We at 380 Capital LLC., (“380 Capital”) including our relevant entities listed in respect your concerns about privacy. This Privacy Notice describes how we process the Personal Data:

• that we collect on 380capital.com and relevant entities, that are accessible through 380capital.com, and other websites or applications that may link to this Privacy Notice (the “Sites“);
• where you visit our premises;
• where you are a contact at one of our suppliers or other business partners;
• and through other data collection points or notices that reference this Privacy Notice.

We provide information on the types of Personal Data we collect, how we use the information, with whom we may share it and the choices available to you regarding our use of the information. We also describe the measures we take to protect the security of the information and how you can contact us about our privacy practices. “Personal Data” has the meaning given to it under data protection laws that apply to our processing of your information and includes any information that relates to, describes, identifies or can be used, directly or indirectly, to identify an individual, such as name, address, date of birth, personal identification numbers, sensitive personal information, and economic information).

If you are a California consumer, please see the separate document “California Consumer Privacy Statement” which supplements this Privacy Notice.

Information We Obtain

The types of information we collect concerning individuals includes:

• business and personal contact information (such as name, postal and e-mail addresses, and telephone number);
• demographic information, such as age, race, gender, and citizenship; account information, including login credentials for our Investor Portal and on our career site;
• financial and other information you provide in connection with our Investor Portal at bxaccess.com, such as date of birth, banking information, account numbers, taxpayer ID number, jurisdiction of tax residence, and certain investment-related information;
• government-issued identifiers and other information we need in order to identify you and complete necessary security and safety checks, including in connection with our products and services and where you visit our premises;
• CCTV footage on our premises for the purposes of safeguarding our customers and employees and our facilities and property;
• content (and related information) in connection with your electronic communications with us or our service providers (including by e-mail or other forms of electronic communication);
• professional details and employment data in connection with job inquiries or applications on our careers pages, such as resume/CV, current or past employment history, performance-related information (e.g., performance evaluations), talent management information (e.g., education history, professional designations, qualifications and other information about your background) and work authorization status;
• voluntary information you provide in connection with job inquiries or applications on our careers pages, including information about your political contributions (not applicable if you are based in the European Union or the United Kingdom), and diversity-related information, such as gender, race/ethnicity, sexual orientation, veteran status and disability status;
• information from third-party data providers and publicly available sources for compliance with anti-money laundering obligations, background screening and to otherwise protect our business and comply with our legal and regulatory obligations;
• information from our charitable foundation, such as details relating to your involvement with our philanthropic and charitable causes, and your charitable contributions;
• information relating to your participation in our events or similar; information from organizations that you represent and with which we have a business relationship, such as your business contact details or details of your role at the organization;
• and other information you provide to us (such as information provided by registering for e-mail alerts, filling in forms, and online registration details).

If you provide information to us about another person, you should ensure that you provide that person with this Privacy Notice and comply with any legal obligations that may apply to your provision of the information to us.

Information We Obtain by Automated Means

When you visit our Sites or open our e-mails, we may collect certain information by automated means (such as by cookies, web server logs, web beacons and JavaScript). The information we collect in this manner includes your IP address, network location, browser characteristics, device characteristics, operating system, referring URLs, information on actions taken on our Sites, and dates and times of website visits. Cookies are files that websites send to your computer or other Internet-connected device to uniquely identify your browser or to store information or settings on your device. We also may use these and similar technology in e-mails we send you to collect certain information, such as whether you opened or clicked on links in our e-mail and what content was interesting to you.

Our Sites may use cookies (such as HTTP, HTML5 and Flash cookies) as well as other types of local storage (such as browser-based or plugin-based local storage). Some of these cookies may be placed by third parties such as our service providers. Your browser may tell you how to be notified when you receive certain types of cookies and how to restrict or disable certain cookies. You also may be able to delete your Flash cookies or adjust your Flash cookie settings by visiting the Adobe Flash Website Storage Settings Panel and Global Storage Settings Panel. Please note, however, that without cookies you may not be able to use all the features of our Sites or other websites and services.

In conjunction with gathering information through cookies, our web servers may log information such as your device type, operating system type, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone in which your device is located. We also may record information such as the address of the web page that referred you to our Sites and the IP address of the device you used to connect to our Sites. We may log information about your interaction with the Sites, such as which pages you visit. To control which web servers collect information by automated means, we may place tags on our web pages called “web beacons”, which are small files that link web pages to particular web servers and their cookies. We also may send instructions to your device using JavaScript or other computer languages to gather the sorts of information described above and other details about your interactions with the Sites.

