Privacy Policy

Hilltop Residential LLC

PROTECTION OF INVESTOR INFORMATION AND PRIVACY POLICY

Purpose

Hilltop Residential has developed these policies and procedures in order to protect the privacy of existing and prospective investors, and to comply with Hilltop Residential’s obligations under applicable federal and state laws and regulations.

Protecting Privacy of Existing and Prospective Limited Partners

No confidential information regarding any limited partner or prospective limited partner, may be disclosed except as follows:

• To other employees in connection with Hilltop Residential’s business.

• To an affiliate, but the affiliate may disclose the information only to the same extent as Hilltop Residential is permitted to do so. For avoidance of doubt, Hilltop Residential shall not use information about individual limited partners that was obtained from affiliates for any joint marketing purposes.

• To service and maintain limited partner accounts.

• When the party to which information is being disclosed is subject to a Hilltop Residential confidentiality agreement.

• When authorization has been given, whether verbally or in writing, by the limited partner or prospective limited partner at issue.

• As required by law.

“Confidential Information” means any and all information, whether written or oral, tangible or intangible, and whether or not marked as confidential or proprietary, of or concerning client or potential client, which client or potential client treats as confidential or proprietary and that is not known by others.

Hilltop Residential encourages employees to be aware of and sensitive to their treatment of confidential information.

Hilltop Residential will send its privacy policy within its subscription agreements to each limited partner.

Violation of the procedures set forth herein will subject the violating employee to disciplinary action, including possible termination.

Initial Privacy Notice

Brooke Mirabi and/or Peter Hand is responsible for ensuring that notices of Hilltop Residential’s privacy policy is provided to each prospective investor no later than the time that he or she becomes an investor in a fund. The Director of Compliance is responsible for periodic testing to ensure compliance.

Hilltop Residential LLC

Annual Privacy Notice

Hilltop Residential ensures that the notices pertaining to its privacy policy is provided to each current investor no less often than annually. The Director of Compliance is responsible for periodic testing to ensure compliance.

Notice Regarding Privacy of Financial Information

The following notice is provided to each limited partner within the subscription agreement initially and on an annual basis:

We are providing this notice to you to comply with the requirements of Regulation S-P, issued by the United States Securities and Exchange Commission. Accordingly, set forth below is our policy regarding disclosure of nonpublic personal information about our clients.

We do not disclose nonpublic personal information about our partners or former partners to third parties except as described below.

We collect certain nonpublic information about you in a number of ways, such as from our discussions with you, from documents such as subscription agreements that you deliver to us and in the course of providing services to you.

In the normal course of serving our partners and effecting transactions for the partnerships, we may share your personal information with: companies that perform services on the partnerships’ behalf, such as accountants, auditors, and attorneys; where applicable, fund administrators and transfer agents; and, as permitted or required by law, regulatory agencies, or other third parties. These parties are to use the information only for the services required of them and as allowed by applicable law or regulation, and are not to share or use it for any other purpose.

We maintain appropriate physical, electronic, and procedural safeguards that comply with federal standards to safeguard your personal information. We reserve the right to change our privacy policy at any time.

This notice is for your information only and requires no action on your part.