Privacy Policy

In the course of serving you as an individual joint venture/employment applicant or as someone associated with a corporate or institutional joint venture applicant or a person seeking additional information about Freehold, We may obtain personal information about you. Obtaining this information is important to our ability to deliver the highest level of service to you, but we also recognize that you expect us to treat this information appropriately.

This Policy describes the types of personal information we may collect about you, the purposes for which we use the information, the circumstances in which we may share the information, and the steps that we take to safeguard the information to protect your privacy. As used throughout this Policy, the term Freehold refers to Freehold Capital Partners, Inc., and its subsidiaries, affiliates and third party providers worldwide.

The Sources of Information

The personal and property information we collect about you comes primarily from the account applications, orders, or other forms and materials you submit to Freehold Capital Partners during the course of your relationship with us. We may also collect information about your transactions and experiences with Freehold Capital Partners relating to the products and services we provide directly or through our affiliates, independent agents or third party providers. In addition, depending on the nature of your relationship with Freehold Capital Partners we may obtain additional information about you, such as your credit history, from consumer reporting agencies.

The Information We Have About You

If you deal with Freehold Capital Partners in your individual capacity, or as a settlor/trustee/beneficiary of a trust, or as an owner or principal of a company or other investment vehicle established to invest on your behalf or on behalf of your family, etc., the typical information we collect about you would include:

• Your name, address and other contact details;
  
• Your age, date of birth, and personal identifier such as, depending on your country of residence, your Social Security Number, EIN, etc.
  

If you are an employee/officer/director/principal, etc. of one of our corporate or institutional joint venture participants, the typical information we collect about you personally would include:

• Your name and contact details;
  
• Your role/position/title and area of responsibility; and
  
• Certain identifying information (e.g., your Social Security Number, passport number, etc.) as required by laws and regulations addressing money laundering and related matters.
  

Of course, you are not required to supply any of the personal information that we may request. While we make every effort to ensure that all information we hold about you is accurate, complete, and up to date, you can help us considerably in this regard by promptly notifying us if there are any changes to your personal information.

Our Use of Your Personal Information

We may use your personal information to:

• Administer, operate, facilitate and manage your relationship and/or account with Freehold Capital Partners. This may include sharing such information internally as well as disclosing it to third parties, as described in the following two sections, respectively;
  
• Contact you or, if applicable, your designated representative(s) by post, telephone, electronic mail, facsimile, etc., in connection with your relationship and/or account;
  
• Provide you with information, recommendations, or advice concerning products and services offered by Freehold Capital Partners; and
  
• Allow others to undertake due diligence, audits, appraisals, valuations or investigations of instruments or assets in which we have an ownership interest, including transfer fee instruments or orders related thereto; and
  
• Facilitate our internal business operations, including assessing and managing risk and fulfilling our legal and regulatory requirements.
  

If your relationship with Freehold Capital Partners ends, we will continue to treat your personal information, to the extent we retain it, as described in this Policy.

Disclosures of Your Personal Information Within Freehold Capital Partners

In order to provide efficient and reliable services, and to improve product and service options available to you, more than one entity within Freehold Capital Partners may be given, or given access to, your personal information. When so sharing your personal information, we adhere to applicable legal and industry standards regarding the protection of personal information.

Disclosures of Your Personal Information to Third Parties

Freehold Capital Partners does not disclose your personal information to third parties, except as described in this Policy. Third party disclosures may include sharing such information with non-affiliated companies that perform support services for your account or facilitate your transactions with Freehold Capital Partners, including those that provide professional, legal, or accounting advice to Freehold Capital Partners. Non-affiliated companies that assist us in providing services to you are required to maintain the confidentiality of such information to the extent they receive it, and to use your personal information only in the course of providing such services and only for the purposes that Freehold Capital Partners dictates.

We may also disclose your personal information to fulfill your instructions, to protect our rights and interests and those of our business partners, or pursuant to your express consent. Finally, under limited circumstances, your personal information may be disclosed to third parties as permitted by, or to comply with, applicable laws and regulations, for instance, when responding to a subpoena or similar legal process, to protect against fraud, and to otherwise cooperate with law enforcement or regulatory authorities, or with organizations such as exchanges and clearinghouses.

You should know that Freehold Capital Partners will not sell your personal information.

Other Privacy Policies or Statements; Changes to Policy

This Policy provides a general statement of the ways in which Freehold Capital Partners protects your personal information. This Policy may be changed from time to time to reflect changes in our practices concerning the collection and use of personal information. The revised Policy will be effective immediately upon posting to our Web site. This version of the Policy is effective November 26, 2007.