Privacy Policy

Last Updated and Effective January 1, 2026

CENTERBOOK PARTNERS LP (THE “MANAGER”) IS COMMITTED TO MAINTAINING THE PRIVACY OF CURRENT AND PROSPECTIVE INVESTORS IN THE CENTERBOOK FUNDS (THE “FUNDS”). THE MANAGER RECOGNIZES THAT INVESTORS IN THE FUNDS ENTRUST THE MANAGER WITH HIGHLY CONFIDENTIAL, NON-PUBLIC PERSONAL AND FINANCIAL INFORMATION (“NON- PUBLIC PERSONAL INFORMATION”), AND THE MANAGER UNDERSTANDS THAT PROTECTING AND SAFEGUARDING THIS INFORMATION IS IMPORTANT. THIS PRIVACY POLICY SETS FORTH THE PRIVACY PRACTICES OF THE MANAGER WITH RESPECT TO OUR COLLECTION, USE, SHARING, AND DISCLOSURE OF NON-PUBLIC PERSONAL INFORMATION, INCLUDING, BUT NOT LIMITED TO, NON-PUBLIC PERSONAL INFORMATION COLLECTED THROUGH OUR WEBSITE AND ANY RELATED URLS (EACH AND COLLECTIVELY, AS APPROPRIATE, THE “SITE”), HOW SUCH NON-PUBLIC PERSONAL INFORMATION IS USED, AND THE CIRCUMSTANCES UNDER WHICH SUCH PERSONAL INFORMATION MAY BE SHARED AND DISCLOSED.  THIS PRIVACY POLICY IS INCORPORATED INTO, AND IS PART OF, OUR TERMS AND CONDITIONS OF USE WHICH GOVERN YOUR ACCESS TO THE SITE AND/OR YOUR USE OF THE SITE AND OF THE CONTENT AND THE SERVICES MADE AVAILABLE ON OR THROUGH THE SITE. THIS PRIVACY POLICY CONSTITUTES A LEGALLY BINDING AGREEMENT BETWEEN YOU AND THE MANAGER THAT CONDITIONS YOUR USE OF THE SITE, WHERE AND AS PERMITTED BY APPLICABLE LAW.

IN THE COURSE OF PROCESSING AN INVESTOR’S SUBSCRIPTION AGREEMENT TO THE FUNDS AND THE MANAGER’S ONGOING DEALINGS WITH SUCH INVESTOR, THE MANAGER MAY OBTAIN NON-PUBLIC PERSONAL INFORMATION ABOUT SUCH INVESTOR. THIS INFORMATION MAY INCLUDE THE INVESTOR’S NAME, ADDRESS, TELEPHONE NUMBER, EMAIL ADDRESS, PASSPORT NUMBER, SOCIAL SECURITY NUMBER, TAXPAYER IDENTIFICATION NUMBER, BANK ACCOUNT NUMBER, TRANSACTION HISTORY AND OTHER PERSONAL INFORMATION. THE MANAGER MAY COLLECT DIFFERENT TYPES OF INFORMATION IN A VARIETY OF WAYS, INCLUDING:

INFORMATION IT RECEIVES FROM AN INVESTOR’S SUBSCRIPTION AGREEMENT, FROM OTHER FORMS AND QUESTIONNAIRES, OR OTHERWISE IN THE COURSE OF ESTABLISHING AN INVESTOR RELATIONSHIP.
INFORMATION ABOUT THE FREQUENCY OF AN INVESTOR’S OR OTHER PERSON’S USE OF THE MANAGER’S WEB SITE.
INFORMATION ABOUT AN INVESTOR’S TRANSACTIONS WITH THE FUNDS, ITS AFFILIATES OR OTHERS, SUCH AS SUCH INVESTOR’S INVESTMENT AND WITHDRAWAL HISTORY.
THE MANAGER USES THIS INFORMATION FOR MARKETING PURPOSES AS WELL AS INTERNAL ADMINISTRATION AND ANALYSIS. THE MANAGER DOES NOT DISCLOSE ANY NON-PUBLIC PERSONAL INFORMATION ABOUT INVESTORS OR FORMER INVESTORS IN THE FUNDS TO ANY NON-AFFILIATED PARTIES, EXCEPT TO THIRD PARTY SERVICE PROVIDERS WHO ASSIST IN THE OPERATION OF THE MANAGER’S AND THE FUNDS’ BUSINESS, AS REQUIRED BY LAW, AT THEIR REQUEST OR WITH THEIR CONSENT. THE MANAGER RESTRICTS ACCESS TO NON-PUBLIC PERSONAL INFORMATION TO THOSE PERSONNEL, AGENTS OR OTHER PARTIES WHO NEED TO KNOW THAT INFORMATION TO PROVIDE SERVICES TO SUCH PERSONS. THE MANAGER MAINTAINS PHYSICAL, ELECTRONIC AND PROCEDURAL SAFEGUARDS TO PROTECT NON-PUBLIC PERSONAL INFORMATION. THE MANAGER’S PRIVACY POLICY COVERS ALL INDIVIDUALS WHO ARE INVESTORS IN THE FUNDS, WHO HAVE BEEN INVESTORS IN THE FUNDS OR WHO ARE CONSIDERING AN INVESTMENT IN THE FUNDS.

