The importance of protecting your privacy is recognized by the Fund and Spinner Asset.  Our Privacy Policy is provided below. Questions regarding this Privacy Policy should be directed to Spinner at: ggomez@spinnerasset.com.

We are required to screen our members to determine whether they qualify as accredited investors and we collect some information either required by us or voluntarily offered by users of this web site. We use reasonable precautions to maintain the security of the personal information of users. However, no security system is perfect. Therefore, we are not responsible if someone manages to circumvent our security measures and gain access to our database or information pertaining to individual users, nor can we be responsible for any use, reproduction, or disclosure they may make of it.

We take reasonable precautions to protect your personal information. You should never share your password with anyone.

We may use cookies on certain pages of our site. "Cookies" are small pieces of information that are stored by your browser on your computer's hard drive. Cookies enable us to improve the performance of our site. You can set your browser to notify you when you receive a cookie, and you can choose to delete any cookies you receive.

By using our site, you consent to the collection and use of your personal information by Spinner. If we decide to change our Privacy Policy, we will post the changes on this page. Your continued use of the site after any such change is made constitutes acceptance of and agreement to be bound by the terms of the Privacy Policy as modified.

We do not, and will not, share your personal information with nonaffiliated third parties which are not service providers to the Fund and/or Spinner Asset without prior notice. Such service providers include but are not limited to the Registrar and Transfer Agent, the Portfolio Administrator, the Auditors, the Placement Agent, and the Legal Advisors of the Fund.  We may be required to share selected information under limited conditions as part of normal business operations and to meet legal and regulatory requirements of the U.S. Securities and Exchange Commission, the U.S. Internal Revenue Service and other regulatory agencies.
We may collect, analyze, and disclose to others aggregated information (which includes users' specific information but only as an unidentifiable part of the aggregate) gathered from overall use of the web site or particular features or areas of the web site.

In addition, we may disclose specific user information (such as identity and contact information) if we believe that such disclosure is necessary or desirable to: (1) fulfill legal or regulatory requirements, (2) protect our rights or those of others, (3) prevent or mitigate harm or damage of any kind or nature, or (4) address or seek redress for a violation of our Terms of Use or other obligations to Spinner or any third party, including our partners, advertisers, and other users.

Our site contains links to third party websites. We are not responsible for the privacy practices or content of such third party websites.