Privacy

Last Reviewed On: March 26, 2025

BroadRiver (as defined below) is committed to protecting your privacy and maintaining the confidentiality and security of your personal information. This BroadRiver Privacy Policy (“Privacy Policy”) explains the types of information we collect through www.broadrivercap.com (“Site”), and through subscription forms, investor questionnaires, account forms and other information that is provided to BroadRiver. This Privacy Policy also explains the manner in which BroadRiver collects, utilizes, shares, discloses and maintains nonpublic personal information about its current, prospective and former investors (“Investors” or “you”), as required under applicable data protection laws.

“BroadRiver” collectively refers to BroadRiver Asset Management L.P., its affiliates and each fund (individually a “Fund,” and collectively, the “Funds”) for which any of the foregoing serves as general partner, manager, managing member, director, trading manager and/or investment adviser. This Privacy Policy only applies to products and services provided by BroadRiver to individuals (including regarding investments in the Funds) and which are used for personal, family, or household purposes (not business purposes). As BroadRiver’s business evolves, this Privacy Policy may change, so check back to this page periodically to make sure you understand how your Personal Information will be treated.

What Information Is Collected?

“Personal Information” is information that can be used to identify you as an individual or allow someone to contact you, as well as information attributed with such information. The categories of Personal Information we may collect include names, residential or business addresses, or other contact details, signature, nationality, tax identification or passport number, date of birth, place of birth, photographs, copies of identification documents, bank account details, information about assets or net worth, credit history, information on investment activities, or other personal information, such as certain special categories of Personal Information (including, where relevant, information on political affiliations, ethnic origin, or criminal convictions), as specified under the applicable data protection laws, that may be contained in the relevant materials, documents, or obtained through background searches. We collect different categories of Personal Information from different sources, including user-provided information and site usage information.

How We Collect Personal Information

BroadRiver collects Personal Information about its Investors from the following sources:

1. Subscription forms, investor questionnaires, account forms, and other information provided by the Investor in writing, in person, by telephone, electronically or by any other means;

2. Transactions within the Funds, including account balances, investments, withdrawals and fees; and

3. Other interactions with BroadRiver affiliates, service providers or other third party sources (for example, communications with our staff, administrators, tax authorities, etc.).

Web Site Usage Information

As is the case with many Web sites, BroadRiver’s servers may automatically collect your IP address when you visit our Site, and we may associate that with your domain name or that of your Internet access provider. We may also capture certain “clickstream data” pertaining to your Site usage. Clickstream data includes, for example, information about your computer or device, Web browser and operating system and their settings, the referring page that linked you to the Site, the pages, content or ads you see or click on during your visit and when and for how long you do so, items you download, the next Web site you visit when you leave the Site, and any search terms you have entered on the Site or a referral site.

Among other things, this information enables us to generate analytics reports on the usage of our Site. To opt-out of your Site usage being included in our Google Analytics reports, you may follow these instructions: https://tools.google.com/dlpage/gaoptout

In addition, we may deploy various tracking technologies on the Site to collect additional information about your Site visits. For example:

· Cookies are small data files stored on your computer or device at the request of a Web site. A cookie assigns a unique numerical identifier to your Web browser, and may enable us to recognize you as the same user who was at our Site in the past, and relate your use of the Site to other information about you, such as your Site usage information and Personal Information. Cookies may also be used to enhance your experience on the Site (for example, by storing your username so you can log in easily, keeping you logged into the Site after you have provided your password, and storing the contents of your shopping cart as you browse) or to collect general usage and aggregated statistical information and detect and prevent fraud. Most browsers can be set to detect cookies and give you an opportunity to reject them, but refusing cookies may, in some cases, inhibit or preclude your use of the Site or its features.

· A pixel tag (also known as a “clear GIF” or “web beacon”) is a tiny image – typically just one-pixel – that can be placed on a Web page or in our electronic communications to you in order to help us measure the effectiveness of our content by, for example, counting the number of individuals who visit us online or verifying whether you’ve opened one of our emails or seen one of our Web pages.

