When you use SC Distributors as your Dealer Manager, you entrust us not only with your hard-earned assets but also with any personal and financial data, if applicable. We consider your data to be private and confidential, and we hold ourselves to the highest standards of trust in their safekeeping and use. We may collect non-public personal information about SC Distributors clients such as you, from the following sources:

  • Information we receive from you on applications or other forms;
  • Information about your transactions with us, our affiliates, or others; and
  • If you visit our Web site, information we collect via a web server, often referred to as a "cookie." Cookies indicate where a site visitor has been online and what has been viewed.

We do not disclose any non-public personal information about our clients or former clients to anyone, except as permitted by law. Moreover, we will not release information about our clients or former clients unless one of the following conditions is met:

  • We receive your prior written consent;
  • We believe the recipient to be you or your authorized representative; or
  • We are required by law to release information to the recipient.

We only use information about you and your account to help us better serve your investment needs or to suggest services or educational materials that may be of interest to you. To further protect your privacy, our Web site uses security programs and devices, which we believe to be in accordance with current business practices, including data encryption, user names and passwords, and other tools. We maintain physical, electronic and procedural safeguards to guard your personal account information. We also restrict access to your personal and financial data to authorized SC Distributors associates who have a need for these records. We advise you not to send such information to us in non-secure e-mails.

Confidentiality and Security

We maintain physical, electronic and procedural safeguards to guard your personal account information. We also restrict access to your personal and financial data to authorized SC Distributors associates who have a need for these records. We require all nonaffiliated organizations to conform to our privacy standards and they are contractually obligated to keep the information provided confidential and used as requested. Furthermore, we will continue to adhere to the privacy policies and practices described in this notice even after your account is closed or becomes inactive. We will continue to conduct our business in a manner that conforms with our pledge to you, your expectations and all applicable laws.

SC Distributors, LLC Business Continuity Plan

SC Distributors, LLC has developed a Business Continuity Plan on how we will respond to events that significantly disrupt our business. Since the timing and impact of disasters and disruptions is unpredictable, we will have to be flexible in responding to actual events as they occur. With that in mind, we are providing you with this information on our business continuity plan.

Contacting Us - If you cannot access us through either phone or e-mail, you should contact the Fund or the broker/dealer though which you have invested in directly for instructions on how you may access investment information, invest additional funds and/or provide you with access to your funds as provided for in the subscription documentation.

Our Business Continuity Plan- We plan to quickly recover and resume business operations after a significant business disruption and respond by safeguarding our employees and property, making a financial and operational assessment, protecting the firm’s books and records, and allowing our customers to transact business. In short, our business continuity plan is designed to permit our firm to resume operations as quickly as possible, given the scope and severity of the significant business disruption. Our business continuity plan addresses: data backup and recovery; all mission critical systems; financial and operational assessments; alternative communications with customers, employees, and regulators; alternate physical location of employees; critical supplier, contractor, bank and counter-party impact; regulatory reporting; and assuring our customers prompt access to their funds and securities if we are unable to continue our business.

Since you invest directly, the Fund is responsible for those records that they maintain on your behalf as an investor in theirinvestment program. Additionally, when you invest with our assistance, we take steps to assure that you have paper or electronic copies of everything that you have signed and or obligated yourself to, which results in your having access to essentially the samerecords as us, should you be unable to contact us during a an emergency situation. Finally, while most transactions done through us are not time sensitive, every emergency situation poses unique problems based on external factors, such as time of day and these verity of the disruption. Thus, while the Fund desires to restore its own operations and be able to complete existing transactions and accept new transactions and payments within a short period of time, your orders and requests for funds and securities could be delayed during this period by them.

Varying Disruptions- Significant business disruptions can vary in their scope, such as only our firm, a single building housing our firm, the business district where our firm is located, the city where we are located, or the whole region. Within each of these areas, the severity of the disruption can also vary from minimal to severe. In a disruption to only our firm or a building housing our firm, we will transfer our operations to a local site when needed and expect to recover and resume business within forty-eight (48) to seventy-two (72) hours. In a disruption affecting our business district, city, or region, we will transfer our operations to a site outside of the affected area, and recover and resume business within seventy-two (72) hours. In either situation, we plan to continue in business, and notify you through our customer emergency number how to contact us. If the significant business disruption is so severe that it prevents us from remaining in business, we will take steps to assure your prompt interface with the Fund.

For more information – If you have questions about our business continuity planning, you can contact us at (657) 383-9640.

This plan is subject to modification; an updated summary will be promptly posted on our Web site (once established) and may alternatively be obtained by requesting a written copy by mail.

February, 2016


NOT AN OFFER TO SELL SECURITIES
The material in this Web site does not constitute an offer to sell, nor a solicitation of an offer to buy the securities described herein. Such an offering is made only by means of a prospectus. The prospectus must be read in order to understand fully all the implications and risks of any offering of securities to which it relates. A copy of the prospectus must be made available to you in connection with an offering. Neither the Securities and Exchange Commission, the attorney General of the state of New York nor any other state securities regulator has approved or disapproved of these securities or determined the prospectus is truthful or complete. Any representation to the contrary is a criminal offense. Investing involves a high degree of risk and there is no assurance that investment objectives of these programs will be met. Refer to the prospectus for suitability standards in your state. Please contact your Financial Advisor for more Information. Securities offered through SC Distributors, LLC member FINRA and SIPC.