March 2011 Privacy Notice

Protecting Your Privacy

At Private Advisors, LLC (“PA”) maintaining our customers’ trust and confidence is of paramount importance. We are committed to safeguarding your personal information and providing you with facts and options about how this information may be shared. Please read this notice to learn more about our privacy policies and the options available to you.

This notice replaces all previous statements of our consumer privacy policy, and may be amended at any time. We will provide you with annual reminders of our policies and with revised policies if there are any changes in how we handle your personal information. If you end your relationship with PA, we will continue to adhere to the policies and practices described in this notice.

Information That We Collect. As part of providing you with our services, we obtain nonpublic personal information about you, which may include the following:

Information we receive from you on applications or other forms including name, address, social security number, assets and income.
Information about your transactions with us or others.

Information That We Share & Why It Is Important. We use or share information in a limited and carefully controlled manner. We do not disclose any nonpublic information about our customers or former customers to anyone, except as permitted by law, unless authorized by you. Instances in which we may share your information with nonaffiliated third parties include:

Inclusion of certain names (institutional clients only) on a Representative Client List. The Representative Client List is contained in our standard marketing material and examples of those who may receive the list include: existing clients, prospective clients, consultants for prospective clients and prospective hedge fund managers. The majority of PA’s assets under management are institutional assets. As a result, institutional assets in general are perceived as stable capital sources and hedge fund managers tend to be biased towards favoring these assets. As we meet with prospective hedge fund managers, we believe our Representative Client List gives PA an advantage when trying to gain access to funds that accept capital on a limited basis.
(NOTE: The Representative Client List includes language stating that the names on the list are not to be construed as an endorsement or recommendation of PA’s services.)
Disclosure to companies that provide services necessary to effect a transaction that you request or to service your account such as prime brokers, accountants, banks, attorneys or administrators.
Disclosure to government agencies, courts, parties to lawsuits, or regulators in response to subpoenas. In such cases, we share only the information that we are required or authorized to share.

Confidentiality and Security.
The security of your account information is important to us. Only those persons who need your information to perform their job have access to it. In addition, we maintain physical, electronic and procedural security measures that comply with federal regulations to protect your information. Our employees have limited access to your personal information based upon their responsibilities. All employees are instructed to protect the confidentiality of your personal information as described in these policies, which are strictly enforced.

Opportunity to “Opt-Out.”
If you prefer that we not disclose nonpublic personal information about you to nonaffiliated third parties (through our Representative Client List), you may “opt out” of those disclosures. This means that you may direct us not to include your name on our Representative Client List (other than disclosures permitted by law). If you wish to opt out of disclosures to nonaffiliated third parties, you may call our Chief Compliance Officer at PA’s main number: (804) 289-6000. You may exercise this right to opt out at any time.

If you have any questions about this Privacy Notice, you may call us at (804) 289-6000.