BROADRIVER PRIVACY NOTICE

BroadRiver Asset Management, L.P. (“BroadRiver,” “we” or “us”) is committed to protecting your privacy and maintaining the confidentiality and security of your personal information. This privacy notice (“Privacy Notice”) explains the manner in which BroadRiver collects, utilizes and maintains nonpublic personal information of individuals who disclose such information to us, including prospective, current and former fund investors. This Privacy Notice only applies to products and services provided by BroadRiver to individuals and which are used for personal, family, or household purposes (not business purposes). Please read this Privacy Notice carefully to understand what we do.

Collection of Individual Information

BroadRiver collects personal information about individuals from the following sources:

  1. Subscription forms, investor questionnaires, account forms, and other information provided by the fund investor in writing, in person, by telephone, electronically or by any other means. This information includes name, address, nationality, employment information, and financial and investment qualifications;
  2. Transactions within the funds managed by BroadRiver, including account balances, investments, withdrawals and fees; and
  3. Other interactions with BroadRiver (for example, discussions with our staff).

Disclosure of Nonpublic Personal Information

BroadRiver may share nonpublic personal information about individuals, including prospective, current and former fund investors, with affiliates, as permitted by law. BroadRiver does not disclose nonpublic personal information about individuals to nonaffiliated third parties, except as permitted by law (for example, to service providers who provide services to a fund investor or the fund investor’s account).

BroadRiver may share nonpublic personal information, without an individual’s consent, with affiliated and nonaffiliated parties in the following situations, among others:

  1. To respond to a subpoena or court order, judicial process or regulatory inquiry;
  2. In connection with a proposed or actual sale, merger, or transfer of all or a portion of its business;
  3. To protect or defend against fraud, unauthorized transactions (such as money laundering), lawsuits, claims or other liabilities;
  4. To service providers of BroadRiver in connection with the administration and operations of BroadRiver, its funds and other BroadRiver products and services, which may include attorneys, accountants, auditors, administrators or other professionals;
  5. To assist BroadRiver in offering BroadRiver affiliated products and services to individuals; and
  6. To process or complete transactions requested by an individual.

Protection of Individual Information

BroadRiver maintains physical, electronic and procedural safeguards that comply with federal standards to protect customer information. BroadRiver restricts access to the personal and account information of individuals to those employees who need to know that information in the course of their job responsibilities. BroadRiver will destroy, erase or make unreadable data, computer files and documents containing nonpublic personal information prior to disposal.

Further Information

BroadRiver reserves the right to change its privacy policy at any time. The examples contained within this Privacy Notice are illustrations and are not intended to be exclusive. This privacy policy complies with federal law regarding privacy. You may have additional rights under other foreign or domestic laws that may apply to you. If you have any questions about this Privacy Notice or our privacy policies, please email BroadRiver Asset Management, L.P.’s General Counsel at counsel@broadrivercap.com.