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Your privacy is important to us.  We believe it is critical that you understand what information we collect about you and what we do with that information.  To that end, Commodity Asset Management, LLC and its affiliates (collectively, "CAM," "we" or “us”) have adopted this Privacy Policy.  Your visit to the website is subject to this Privacy Policy and our Terms of Use.  By visiting our website, you agree that we may collect, disclose and use information about you except as expressly provided below.  You should review this policy carefully, because if you do not agree with our practices, you should not visit our website.


When you invest with us or visit and browse our website or otherwise interact with us (as a trade counterparty or contractor, for instance), we may collect two different types of information about you:  (1) information you provide to us; and (2) information we collect through visits to our website.


We may collect information from you from a variety of different sources, including correspondence and discussions with you, information we receive from you on applications or other forms or documents you provide to us, and information about your transactions with us, our affiliates or others.  This information may include names, addresses, e-mail addresses, social security numbers, tax identification numbers and financial and other information we feel is necessary or useful in evaluating your ability to invest in our funds, in processing and managing your investment, or otherwise in furtherance of our business.

In addition, to access password protected areas of our website you will be required to provide your user name and password, which permits us to identify you and associate you with the personal information you have provided to us in the past.

We refer to all of this information collectively as your personally identifiable information.


Visitors to our website may be assigned a “cookie.”  Cookies are small text files sent to your computer browser from our web server and stored on your computer’s hard drive.  We use cookies for a variety of purposes, including helping us gather information and provide services to you.  For instance, when you return to our website after logging in, cookies provide information to our website so it will remember you and your technology preferences while visiting our website.  Cookies also help us diagnose problems with our web server.

You may always choose to reject our cookies by adjusting the settings of your browser, though choosing to do so may inhibit your ability to use some of the features of our website.  Each browser is different, so check your browser's "Help" menu to learn how to change your cookie preferences.

We also collect certain technical information from your computer each time you visit our website. This information may include (among other things) the Internet protocol (IP) address used to connect your computer to the Internet, the type of computer and browser you are using, and the websites you access immediately before and after you visit our website.

We may use third-party web analytics services on this Website. The analytics providers that administer these services use technologies such as cookies, web server logs and web beacons to help us analyze how visitors use this Website. The Data collected through these means (including IP address) is disclosed to these analytics providers, who use Data to evaluate use of this Website.

We may use the information we collect through technological means to measure site activity, to develop ideas for improving our website, and for any other purpose. We may freely share this information with third parties. By continuing to visit and use our website, you are agreeing to our use of cookies.


We may use your personally identifiable information to provide services to you, to open an account for you, to process transactions for our funds or your account or otherwise in furtherance of our business.  We may provide your personally identifiable information to our affiliates and to third parties that assist us in servicing your account and have a need for such information.  We may also disclose personally identifiable information about you (1) to any third party to the extent you authorize us to do so, (2) to our attorneys, accountants and auditors to the extent permitted by law for purposes of preventing fraud, responding to judicial process or a subpoena, or complying with federal, state or local laws, and (3) to U.S. or foreign governmental authorities either directly or through counterparties or other intermediaries that are regulated by such authorities) to the extent we deem necessary or advisable.  We may also disclose your personal information to our Site hosts or IT Service Providers in certain limited circumstances, for example when the Site experiences a technical problem. We may store your personally identifiable information and use it for our own research and other business purposes, and we may associate your personally identifiable information with other information we collect about you.


We endeavor to protect your personally identifiable information.  However, we will not be responsible or liable for any losses or disclosures of your personal information. We do not guarantee in any way that a security breach will not occur, whether the data is being transmitted or stored, nor that your personal information or any other information or data is fully protected from unauthorized disclosure or use.


Our website may contain links to or from other websites.  Please be aware that we are not responsible for the privacy practices of other websites and you visit those websites at your own risk.  This Privacy Policy applies only to the information we collect on our website.  We encourage you to read the privacy policies of other websites you visit. Those are the policies and practices that will apply to your use of the third-party linked website, not the Firm’s policies and practices.  Because the privacy and information security practices may be different than the Firm’s, you may be at greater risk of computer viruses, malicious code, or other defects in websites that may affect your computer.


You consent to our using your personal information for marketing purposes, including sending you information about our and our business partners’ products, services, events and research, as well as responding to requests for information, whether by means of direct mail, telemarketing or email. In connection with that use, we may use software and systems that allow us to view and analyze whether email addresses are active, individual responses to correspondence, viewing of messages, and other data points and analytic information. You should also be aware that the level of protection in relation to the storage, processing and use of personal information may not be the same in countries outside your own.


The Sites do not currently recognize automated web browser tracking method signals, such as “do not track” instructions. You can change your privacy preferences regarding the use of cookies and other technologies through your browser, including blocking all cookies; however blocking all cookies may affect your use of our Sites and other websites and services online, and may prevent you from using all the features and elements of our Sites and other websites and services.


We may revise this Privacy Policy from time to time. Any such changes will be effective immediately, so we suggest that you review this policy periodically to insure you have the most recent version.  The current version of our Privacy Policy may be accessed from the link on our website.


If you have any questions or concerns about our privacy policy, or if you wish to request access to or correct or delete any personally identifiable information that you have provided to us, please contact us by email at:

Last Updated: December 19, 2016.

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