These tracking technologies may be deployed by us and/or by our service providers or partners on our behalf. These technologies enable us to assign a unique number or identifier to you, and relate your Site Usage Information to other information about you, including your Personal Information. These technologies also enable us to recognize you when you access our Site using different Web browsers and different computers or devices.

How is Your Information Used?

We may process your personal data for the purposes of administering the relationship between you and us (including subscription acceptance, communications and reporting), marketing of our products and services, monitoring and analysing our activities, and complying with applicable legal or regulatory requirements (including anti-money laundering, fraud prevention, tax reporting, sanctions compliance, or responding to requests for information from supervisory authorities, or law enforcement agencies).

We will use one of the permitted grounds under the applicable data protection laws to process your personal information. Such grounds include, for example, circumstances where:

· processing is necessary to perform our obligations under the Fund documents;

· we are required to comply with a legal or regulatory obligation applicable to us; or

· we, or a third party on our behalf, have determined that it is necessary for our legitimate interests to collect and use your personal information, such as if we believe that you have a reasonable expectation for us or a third party to collect or use your personal information for such purpose.

BroadRiver or our service providers may use the Personal Information we collect from and about you to perform the following business functions:

· enabling users to use our Site and its features

· administering the Site and your account with us, including verifying approved access to deal datarooms, for example

· responding to your requests, questions, and concerns

· market research and better understanding our audience

· developing new features and offerings on the Site

· increasing the functionality and user-friendliness of the Site

· protecting our rights and property

· recovering debt and preventing fraud

· other purposes disclosed when Personal Information is submitted to us

To perform the above functions, we may match information collected from you through different means or at different times, including both Personal Information and Site Usage Information, and use such information along with information obtained from other sources (including third parties) such as demographic information and updated contact information. We or our service providers may also use your information to assess the level of interest in, and use of, the Site, our e-mails and our other messaging campaigns both on an individual basis and in the aggregate.

How is Your Personal Information Shared?

BroadRiver may share nonpublic personal information about its Investors or potential Investors with affiliates, as permitted by law. BroadRiver does not disclose nonpublic personal information about its Investors or potential Investors to nonaffiliated third parties, except as permitted by law (for example, to service providers who provide services to the Investor or the Investor’s account).

BroadRiver may share nonpublic personal information, without an Investor’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 or to comply with applicable legal or regulatory requirements;

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, the Funds and other BroadRiver products and services, which may include but are not limited to attorneys, accountants, auditors, administrators or other professionals;

5. To assist BroadRiver in connection with a with a corporate change or dissolution, including for example a merger, acquisition, reorganization, consolidation, bankruptcy, liquidation, sale of assets or wind down of business;

6. To assist BroadRiver in offering BroadRiver affiliated products and services to its Investors; and

7. To process or complete transactions requested by an Investor.

Data Subject Rights Under European Law

If you are a natural person in the European Union (a “Data Subject”), you may have certain rights under EU General Data Protection Regulation and equivalent regulation in effect in the United Kingdom (“GDPR”) (in addition to those described in this Privacy Policy. These rights include: (i) the right to request access to your Personal Information; (ii) the right to request rectification of your Personal Information; (iii) the right to request erasure of your Personal Information (the “right to be forgotten”); (iv) the right to restrict our processing or use of your Personal Information; (v) the right to object to our processing or use where we have considered this to be necessary for our legitimate interests (such as in the case of our marketing activities); (vi) where relevant, the right to request the portability of the data; (vii) if your consent to processing has been obtained, the right to withdraw your consent at any time; and (viii) the right to lodge a complaint with a supervisory authority. Please note that the right to be forgotten that applies in certain circumstances under GDPR is not likely to be available in respect of the Personal Information we hold, given the purpose for which we collect such data, as described above.

