“The confidentiality of client information is of the utmost importance to Certeza Asset Management LLC.  During the course of opening Client accounts and managing the accounts, Certeza Asset Management 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 (i.e., FCMs and IBs) necessary to open and maintain the account.

Certeza Asset Management LLC does not disclose any nonpublic personal information about its clients to anyone, except as may deemed necessary by Certeza Asset Management LLC to comply with the rules and regulations that govern Certeza Asset Management LLC’s CTA operations.  Certeza Asset Management 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 Asset Management LLC may share Client information with non-affiliated companies that work for Certeza Asset Management LLC in the capacity as independent contractors.  These companies may include compliance service providers that assist Certeza Asset Management LLC in compiling performance data and computing the Advisor’s fees in accordance with CFTC and NFA Requirements.  Generally, the records provided to these service providers would be the daily and monthly statements generated by the FCM, the Client’s completed account forms, or other information that the Client may have provided to Certeza Asset Management LLC in the course of establishing and maintaining the account.   At times, Certeza Asset Management 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 Asset Management LLC does not sell personal information related to its Client account.  Furthermore, no Client will be permitted to review other Clients’ records.

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

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