Capital Markets

Privacy Policy

Guggenheim Capital Markets, LLC (“Guggenheim”) recognizes how important it is for you to feel confident in the knowledge that your personal financial information is secure. We are committed to protecting and safeguarding the personal and financial information that you have entrusted to us.

In the course of doing business with investors, Guggenheim collects confidential information about investors. “Confidential personal information” is financial and any other information about our investors that is non-public and personally identifiable. Non-public personal information may include, for example, your address, telephone number, social security number or tax identification, the amount of your investments, representations about your assets and income you made, and representations of sources of your funds.

Guggenheim collects such confidential information from investors in order to determine the proper asset allocation to match the investor’s objectives. Guggenheim collects this information from the following sources:

• Subscription agreements or other forms or agreements on which you provide information
• Mail, e-mail, and the telephone
• Your transactions and investment activity (for example, your investments in private placements), and capital account inquiries with us, our service providers, or others
• Information you provide orally
• Other sources with your consent or with the consent of your representative (for example, from other institutions such as credit reporting agencies)

In addition, when you visit Guggenheim’s Internet site at www.guggenheimcm.com (“Website”), we may collect technical and navigational information, such as computer browser type, Internet protocol address, pages visited, and average time spent on our Website. This information may be used, for example, to alert you to software compatibility issues, or it may be analyzed to improve our Website design and functionality. When you use the contact features of the Website, you consent to the review and internal use of your communication by Guggenheim.

What information Guggenheim will disclose and to whom Guggenheim will disclose that information.
Guggenheim may disclose confidential information about investors as may be permitted or required by applicable laws or regulations. Accordingly, it may disclose confidential information about investors

• to government entities, in response to subpoenas or to comply with applicable laws or regulations;
• when investors instruct, or consent to, Guggenheim making such disclosure;
• to affiliates, including affiliated service providers;
• to service providers that perform services for Guggenheim, including third-parties such as our external auditors, outside counsels, and service providers that process or service Guggenheim transactions (including custodians, broker-dealers, prime brokers, third party administrators and banks).

Information about former investors.
If an investor no longer invests with, or through, Guggenheim, we will adhere to the privacy policies and practices described in this notice.

How Guggenheim safeguards information:
Within Guggenheim, access to confidential information about investors is limited to our employees, affiliates and in some cases to third parties (for example, the service providers described above) as may be permitted or required by applicable laws or regulations. We restrict access to nonpublic personal information about you to those employees who need to know that information to provide products or services to you. We maintain physical, electronic, and procedures safeguards that comply with federal regulations to guard your nonpublic personal information. With respect to information given on the Internet, Guggenheim uses a variety of proven protections to maintain the security of your online session. This may include the use of firewall barriers, encryption techniques and authentication procedures. We also use cookies and similar files that may be placed on your hard drive for security purposes, to facilitate site navigation and to personalize the appearance of our site. If this Privacy Policy changes in any way, you will be notified through appropriate means. If you have questions or comments about our privacy policy, please call us at (212) 651-0860 for further information or explanation.

Application of this Privacy policy
Please note that this Guggenheim Privacy policy does not apply to any Web pages hosted by other companies to which we may link and whose privacy policies may differ. This website is operated in the United States subject to applicable U.S. laws; any personal information obtained by this website will be transmitted to the United States.