We may use third-party web analytics services on our Sites, such as those of Google Analytics. These service providers help us analyze how visitors use the Sites, including attributing site interactions to known contacts who have subscribed to receiving communications from us. The information processed for this purpose (including your IP address, CRM ID/BX ID and other information collected by automated means) may be disclosed to or collected directly by these service providers. To learn about opting out of Google Analytics, please click here.

The providers of third-party plugins and widgets on our Sites, such as embedded videos and social media sharing tools, may use automated means to collect information regarding your use of the Sites and your interactions with the plugins and widgets. This information is subject to the privacy policies or notices of the providers of the plugins and widgets.

How We Use the Information We Obtain

We may use, disclose or otherwise handle the information described in this Privacy Notice for the following purposes to:

• operate, evaluate, develop, promote, and improve our business (including developing new products and services; enhancing, improving and analyzing our products and services; managing our communications; managing our premises; and performing accounting, auditing and other internal functions);
• create and manage your account;
• manage your investments;
• comply with and enforce applicable legal requirements, relevant industry standards and our policies, including our Terms and Conditions of Use;
• protect against, identify and prevent fraud, money-laundering, breach of confidence, cyber attack, theft of proprietary materials, financial or business crimes, and other unlawful activity;
• in some cases, in order to operate, administer and improve the user’s experience of the Sites;
• provide our products and services to you;
• send you (or produce) promotional materials, newsletters and other communications, including in visual and audio form (such as videos, podcasts and seminars);
• communicate with you about, and administer your participation in, special events, programs, promotions, offers, surveys and market research;
• respond to your inquiries;
• manage your employment application, assess your qualifications and manage your employment with us –
• comply with US Equal Employment Opportunity reporting requirements and similar legal and compliance obligations – note that 380 Capital will not consider any voluntary information you provide in connection with a job inquiry or application or your choice to decline to provide such information in evaluating your qualifications for employment;
• verify your information;
• perform data analyses (including market and consumer research, demographic analyses and anonymization and aggregation of information);
• operate, schedule and facilitate online meetings, webinars and (video) conferences (for example, using Zoom and other online meeting platforms);
• record and monitor details and content of your electronic interactions with us or our service providers, to the extent permitted or required by applicable law;
• and facilitate and administer your participation our events;
• record audio and video content (for example, of our in-person or online events, training, and meetings where permitted by, and collected in accordance with, applicable data protection law).

In addition, we use information collected through cookies, web beacons, web server logs and other automated means for purposes such as (i) customizing our users’ visits to our Sites, (ii) delivering content tailored to our users’ interests and the manner in which our users browse our Sites, and (iii) managing our Sites and other aspects of our business.

CCTV may operates in some of our buildings for security and safety purposes, in accordance with applicable data protection law. Where CCTV is not operated by us, the CCTV will be under the control of the relevant building landlord, manager or operator.

We may also use the information in other ways for which we provide specific notice at the time of collection.

We will only process your Personal Data as necessary so that we can pursue the purposes described above. Where we process your Personal Data for our legitimate interests as a business or those of a third party, we do so only where we have concluded that our processing does not prejudice you or your privacy in a way that would override our legitimate interest in pursuing those purposes.

When we collect Personal Data from you, unless indicated otherwise, if we ask you for information, we need it for our business or compliance purposes. In limited circumstances, we are required to collect Personal Data to comply with a legal obligation and/or might ask you to provide information which is purely voluntary; in either case, this will be indicated to you.

If you are a former employee, worker, contractor or member of 380 Capital, we will continue to process your Personal Data for a reasonable period following the end of your employment or engagement for our legitimate business and/or our legal compliance purposes and/or for the establishment or defense of a legal claim. Further, in some instances, we may process your data to perform our obligations under the contract between us (e.g., to pay you your final salary payment after your termination date). We only carry out such processing where we have concluded that our processing does not prejudice you or your privacy in a way that would override our legitimate interests in pursuing those purposes. Your data will be retained and deleted in accordance with our retention policies and procedures (as discussed further below).

