©2005 Ventura Capital
Management, LLC

You are entitled to know how we protect your nonpublic personal information and how we limit its
disclosure. This privacy policy applies to individuals who invest in any of our funds (or have done
so in the past) or are otherwise an advisory client. This privacy policy describes our policies and
practices for collecting, disclosing, and safeguarding "nonpublic personal information," which may
include financial or other information about you.

Information We Collect

•        We collect nonpublic personal information about you from the following sources:

•        Information we receive from you on your investor questionnaire and subscription agreement or
other forms. This information includes, for example, your name, address, social security number,
assets and income; and

•        Information about your transactions with us, our affiliates or others, such as capital account
balances and parties to transactions.

Information We Disclose

We do not disclose your nonpublic personal information to anyone, except as permitted or required
by law.  
This means, most importantly, that we do not sell client information – whether it is
your personal information or the fact that you are our client – to anyone.
 Instead, we use
your information primarily to complete transactions that you request. For example:

•        To complete certain transactions or account changes that you request, it may be necessary to
provide identifying information to nonaffiliated third parties.

In certain instances, we may contract with nonaffiliated third parties to perform services for us and,
where necessary, disclose your information (described above) to them. In all such cases, we provide
the third party with only the information necessary to carry out its assigned responsibilities and
only for that purpose. Further, we require these third parties to treat your nonpublic information
confidentially.

Finally, we will release your nonpublic information if you direct us to do so, if we are required by
law to do so or in other limited circumstances permitted by law – for example, to protect your
account from fraud or to comply with anti-money laundering requirements.

Who Has Access to Your Personal Information

We restrict access to your nonpublic personal information to those employees and third parties who
need to know that information to provide products or services to you. We maintain physical,
electronic and procedural safeguards that comply with federal regulations to guard your nonpublic
personal information.

We Will Keep You Informed

This publication replaces all previous statements of our privacy policy. As required by law, we will
notify you annually of our privacy policy. We reserve the right to modify this policy at any time
and will keep you informed of changes.
VENTURA CAPITAL MANAGEMENT, LLC
PRIVACY POLICY