PERACS, GmbH, its affiliates, and its employees (“PERACS”) place a strong emphasis on the protection of its clients’ confidential and sensitive information, both personal and financial. PERACS believes that confidentiality and discretion are central factors in developing and maintaining trust and confidence. As part of it services PERACS may collect non-public information about its clients from negotiations, documents and other sources provided by authorized representatives.

PERACS does not disclose confidential information of clients or that of former clients other than that permitted or required by law. PERACS only discloses such information with the knowledge of its clients in the ordinary course of providing investment advisory services on their behalf. Any such information is only provided with the understanding that it will be maintained in confidence by the receiving party.

To protect confidential information PERACS limits access to those employees who need the information to perform their duties on its clients’ behalf. PERACS requires its employees to maintain this information in confidence. PERACS maintains physical, electronic, and procedural safeguards, including the use of encryption technologies, to protect confidential information.