Crayhill Capital Management LP and its affiliates (“Crayhill”) may collect personal information (which includes public and non-public personal information), such as name, address, social security number, birth date, assets, income and investment experience, about current, former and prospective clients and investors. This information is compiled from: (i) subscription documents and related forms and agreements completed by such persons; (ii) transactions between such persons and Crayhill (e.g., account activity and balances); and (iii) other third-party sources (e.g., credit reporting agencies).

Personal information is not shared with any unaffiliated third parties for their marketing purposes. Crayhill will use, disclose and otherwise process personal information for their business, administrative and marketing purposes. Crayhill also may reveal personal information in their possession to their regulators and appropriate government agencies, as necessary and permissible under applicable laws, in connection with legal proceedings or otherwise to assert and protect legal interests or as part of a corporate transaction with a successor or affiliate. Crayhill restricts access to such personal information to their personnel, their affiliates and affiliates’ personnel, their service providers and their outside counsel, auditors and other independent professionals who need to know that information.

Crayhill maintains appropriate administrative, technical, and organizational controls to safeguard such personal information, although such safeguards may not prevent all breaches of information security. If the security of personal information is compromised, the affected individuals will receive notice from Crayhill of the data security incident where required by and consistent with applicable law.

Individuals may exercise their rights under applicable law to access such personal information as is held by Crayhill, to rectify or delete any personal information that is factually incorrect, incomplete or irrelevant for the purpose for which it is processed and to raise any queries or concerns as to the use of their personal information by contacting Crayhill.

In order to use and disclose such personal information for the purposes described above, such personal information may be transferred internationally to countries that the United States has deemed not to provide adequate data protection. Current, former and prospective clients and investors recognize the necessity of such international processing of personal information and consent to such international transfers of personal information, including social security and taxpayer identification numbers, as Crayhill deems appropriate. Crayhill will ensure application of the same standards of privacy protection as set out in this privacy policy regardless of the country in which such personal information is processed.

The policy is effective as of March 2019. If, at any time in the future, it is necessary to disclose any personal information in a way that is materially inconsistent with this policy, Crayhill will give the relevant person written notice of the change and, where required under applicable law, obtain consent to such change.