Online Tracking and Interest-Based Advertising

We and third parties acting on our behalf (such as Facebook, Twitter and LinkedIn) may collect information about your online activities over time and across third-party websites to provide you with advertising about products and services tailored to your interests. Where required by applicable law, we will obtain your consent for the processing of your Personal Data for direct marketing purposes. If you do receive direct marketing communications from us (for example, by post, e-mail, fax or telephone), you may opt-out by e-mailing support@380capital.com

You may see our ads on other websites or mobile apps because we participate in advertising networks. Ad networks allow us to target our messaging to users by considering demographic data, users’ inferred interests and browsing context. These networks track users’ online activities over time by collecting information through automated means (such as by cookies, web server logs, web beacons and other similar technologies). The networks use this information to show ads that may be tailored to individuals’ interests, to track users’ browsers or devices across multiple websites or apps, and to build a profile of users’ online browsing activities. The information our ad networks may collect includes data about users’ visits to websites and apps that participate in the relevant ad networks, such as the pages or ads viewed and the actions taken on the websites or apps. This data collection takes place both on the Sites and on third-party websites and apps that participate in the ad networks. This process also helps us track the effectiveness of our marketing efforts and tailor content relevant to your interests.

The Sites are not designed to respond to “do not track” signals received from browsers. To learn how to opt out of ad network interest-based advertising, please visit www.aboutads.info/choices, http://www.networkadvertising.org/choices/ or http://www.youronlinechoices.eu/

Information We Disclose to Others

We do not disclose Personal Data we obtain about you through the Sites or other channels covered by this Privacy Notice, except as described in this Privacy Notice. We may share your Personal Data with our affiliates and subsidiaries. Depending on the nature of our relationship with you, we also share Personal Data with service providers who perform services on our behalf (including cloud services), our financial and transaction counterparties, Philanthropic, charitable and advocacy partners, our professional advisors, and your agents and representatives. We do not authorize these persons to use or disclose the information except as necessary for the purposes for which it is provided or to comply with legal requirements.

We also may disclose information about you (i) if we are required to do so by law or legal process, (ii) to law enforcement authorities, regulators and/or other government entities and/or other competent authorities based on a lawful disclosure request, or (iii) when we believe disclosure is necessary or appropriate to prevent harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity. We reserve the right to transfer Personal Data we have about you or otherwise process in the event that we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, spin-off, dissolution or liquidation).

In addition, we may share anonymous / aggregated information with third parties, such as service providers, in order to facilitate our business operations.

Information collected through third-party plug-ins and widgets on the Sites (such as information relating to your use of a social media sharing tool) is collected directly by the providers of the plug-ins and widgets. This information is subject to the privacy policies of the providers of the plug-ins and widgets, and 380 Capital is not responsible for those providers’ information practices.

Data Transfers

We may transfer the Personal Data we collect about you to recipients in countries other than the country in which the information was originally collected. Where you are based in the UK, the EU, or another country which imposes data transfer restrictions outside of its territory, this includes transfers outside of the UK and the European Economic Area (“EEA“) or that geographical area, including to those countries in which our affiliates, group members, service providers and business partners operate, such as the U.S. Those countries may not have the same data protection laws as the country in which you initially provided the information. Where we transfer Personal Data outside of the UK, the EEA, or other territories subject to data transfer restrictions to other members of the 380 Capital group or our service providers, we will ensure that our arrangements with them are governed by data transfer agreements or safeguards, designed to ensure that your Personal Data is protected as required under applicable data protection law (including, where appropriate, under an agreement on terms approved for this purpose by the European Commission or by obtaining your consent).

Retention and Deletion of Your Information

We intend to keep your Personal Data accurate and up-to-date. We will delete the information that we hold about you when we no longer need it. We retain your Personal Data for as long as it is required by us for our legitimate purposes, to perform our contractual obligations, or where longer, such longer period as is required or permitted by law or regulatory obligations which apply to us.

We will retain your information in line with our retention policies and, in any event, for no longer than is necessary given the purpose for which it was collected, after which it will be deleted or anonymized.

Note that we may retain some limited information about you (even when we know that you have left the organization that you represent) so that we can maintain a continuous relationship with you if and when we are in contact with you again.

Your Rights and Choices

We offer you certain choices in connection with the Personal Data we collect from you. To update your preferences or submit a request, please contact us as indicated in the “How to Contact Us” section of this Privacy Notice. To the extent provided by the law of your jurisdiction or otherwise applicable to our processing of your information, you may request access to the Personal Data we maintain about you or request that we correct, amend, delete or block the information by contacting us as indicated below. Where provided by law, you may withdraw any consent you previously provided to us or object at any time on legitimate grounds to the processing of your Personal Data, and we will apply your preferences going forward.