WE MAY SEND TEXT FILES (E.G., “COOKIES” OR OTHER CACHED FILES) OR IMAGES TO YOUR WEB BROWSER TO COLLECT AND/OR STORE INFORMATION ON YOUR COMPUTER. SUCH TEXT FILES AND IMAGES ARE USED TO SUPPORT THE OPERATION, AND TO ENHANCE THE FUNCTIONALITY, OF OUR DIGITAL OFFERINGS AND FOR THE TECHNICAL CONVENIENCE TO STORE INFORMATION ON YOUR COMPUTER. WE MAY USE INFORMATION STORED IN SUCH TEXT FILES AND IMAGES TO CUSTOMIZE YOUR EXPERIENCE ON OUR SITE, MONITOR USE OF OUR SITE AND FOR ANONYMIZED ANALYTICS PURPOSES. YOU MAY SET YOUR BROWSER TO NOTIFY YOU WHEN YOU RECEIVE A COOKIE. MANY WEB BROWSERS ALSO ALLOW YOU TO BLOCK COOKIES. IF YOU BLOCK COOKIES YOU MAY NOT BE ABLE TO ACCESS CERTAIN PARTS OR USE ALL FEATURES OF OUR SITE. YOU CAN DISABLE COOKIES FROM YOUR COMPUTER SYSTEM BY FOLLOWING THE INSTRUCTIONS ON YOUR BROWSER OR AT HTTP://WWW.ALLABOUTCOOKIES.ORG/. WE DO NOT CURRENTLY RESPOND TO “DO NOT TRACK” SIGNALS OR OTHER MECHANISMS THAT MIGHT ENABLE USERS TO OPT OUT OF TRACKING ON OUR SITE.

FOR THE LIMITED PURPOSES OUTLINED ABOVE, THE MANAGER MAY DISSEMINATE INTERNALLY NON-PUBLIC, PERSONAL INFORMATION CONCERNING INVESTORS. HOWEVER, THE MANAGER WILL USE REASONABLE BEST EFFORTS TO ENSURE THAT SUCH INFORMATION IS TREATED IN ACCORDANCE WITH THIS PRIVACY POLICY.

BY DISCLOSING NON-PUBLIC PERSONAL INFORMATION TO THE MANAGER, THE DISCLOSING PARTY CONSENTS TO THE COLLECTION, STORAGE AND PROCESSING OF ITS NON-PUBLIC PERSONAL INFORMATION BY THE MANAGER IN A MANNER CONSISTENT WITH THIS PRIVACY POLICY.

ALTHOUGH REGULATIONS ONLY REQUIRE THAT THE FOREGOING PRIVACY POLICY BE APPLIED TO NATURAL PERSONS, THE MANAGER APPLIES THE SAME PRIVACY POLICY TO ALL INVESTORS.

THE FOREGOING PRIVACY POLICY SHALL NOT PREVENT THE MANAGER OR THE FUNDS FROM DISCLOSING TO APPROPRIATE THIRD PARTIES SUCH INFORMATION AS THE MANAGER OR THE FUNDS MAY DEEM NECESSARY OR ADVISABLE IN ORDER TO COMPLY WITH APPLICABLE ANTI-MONEY LAUNDERING AND OTHER APPLICABLE LAWS AND REGULATIONS.

OUR SERVERS ARE LOCATED IN THE U.S. OUR SERVICES ARE DIRECTED TOWARD THE U.S. MARKET, AND OUR PRIVACY POLICY COMPLIES WITH APPLICABLE U.S. LAW. IF YOU ARE AN INTERNATIONAL VISITOR, YOU SHOULD NOTE THAT BY PROVIDING YOUR NON-PUBLIC PERSONAL INFORMATION ON OR THROUGH THE SITE, YOU ARE: (1) CONSENTING TO THE TRANSFER OF YOUR PERSONAL INFORMATION FROM REGIONS OUTSIDE THE U.S. TO THE U.S., WHICH MAY NOT HAVE THE SAME DATA COLLECTION AND PROTECTION LAWS AS THE COUNTRY IN WHICH YOU RESIDE; AND (2) CONSENTING TO THE USE OF YOUR PERSONAL INFORMATION IN ACCORDANCE WITH THIS PRIVACY POLICY.

THIS SITE IS NOT INTENDED FOR, OR DESIGNED TO ATTRACT, CHILDREN UNDER THE AGE OF THIRTEEN (13). CONSEQUENTLY, WE DO NOT INTENTIONALLY GATHER INFORMATION FROM INDIVIDUALS WHO ARE UNDER THE AGE OF THIRTEEN (13). UPON NOTIFICATION THAT A CHILD UNDER THIRTEEN (13) HAS PROVIDED US WITH PERSONALLY IDENTIFIABLE INFORMATION, WE WILL DELETE THE CHILD’S PERSONALLY IDENTIFIABLE INFORMATION FROM OUR RECORDS.

WE RESERVE THE RIGHT AT ANY TIME TO UPDATE THIS PRIVACY POLICY WITHOUT ANY NOTICE TO YOU. IF WE UPDATE THE PRIVACY POLICY, WE WILL INDICATE AT THE TOP OF THE PAGE THE DATE THE PRIVACY POLICY WAS LAST UPDATED. ANY SUCH UPDATES WILL BE EFFECTIVE IMMEDIATELY UPON POSTING ON THE SITE. EACH TIME YOU USE THE SITE, THE CURRENT VERSION OF THIS PRIVACY POLICY WILL APPLY. YOU UNDERSTAND AND CONSENT THAT YOUR CONTINUED USE OF THE SITE AFTER WE HAVE MADE ANY SUCH UPDATES CONSTITUTES YOUR ACCEPTANCE OF THE MOST CURRENT PRIVACY POLICY, AS AMENDED. YOU CAN ALWAYS REFUSE TO ACCEPT THE UPDATES TO OUR PRIVACY POLICY BY TERMINATING YOUR USE OF THE SERVICES.