AlphaGen Asset Management Privacy Policy
Effective as of January 1, 2007

Protecting Your Privacy has always been important to us, because we realize that your relationship with us is built on trust. Federal law now requires us to provide you with our Privacy Policy, which describes how we collect and use nonpublic personal financial information about you ("Information"). This Privacy Policy includes examples of the types of Information we collect and the kinds of companies with which we share such Information. We give you these examples to help you understand our Privacy Policy; they are not a complete listing of our Information collection, use and sharing practices. You may have other privacy rights in some states. To the extent state laws apply, we will comply with them when we share Information about you.

Please take a few minutes to review this policy.

Web Privacy Statement: Whether you are an AlphaGen Asset Management client or just visiting our Web site, we safeguard all information you provide to us.

We do not gather information about our clients or visitors via the Web, except for the data provided by the client under the password-protected section. We do gather and analyze data regarding the usage of our Web site, including the number of visits, pages visited, etc. to evaluate the usefulness of our site.

We preserve the content of your e-mail, your e-mail address and our response so that we can more efficiently handle any follow-up questions you may have. We also do this to meet legal and regulatory requirements.

Collecting Information: We collect Information about you from the following sources:

1. Applications or other forms we receive from you, or in interviews with you. This Information may include your name and addresses, personal financial situation and your investment objectives, among other things.
2. Our affiliates or third parties providing service to your account. This may include Information about your transactions with us.
3. Unaffiliated third parties.

Sharing Information: We do not sell the Information that we collect about current or former clients and prospects, or their accounts to third parties. We may share all of the Information described above:

1. With our financial services affiliates in order to provide you with services you request.
2. With non-affiliated companies (like custodians and transfer agents) to the extent necessary to process and service your accounts.
3. With non-affiliated companies with whom we may contract to provide us certain services, such as printers, mail houses, database management companies, and e-mail archiving services. These companies are provided with only the Information we believe that they need to perform their services.

In addition, we may release Information to non-affiliated third parties at your request, in response to a subpoena, to prevent fraud or for other non-marketing purposes as permitted by law.

Protecting Information: We restrict access to Information to those people whom we believe have a legitimate business purpose to access such Information. We have also adopted physical, electronic and procedural safeguards that comply with federal standards to protect the confidentiality of your Information.

Changes to this Privacy Policy: We may change or replace this Privacy Policy at any time. If we make material changes, we will provide current clients with a revised notice that describes our new practices and will post a notice of the change (or amended Privacy Policy) at the www.alphagenco.com Web site.