This privacy policy explains the manner in which ICEHOUSE CAPITAL collects, utilizes and maintains nonpublic personal information about ICEHOUSE CAPITAL's investors, as required under United States federal legislation as it may be applicable.  This privacy policy only applies to nonpublic information of investors who are individuals (not entities).

 

ICEHOUSE CAPITAL has delegated the responsibility to collect personal information about investors in funds residing on the ICEHOUSE CAPITAL platforms to Apex Fund Services Ltd. (“Apex”) who serves as the administrator for the ICEHOUSE CAPITAL platforms and Apex’s affiliates to whom it may sub-delegate this responsibility.  The personal information about investors is collected mainly through the following sources:

 

• Subscription forms, investor questionnaires and other information provided by the investor in writing, in person, by telephone, electronically or by any other means. This information includes name, address, nationality, tax identification number, and financial and investment qualifications; and

 

• Transactions within ICEHOUSE CAPITAL, including account balances, investments and withdrawals.

 

Neither ICEHOUSE CAPITAL nor Apex sell or rent investor information.  Neither ICEHOUSE CAPITAL nor Apex disclose nonpublic personal information about investors invested in funds on the ICEHOUSE CAPITAL platforms to nonaffiliated third parties or to affiliated entities, except as permitted by law.  For example, ICEHOUSE CAPITAL and Apex may share nonpublic personal information in the following situations:

 

• To service providers in connection with the administration and servicing of ICEHOUSE CAPITAL and the funds on its platforms, this may include attorneys, accountants, auditors and other professionals. ICEHOUSE CAPITAL may also share information in connection with the servicing or processing of Partnership transactions;

 

• To affiliated companies in order to provide you with ongoing personal assistance with respect to the products and services you have purchased through ICEHOUSE CAPITAL;

 

• 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; and,

 

• Upon consent of an investor to release such information, including authorization to disclose such information to persons acting in a fiduciary or representative capacity on behalf of the investor.

 

ICEHOUSE CAPITAL’s policy is to require that all employees, financial professionals and companies providing services on its behalf keep client information confidential.

 

ICEHOUSE CAPITAL maintains safeguards that comply with best practices in the jurisdictions in which it operates to protect investor information.  ICEHOUSE CAPITAL restricts access to the personal and account information of investors to those employees who need to know that information in the course of their job responsibilities.  Third parties with whom ICEHOUSE CAPITAL shares investor information must agree to follow appropriate standards of security and confidentiality.

 

ICEHOUSE CAPITAL and Apex implement appropriate technical and organizational measures to protect electronic data and ensure against accidental destruction or loss or unlawful forms of processing in order to provide an adequate level of technical security. ICEHOUSE CAPITAL and Apex have a written cyber security policy in place as part of their efforts to employ best practices with regard to the protection of electronic data.

 

ICEHOUSE CAPITAL’s privacy policy applies to both current and former investors. ICEHOUSE CAPITAL may disclose nonpublic personal information about a former investor to the same extent as for a current investor.

 

ICEHOUSE CAPITAL may make changes to its privacy policy in the future. ICEHOUSE CAPITAL will not make any change affecting you without first sending you a revised privacy policy describing the change.