These rights, subject to certain limitations, may include:

Rights of access, correction and deletion. You may have a right of access to the Personal Data that we hold about you, and to some related information, including the purpose for processing the Personal Data, the categories of recipients of that Personal Data to the extent it has been transferred internationally, and, where the Personal Data has not been collected directly from you, the source. You may also have the right to require any inaccurate Personal Data to be corrected or deleted.

Right to object, and portability. You can object to our use of your Personal Data for direct marketing purposes at any time and you may have the right to object to our processing of some or all of your Personal Data (and require it to be deleted) in some other circumstances. In some circumstances, you may also have a “data portability” right to require us to transfer your personal data to you or a third party, in a data portable format.

We review and verify requests to protect your Personal Data, and will action data protection requests fairly and in accordance with applicable data protection laws and principles.

If you wish to exercise any of these rights, please contact us as set out below.

Complaints.

You can also lodge a complaint about our processing of your Personal Data with the body regulating data protection in your country.

If you are a California consumer, for more information about your privacy rights, please see the section of this Privacy Notice called “California Consumer Privacy Statement.”

How We Protect Personal Data

We maintain administrative, technical and physical safeguards designed to protect Personal Data we obtain through the Sites against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.

Links to Other Websites

Our Sites may provide links to other websites for your convenience and information. These websites may operate independently from us. Linked websites may have their own privacy notices or policies, which we strongly suggest you review. To the extent any linked websites are not owned or controlled by us, we are not responsible for their content, any use of the websites, or the privacy practices of the websites.

Updates to Our Privacy Notice

This Privacy Notice may be updated periodically and without prior notice to you to reflect changes in our Personal Data practices. We will post the updated version on the Sites and indicate at the top of the Notice when it was most recently updated. Please check for any updates regularly.

How to Contact Us

If you have any questions or comments about this Privacy Notice, or if you would like us to update information we have about you or your preferences, please e-mail us support@380capital.com

Why are you seeing this notice?

You may need to provide Personal Data to us as part of your investment into an investment vehicle (as applicable, “the Fund”).

We want you to understand how and why we use, store and otherwise process your Personal Data when you deal with us or our relevant affiliates (including under applicable data protection laws). If this notice (the Data Privacy Notice) has been made available to you, you may have certain rights with respect to your Personal Data under applicable data protection laws (including as described in this Data Privacy Notice).

“Personal Data” has the meaning given to it under data protection laws that apply to our processing of your personal information, and includes any information relating to an identified or identifiable individual (such as name, address, date of birth, personal identification numbers, sensitive personal information, and economic information).

We ask that investors promptly provide the information contained in this Data Privacy Notice to any individuals whose Personal Data they provide to the Fund or its affiliates in connection with ‘know your client’ / anti-money laundering requests or otherwise.

Please read the information below carefully. It explains how and why Personal Data is processed by us.

Who is providing this notice?

380 Capital is committed to protecting and respecting your privacy.

For transparency, the 380 Capital entities on whose behalf this privacy statement is made are: (i) the Fund; and (ii) where applicable, the 380 Capital general partner, manager and/or investment adviser of the relevant Fund, in each case, with which you contract, transact or otherwise share Personal Data (together, the Fund Parties).

Where we use the terms “we”, “us” and “our” in this Data Privacy Notice, we are referring to the Fund and the Fund Parties.

Please consult your subscription documents, private placement memorandum or other offering documentation provided to you by or on behalf of the Fund Parties which will further specify the entities and contact details of the Fund Parties relevant to our relationship with you.

We welcome investors and their representatives to contact us if they have any queries with respect to the Fund Parties (in particular, which Fund Parties are relevant to their relationship with 380 Capital.

When you provide us with your Personal Data, each Fund Party that decides how and why Personal Data is processed acts as a “data controller”. In simple terms, this means that the Fund Party makes certain decisions on how to use and protect your Personal Data – but only to the extent that we have informed you about the use or are otherwise permitted by law.

Where your Personal Data is processed by an entity controlled by, or under common control with, the 380 Capital entity/ies managing a Fund for its own purposes, this entity will also be a data controller.

What personal data do we collect about you?

