Protecting your personal information is an important priority for Fair Winds Capital Investments (the “Company” or “Fair Winds”).  Ashcroft’s privacy policy is designed to support this objective. Fair Winds may collect non-public personal information concerning you in the following ways:

• Information provided by you or your representative on documents or other forms furnished to the Company or through other interactions that you or your representative have with the Fair Winds
• Information arising from your investments in or accounts with the Fair Winds Capital Investments

Fair Winds Capital Investments employs physical, electronic, and procedural controls to safeguard your information. For example, Fair Winds authorizes access to your personal and account information only for personnel who need that information in order to provide products or services to you.

Fair Winds does not disclose any non-public personal information about you, except as permitted by law. For example, the Company has entered into a number of arrangements with service providers to assist with tax form preparation, investor outreach, required SEC and State filings, internet security, online investor account management, including distributions and servicing of investment accounts.

If you decide to close your account, Fair Winds will continue to adhere to the privacy policies and practices as described in this notice.”