One Oak Capital Management, LLC (the “Firm”) has adopted this policy with recognition that protecting the privacy and security of the personal information the Firm obtains about investors and potential investors in the Fund(s) and Account client(s) advised by the Firm is an important responsibility. The Firm understands that such investors, prospective investors, and clients expect the Firm to service you in an accurate and efficient manner. To do so, the Firm must collect and maintain certain personal information about you. The Firm wants you to know what information the Firm collects and how the Firm uses and safeguards that information.

WHAT INFORMATION THE FIRM COLLECTS

The Firm collects certain nonpublic personal identifying information about you (such as your name, address, social security number, etc.) from information that you provide on the Funds’ subscription documents, account 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.).

WHAT INFORMATION THE FIRM DISCLOSES

The Firm does not disclose the nonpublic personal information the Firm collects about investors, prospective investors and clients to anyone except: (i) in furtherance of the Firm’s business relationship with them and then only to those persons necessary to effect the transactions and provide the services that they authorize (such as broker-dealers, custodians, independent managers, etc.); (ii) to persons assessing Firm’s compliance with industry standards (e.g., professional licensing authorities, etc.); (iii) Firm’s attorneys, accountants, and auditors; or (iv) as otherwise provided by law. The Firm is 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 or marketing services on our behalf or for joint marketing programs). These third parties are prohibited from using or sharing the information for any other purpose. If you decide at some point to withdrawal from the Fund(s), the Firm will continue to adhere to its privacy policy, as may be amended from time to time.

SECURITY OF YOUR INFORMATION

The Firm restricts access to your nonpublic personal information to that person who needs to know that information to provide its service to the Fund(s). The Firm maintains physical, electronic, and procedural safeguards that comply with applicable federal or state standards to protect your nonpublic personal information.

CHANGES TO THE FIRM’S PRIVACY POLICY OR RELATIONSHIP WITH YOU

The Firm’s policy about obtaining and disclosing information may change from time to time. The Firm will provide you notice of any material change to this policy before the Firm implements the change.