Annandale Capital, L.L.C. considers the confidentiality, integrity and security of client information and records absolutely essential to maintain trust and superior service. To the extent Annandale Capital, L.L.C. collects certain nonpublic personal information about the current and prospective clients, such shall not be disclosed to any unauthorized individual or entity, except as required by law.

All business activities associated with privacy and security related matters shall be reviewed and approved by the CCO, or his designee.

The CCO, or his designee, is responsible to ensure the security and confidentiality of customer information and records, protect against anticipated threats to its integrity and unauthorized access. In order to establish, implement and monitor these privacy policies, the CCO, or his designee, shall:

• Maintain current policies and procedures to protect client records and information;
• Deliver initial, and offer annually thereafter, privacy notices to all existing and new customers;
• Protect the collection, storage and transmission of all nonpublic personal information; and
• Educate employees about privacy policy and procedures.

Annandale Capital, L.L.C. will disclose details of any information sharing arrangements. Specifically, Annandale Capital, L.L.C. shall not disclose nonpublic personal information that it may collect other than to service providers and third parties that aid in fulfilling the service requested by a client and Annandale Capital, L.L.C.’s policies and practices with respect to protecting the confidentiality, security, and integrity of nonpublic personal information. The notices shall be delivered to all current clients initially, every client at the inception of the account and offer annually thereafter.

With regard to internal security procedures, Annandale Capital, L.L.C. shall restrict access to client’s personal and account information to those employees who need to know that information to service the account(s). Annandale Capital, L.L.C. shall maintain physical, electronic and procedural safeguards to protect nonpublic personal information.

These policies and procedures described in this section shall be adhered to regardless of termination or inactivity in customer’s account(s).

DELIVERY OF THE POLICY
Annandale provides it Privacy Policy to its customers in a variety of ways.

• The policy is provided to all customers who open an account at the time the account is opened.
• All customers will be provided a copy of the Firm’s amended policy, should such occur.
• All customers will be offered a copy of the policy at least annually.
• The policy will be available on the Firm’s web site, if any.

The CCO is responsible for ensuring secure access to the policy and will monitor all changes to it.

These activities and the testing of safeguards will be conducted annually by the CCO, or his designee. Their initials on the review document will evidence supervision of this area.