Due to the international nature of our business, your Personal Information may be transferred to jurisdictions that do not offer equivalent protection to personal data as under the GDPR (“Third Countries”). In such cases, we will process Personal Information (or procure that it be processed) in the Third Countries in accordance with the requirements of GDPR, which may include having appropriate contractual undertakings in legal agreements with service providers who process Personal Information on our behalf in such Third Countries. We may also be required to transfer your Personal Information to our regulators or government agencies in Third Countries in cases where such transfers are necessary in the context of administrative proceedings, such as requests for information, examinations or investigations, or to other relevant parties in Third Countries where it is necessary for the purposes of establishing, bringing, or defending legal claims, or for another legitimate business purpose, such as compliance with our legal or regulatory obligations under foreign law.

As a Data Subject, you should use the contact information below to get more information and/or to make a formal request. To the extent applicable, we will endeavor to keep the Personal Information we store about you reasonably accurate and up-to-date by enabling you to correct it by request. However, if you are a Data Subject resident in the European Economic Area, your personal information will be processed in the United States as described herein by BroadRiver and may not offer the same level of protections of personal information as GDPR. Please be advised that certain aspects of the GDPR may not be consistent with the laws and regulations applicable to BroadRiver. You may have additional rights under other foreign or domestic laws that may apply to you.

Additional Information under the U.S. Gramm-Leach-Bliley Act 1999 (Reg S-P) and Fair Credit Reporting Act (Reg S-AM)

For purposes of U.S. federal law, this Privacy Notice applies to current and former investors who are individuals or Individual Retirement Accounts. We are providing this additional information under U.S. federal law.

We may disclose information about our investors, prospective investors or former investors to affiliates (i.e., financial and non-financial companies related by common ownership or control) or non-affiliates (i.e., financial or non-financial companies not related by common ownership or control) for our everyday business purposes, such as to process your transactions, maintain your account(s) or respond to court orders and legal investigations. Thus, it may be necessary or appropriate, under anti-money laundering and similar laws, to disclose information about the Fund’s investors in order to accept subscriptions from them. We will also release information about you if you direct us to do so.

We may share your information with our affiliates for direct marketing purposes, such as offers of products and services to you by us or our affiliates. You may prevent this type of sharing by contacting us at 212 486-0600.

If you are a new investor, we can begin sharing your information with our affiliates for direct marketing purposes 30 days from the date we sent this Privacy Notice. When you are no longer our investor, we may continue to share your information with our affiliates for such purposes.

You may contact us at any time to limit our sharing of your personal information. If you limit sharing for an account you hold jointly with someone else, your choices will apply to everyone on your account. U.S. state laws may give you additional rights to limit sharing.

We do not share your information with non-affiliates for them to market their own services to you. We may disclose information you provide to us to companies that perform marketing services on our behalf, such as any placement agent retained by the Funds

Protection of Investor 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 Investors 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.

Changes to this Privacy Policy and Further Information

BroadRiver reserves the right to change this Privacy Policy at any time. When we do, we may let you know by posting the changed Privacy Policy on this page with a new “Effective Date.” In some cases (for example, if we significantly expand our use or sharing of your Personal Information), we may also tell you about changes by additional means, such as by sending an e-mail to the e-mail address we have on file for you. In some cases, we may request your consent to the changes.

Contact us

If you have any questions about this Privacy Policy, please contact us at 212 486-0600 and/or email us at ir@broadrivercap.com.

Please note that the administrator, broker and custodians engaged by BroadRiver work under a range of professional and legal obligations that require them to process personal data (e.g., anti-money laundering legislation). In order to meet the requirements of such obligations, they, from time to time, would not be acting on our instructions but instead in accordance with their own respective professional or legal obligations and therefore as data controllers in their own right with respect to such processing. For more specific information or requests in relation to the processing of personal data by such service providers of the Funds, you may also contact the relevant service provider directly at the address specified in the Fund’s offering memorandum or by visiting their websites.