Camden Asset Management, LP

Camden Asset Management L.P.
Internet Privacy and Security Policy
Revised as of January 2012

This Internet Privacy and Security Statement (“Statement”) is issued by Camden Asset Management L.P. (“CAM”). We understand the importance of maintaining your information in a secure and confidential manner. We are committed to maintaining the privacy of the information you share with us when you use our web site. We will use reasonable efforts to see that all information, identifying and otherwise, submitted to us by clients who use our web site, remains private and is used only for the purposes intended.

In this Statement, we describe what information is gathered from our web site and from certain other sources and how we use it. If you have any questions about CAM’s privacy practices or this Statement, or you would like to receive a copy of CAM’s full Privacy Policy, please e-mail Janice Brooks at JBrooks[at]camdenasset[dot]com or contact us via telephone at (310) 785-9755. We will be happy to assist you.

Information we gather from our Clients.

CAM collects nonpublic personal information about you from applications or other forms you complete and from your transactions with us. The term “personal information” includes information such as your name, address, telephone number, e-mail address, Social Security number or other national identification number, account number, income, assets information, account balance, accreditation status and investment history.

What we do with the information we gather.

We do not disclose information about you, or our former clients to service providers or other third parties except on the limited basis permitted by law. For example, we use this information to help administer your accounts with us such as by providing you with performance information and portfolio analysis on CAM’s products. Your personal information also lets us know how to contact you so that we may answer your questions or respond to your requests. To serve you better, we may combine information you give us through this web site or through other communication channels.

Currently we do not track individual users; but we may implement the capacity to do so in the future. In any case, we currently analyze the data, and will analyze the data in the future, only to determine how to make the web site better and more useful. This information is and will be strictly for our internal use.

Our policy on sharing site information with third parties.

Information about you and any users of our web site is not sold or rented to any third party. We do not trade such information with any third party. Even within CAM, only people involved with servicing your accounts have access to your personal information.

We do reserve the right to disclose or report personal information in limited circumstances where we believe in good faith that disclosure is required under law, to cooperate with regulators or law enforcement authorities, and to protect our rights or property. We reserve the right to use your e-mail or other address to send you important information relating to your account, including regulatory communications.

How we protect your information.

To ensure a high level of confidentiality and security, CAM maintains physical, electronic and procedural safeguards that meet federal standards. We also employ the security techniques described in the Terms and Conditions of Use. This web site does not use cookies.

When we share personal information with our service providers, we expect them to treat that information with strict confidentiality and to retain your personal information no longer than is necessary to provide the product, service, or information.

We expect our employees with access to confidential client information not to use or disclose the information except for business purposes. Personal information about you is normally used only by those employees who need to know that information to provide our products or services to you. All employees are expected to safeguard such information and employees who violate these obligations will be subject to our normal disciplinary process.

Special security measures apply to your communications with us on this web site. Internally, we employ encryption technologies, user authentication systems (e.g., passwords and personal identification numbers) and access control mechanisms to secure access to our computer systems and files. We employ firewalls for our Internet-based systems.

Our site uses current Web server technology, which provides us with data encryption and authentication features. Certain communications between you and this web site are protected by a Secure Sockets Layer (“SSL”). Your browser will let you know when the page you are viewing is secure. SSL is a technology that is used to establish an encrypted connection between your computer and the web server. Pages accessed via SSL allow all data on those pages transmitted between the server and your computer to be encrypted even while traveling across multiple networks. The encryption is achieved through an electronic scrambling technology that uses “keys” to encrypt and decrypt data. The “keys” for each secure session are established and retired automatically by the SSL program; it is not necessary for you to learn to operate an encryption program. CAM uses SSL encryption that provides the maximum encryption key length (up to 128 bits) allowed by your browser when transmitting your information. The longer the key, the more secure the encrypted data.

How you can correct and update personal information.

If you would like to correct, review or delete any of the information you have submitted to CAM via this web site, you may do so at any time by e-mail, postal mail or telephone call. Note our postal address is Camden Asset Management L.P., 2029 Century Park East, Suite 2010, Los Angeles, CA 90067.

Communications with Us.

CAM welcomes your e-mail correspondence and our staff is available to address your general investment questions as well as respond to your suggestions for improvement.

Changes to this Statement.

We reserve the right to change or remove this Statement at our discretion. If we decide to change it, we will post those changes here. Any changes or updates will be effective immediately upon posting to this web site. In the event of any material change to our Internet Privacy and Security Statement, we will notify you via the address we have in your personal profile. We encourage you to visit this area frequently to stay informed. If you access our web site after we have posted changes to this Statement, you are agreeing to accept the changes.