The confidentiality of client information is of the utmost importance to Certeza Fund Advisors LLC.  During the course of opening Client accounts and managing the accounts, Certeza Fund Advisors LLC collects nonpublic personal information from its Clients which includes information provided by Clients on account applications and forms, and through transactions that occur in Clients’ trading accounts.  This includes account numbers for accounts maintained at financial institutions, addresses, telephone numbers, e-mail addresses, social security numbers, income and net worth figures, credit information, and any other information requested by a third party necessary to open and maintain the account. 

Certeza Fund Advisors LLC does not disclose any nonpublic personal information about its clients to anyone, except as may deemed necessary by Certeza Fund Advisors LLC to comply with the rules and regulations that govern Certeza Fund Advisors LLC’s operations.  Certeza Fund Advisors LLC limits access to the information obtained from a Client to only those employees who need it to perform their job duties while providing services to the Client.  Certeza Fund Advisors LLC may share Client information with non-affiliated companies that work for Certeza Fund Advisors LLC in the capacity as independent contractors.  These companies may include compliance service providers that assist Certeza Fund Advisors LLC in compiling performance data and computing the Advisor’s fees in accordance with CFTC, NFA & SEC Requirements.  Generally, the records provided to these service providers would be the daily and monthly statements, the Client’s completed account forms, or other information that the Client may have provided to Certeza Fund Advisors LLC in the course of establishing and maintaining the account.   At times, Certeza Fund Advisors LLC may be required to furnish complete client records to regulators, legal counsel, courts of competent jurisdiction, or other entities as deemed necessary by the Advisor or required by law.  In addition, the Advisor may be required to furnish tax information to the Internal Revenue Service. 

Certeza Fund Advisors LLC does not sell personal information related to its Client account.  Furthermore, no Client will be permitted to review other Clients’ records. 

Certeza Fund Advisors LLC maintains physical, electronic, and procedural safeguards to protect clients’ nonpublic personal information. 

Certeza Fund Advisors LLC will provide its Clients with notice of its privacy policy annually, as long as the Client maintains an ongoing relationship with Certeza Fund Advisors LLC.  If the Clients’ account(s) become inactive or closed for some reason, Certeza will continue to treat and safeguard Client information as described in this notice.