PRIVACY POLICY

At Balestra Capital, Ltd., maintaining the trust and confidence of our clients is of paramount importance. We are committed to safeguarding our clients' personal information and providing them with facts and options about how this information may be shared. This notice replaces all previous statements of our consumer privacy policy, and may be amended at any time. We will provide our clients with annual reminders of our policies and with revised policies if there are any changes in how we handle our clients' personal information. If a client ends its relationship with us, we will continue to adhere to the policies and practices described in this notice. If clients or prospective clients have any questions about this privacy policy, they can contact Balestra Capital at (212) 768-9000.   

Information That We Collect. In connection with providing our clients with our services, we obtain nonpublic and public information about our clients, which may include the following:   

• Information that we receive from clients in subscription documents or other forms including name, address, social security number, assets, and income.   
• Information about clients' investments with us, our affiliates or others.   
• Information that we may obtain about clients from a consumer reporting agency.   

Information That We Share. We, along with our affiliates, use or share information in a limited and carefully controlled manner. We do not disclose any nonpublic information about our prospective, existing or former clients to anyone, except as permitted or required by law or requested by a regulatory agency. Instances in which we may be required or requested to share client information include:  

• Disclosure to companies that provide services necessary to effect a transaction that clients request or to service client accounts, such as prime brokers, accountants, attorneys, or administrators. 
• Disclosure to government agencies, courts, parties to lawsuits, or regulators in response to requests or subpoenas. In such cases, we share only the information that is reasonably necessary to satisfy the request or that we are required or authorized to share.   

Confidentiality and Security. Only those persons who need client information to perform their jobs have access to it. In addition, we maintain physical, electronic, and procedural security measures that comply with federal regulations to protect client information. Our employees have limited access to clients' personal information based upon their responsibilities. All employees are instructed to protect the confidentiality of clients' personal information as described in these policies, which are strictly enforced.