Privacy Policy

PALINGENIX EQUITY, LP

NOTICE REGARDING PRIVACY OF FINANCIAL INFORMATION

Pursuant to Regulation P, 12 C.F.R. 1016, adopted by the Consumer Financial Protection Bureau and Regulation S-P, 17 C.F.R. 248.1 – 248.30, adopted by the U.S. Securities and Exchange Commission, we are providing this notice to you in order to inform you of our privacy policies and practices with respect to your nonpublic personal information so that you will know the type of information that we collect about you and the circumstances in which that information may be disclosed to third parties.

Palingenix Equity, LP (“Palingenix”) understands that it is our obligation to maintain the confidentiality of information with regard to our investors generally. We are committed to maintaining the privacy, integrity and security of our current and former limited partners’ nonpublic information. As a consequence, we do not disclose any nonpublic personal information about our investors or former investors to anyone other than:

our affiliates and service providers;

as permitted or required by law, or in connection with any government or self-regulatory organization request, examination or investigation; and

if you direct us to do so.

We also do not transfer or license your information to any third party, or permit any third party to use your information, for their own marketing purposes, or the marketing purposes of any other third party. Furthermore, consistent with industry practice, and the provisions of our fund agreements, we may continue to distribute certain personally-identifiable financial information, such as a list of investors, to all investors in a specific fund. In order to accurately and efficiently conduct each fund’s investment program, we must collect and maintain certain nonpublic information about you and such fund’s other investors.

Security of Nonpublic Information

We consider the protection of sensitive personal information to be a sound business practice and we intend to continue to scrupulously guard the privacy of our investors. We restrict access to nonpublic personal information about you to those employees and service providers who need to know that information to provide services to our funds and our investors. Any party that receives this information will use it only for the services required and as allowed by applicable law or regulation, and is not permitted to share or use this information for any other purpose. We and our service providers maintain physical, electronic and procedural safeguards to guard your nonpublic personal information. In addition, we will continue to assess new technology for protecting information with regard to our investors.

Collection of Information and Disclosures to Affiliates and Service Providers

We collect, and may disclose to our affiliates and service providers (e.g., our attorneys, accountants, consultants, transfer agents, brokers, administrators and other entities that provide back-office services to us) on a “need to know” basis, certain nonpublic personal information about you from the following sources:

information we receive from you as set forth in your subscription agreement and exhibits thereto or similar forms, such as your name, address and social security or tax identification number; and

information about your transactions with us, our affiliates and service providers, or others, such as your participation in each of our funds, your capital account balance, contributions and distributions and, in the case of an investor that is an individual retirement account, information with regard to such account.

In connection with fundraising efforts for future funds, we may disclose information about existing investors to one or more placement agents for use in marketing efforts, including communication with prospective future investors. In the event of a change in corporate control resulting from, for example, a sale to, or merger with, another entity, or in the event of a sale of assets, we reserve the right to transfer your information, including nonpublic personal information, to the new party in control or the party acquiring such assets.

We will provide notice of our privacy policy annually to natural persons and individualized retirement accounts, as long as such persons maintain an investment with us. We reserve the right to modify this policy at any time and will keep you informed of material changes. You can always review our current policy by asking us for a copy.

This privacy policy applies to all of the Palingenix sponsored funds, including all such funds bearing the “Palingenix” name.