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PRIVACY POLICY
Valley Management, L.P. (the “General Partner”) and Dern Capital Management Corporation (the “Investment Manager”) maintain physical, electronic, and procedural safeguards to store and secure your information against unauthorized access, alteration and destruction. Control policies, for example, authorize access to client information to individuals who need access to do their work. Our employees are required to protect the confidentiality of your information and to comply with our established policies. They may access information only when there is an appropriate reason to do so. Employees who violate our privacy policy are subject to disciplinary process. We provide our Privacy Policy to clients when they invest or open a new account and annually thereafter. If we materially change our Privacy Policy, we will notify you.
This Privacy Policy applies to the relationships of current and former investors in the Funds and Investment Manager Clients. We obtain most of our information from you when you invest in the Fund(s) or apply for, access and use financial services offered by Investment Manager. We limit the collection and use of information to the minimum necessary to provide superior service to you. We use the information we have about you to provide superior client service, offer more convenient access to our services, and make a wider range of services and investment products available to you. We do not disclose your personally identifiable information to third parties except as described in our Privacy Policy. We may disclose information when required to do so by law and for legal compliance purposes, such as disclosure to attorneys or other professionals. In addition, information may be disclosed for audit purposes or to law enforcement and regulatory agencies. Further, we may disclose information to third party service providers to enable them to provide the Funds with business services such as Fund bookkeeping and audits.
Except in those limited situations, we will not make any disclosures of information to other companies who may want to sell their products or services to you without your consent. We hope that the use of your information will result in improved client service and responsiveness, access to new service offerings and detection of unusual behavior to help prevent unauthorized transactions or fraud within your account. We reserve the right to change this Privacy Policy. The examples contained within this Privacy Policy are illustrations and they are not intended to be exclusive. This notice complies with Federal law and SEC regulations regarding privacy.
March 31, 2010
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