal Information of the specific Client or Consultant to which they are assigned.  If an Employee requires further access, they must receive approval from the Compliance Department, who will determine if such access will be approved, and if so, the level of access allowed thereto.