Last Revised November 2013


This notice describes the privacy policies of CVR and its affiliated entities and investment funds, (collectively referred to in this notice as “CVR”).  Federal law requires us to tell you how we collect, share, and protect your non-public personal information.  This notice applies to any individual that invests in CVR’s investment funds (“Investor”) and is subject to change.  CVR provides Investors with a Privacy Notice as part of their subscription materials and annually after that.  CVR does not share non-public personal information about its Investors, prospective Investors, or former Investors with third parties other than as described below or as otherwise required or permitted by law.  Please read this notice carefully to understand what we do.  If you have any questions about this notice, please contact Peter Higgins, CVR’s Chief Compliance Officer.

What personal information CVR collects and how CVR collects this information. CVR collects non-public personal information about Investors in connection with the advisory services CVR provides to Investors.  This information may include:

  • information we receive in subscription documents, investment management agreements, investor questionnaires and other forms which Investors complete and submit to us, such as your name, date of birth, address, phone number, email address, social security number, tax identification number, employment, net worth, income,  assets, investment experience and other financial and household information;
  • information we receive and maintain relating to your capital account, such as profit and loss allocations and capital withdrawals and additions;
  • information about your investment in and other transactions with CVR, including information we receive and maintain relating to new issue and other securities transactions with and through CVR;
  • information you may provide us about where to send money, such as wire transfer instructions; and
  • information we receive about an Investor from the Investor’s purchaser representative, financial advisor, investment consultant or other financial institution with whom CVR has a relationship and/or whom you may have authorized to provide such information to CVR.

How CVR uses this information.  CVR may use this information to provide advisory services to Investors, which may include the opening of accounts and other actions necessary to effect Investors’ advisory transactions.  CVR may also use this information to market products and services to you.  Further, CVR may use this information to respond to court orders, government or self-regulatory organization requests or investigations, or as otherwise required by law.

How CVR shares this information.  In connection with providing Investors with advisory services and effecting Investors’ transactions, CVR may share your non-public personal information with non-affiliated third parties that assist us in servicing your account and have a need for such information, for example:

  • financial service providers, such as brokers, custodians, transfer agents, banks, fund administrators and compliance/operational support providers;
  • persons acting in a fiduciary or representative capacity on behalf of an individual Investor, such as an IRA custodian or Trustee of a grantor trust; and
  • CVR’s legal representatives, such as our counsel, accountants and auditors.

When it is necessary for CVR to share your non-public personal information with non-affiliated third parties, CVR requires or will require all such parties to protect the confidentiality of your non-public personal information.  We require that such information only be used for the limited purpose for which it is shared, and will advise these parties not to further share your information with others except to fulfill that limited purpose.  These sharing practices are consistent with Federal and state privacy and related laws, and in general, you may not limit our use of your personal information for these purposes under such laws.  If CVR changes how it handles your personal information to permit disclosures to additional types of third parties, you will be notified in advance, and if required by law, you will be given the opportunity to direct us not to share your personal information with such parties.

How CVR protects your personal information.  CVR takes its responsibility to protect the privacy and confidentiality of Investors’ non-public personal information very seriously.  To protect your personal information from unauthorized access and use, we use security measures that comply with state and Federal law.  We restrict access to your personal information to our employees who need to know such information to provide products or services to you.  We also maintain appropriate physical, electronic and procedural safeguards.