Privacy Policy Notice

The privacy of our investors is important to us, and we are committed to safeguarding and protecting their personal and financial information.

Information Provided by Investors/Partners

In the normal course of doing business and to satisfy our regulatory requirements, Steben & Company typically obtains the following non-public personal information about our investors:

• personal information such as, name, address and social security/tax id number.
• Investors financial information such as assets, income, investment experience and investment objectives

How We Manage and Protect Personal Investor/Partner Information

Steben & Company does not sell information about current or former clients to non-affiliated third parties, nor do we disclose such information to non-affiliated third parties unless requested to do so by a client or client representative or, if necessary, in order to properly service an account or as required by law. We do share investor account information with the broker dealer or investment advisory firm that introduced the investor to us, if applicable, so that they may properly advise their client, and with outside companies that perform administrative services for us, including our accountants, insurance providers and legal counsel. However, our contractual arrangements with our service providers require them to treat our investor information as confidential.

Nonpublic personal information is gathered and kept only to the extent necessary to comply with applicable state and federal regulations. Steben & Company has established security standards to ensure against unauthorized access to customer information.

Steben & Company employees are trained regarding the Firm’s privacy policy. They are not permitted to release personal financial information to any unauthorized individual or entity.

Client Notifications

We are required by law to annually provide a notice to investors describing our privacy policy and to notify them of any interim modifications. For questions regarding the Steben & Company Privacy Policy, please call us at 240 631 7600 or email us at info@steben.com.