Vardon will not disclose information concerning the Advisory Clients, investors or that of former clients or investors, such as names, addresses, social security numbers, tax identification numbers, net worth, total assets, income and other financial information necessary to determine required accreditation standards (the “Information”) except: (i) to the administrator, the Funds’ attorneys, accountants and auditors in furtherance of the Funds’ businesses and to other service providers such as brokers who may have a need for the Information in connection with providing services to the Funds, (ii) to third-party service providers or financial institutions who may be providing marketing services to the Funds, provided that such persons must agree to protect the confidentiality of the Information and use the Information only for the purposes of providing services to the Funds and (iii) as otherwise required or permitted by law. Vardon restricts access to the Information to their employees who need to know the Information to provide services to the Fund, and maintain physical, electronic and procedural safeguards that comply with U.S. federal standards to guard the Information.