The types of Personal Data that we collect and share depends on the product or service you have with us and the nature of your investment. The Personal Data we collect about you may include:

Contact information, such as name, e-mail and postal address, and phone number;

Demographic information, such as date and country of birth, gender, country of residence, nationality, and citizenship;

Government-issued identification numbers provided in connection with a subscription to Funds, such as Social Security number, driver’s license number, passport number, national identification number, and tax identification number;

Professional or employment-related information, such as the name of your employer or the organization you represent and your position;

Financial information, such as information related to your transactions with us or others, bank account details (e.g., account and routing number), financial account history, information concerning the source of funds used for investments, and details regarding your investment history (e.g., types and amounts of investments) assets, income, and financial returns and positions;

Investment preferences;

Information related to background checks (e.g., “know your client”, anti-money laundering and sanctions checks) and any information related to applicable restrictions on your investments, such as political exposure or sanctions;

Information collected in the context of monitoring and surveillance where permitted or required by applicable law, including recordings of telephone and video calls and CCTV; and

Other information you or the organization you represent choose to provide, such as through eligibility questionnaires and ongoing investor relations communications.

We may combine Personal Data that you provide to us with Personal Data that we collect from you, or about you from other sources, in some circumstances. This will include Personal Data collected in an online or offline context.

Where do we obtain your personal data?

We collect Personal Data about you from a number of sources, including:

Personal data that you give us: From the forms and any associated documentation that you complete when subscribing for an investment, shares, interests, and/or opening an account with us. This can include information about your name, address, date of birth, passport details or other national identifier, driving license, your national insurance or Social Security number and income, employment information and details about your investment or retirement portfolio(s), and financial-related data (such as returns and financial positions). When you provide it to us in correspondence and conversations, including electronic communications such as e-mail and telephone calls. When you make transactions with respect to the Fund. When you interact with our online platforms and websites (such as bxaccess.com). When you purchase securities from us and/or tell us where to send money. From cookies, web beacons, and similar interactions when you or your devices access our sites. When we need to identify you and/or complete necessary security checks, where you visit one of our buildings or attend meetings. This can include form of ID, and your image for CCTV purposes.

Personal data that we obtain from others We obtain Personal Data from: Publicly available and accessible directories and sources. Bankruptcy registers. Tax authorities, including those that are based outside the territory in which you are located or domiciled, including the Cayman Islands, the United Kingdom (UK) and the European Economic Area (EEA), if you are subject to tax in another jurisdiction. Governmental and competent regulatory authorities to whom we have regulatory obligations. Credit agencies. Fraud prevention and detection agencies / organizations.Transaction counterparties

Why do we process your personal data?

We may process your Personal Data for the following reasons:

Contract: It is necessary to perform our contract with you to: Administer, manage and set up your investor account(s) to allow you to purchase your holding (of shares or interests) in our Funds. Meet the resulting contractual obligations we have to you. Facilitate the continuation or termination of the contractual relationship between you and the Fund. Facilitate the transfer of funds, and administering and facilitating any other transaction, between you and the Fund

Compliance with law: It is necessary for compliance with an applicable legal or regulatory obligation to which we are subject, in order to: Undertake our client and investor due diligence, and on-boarding checks, Carry out verification, “know your client”, terrorist financing, sanctions, and anti-money laundering checks, Verify the identity and addresses of our investors (and, if applicable, their beneficial owners), Comply with requests from regulatory, governmental, tax and law enforcement authorities, Carry out surveillance and investigations, Carry out audit checks, Maintain statutory registers, Prevent and detect fraud, Comply with sanctions requirements

Legitimate Interests: For our legitimate interests or those of a third party (such as a transaction counterparty or lender) to: Manage and administer your holding in any Funds in which you are invested, and any related accounts on an ongoing basis, Assess and process any applications or requests made by you, Open, maintain or close accounts in connection with your investment in, or withdrawal from, the Fund scheme, Send updates, information and notices or otherwise correspond with you in connection with your investment in the Fund scheme, Address or investigate any complaints, claims, proceedings or disputes, Provide you with, and inform you about, our investment products and services, Monitor and improve our relationships with investors, Comply with applicable prudential and regulatory obligations, including, anti-money laundering, sanctions and “know your client” checks, Assist our transaction counterparties to comply with their regulatory and legal obligations (including anti-money laundering, “know your client”, terrorist financing, and sanctions checks), Manage our risk and operations, Comply with our accounting and tax-reporting requirements, Comply with our audit requirements, Assist with internal compliance with our policies and processes, Ensure appropriate group management and governance, Keep our internal records, Prepare reports on incidents/accidents, Protect our business against fraud, breach of confidence, theft of proprietary materials, and other financial or business crimes (to the extent that this is not required of us by law), Analyze and manage commercial risks, Seek professional advice, including legal advice, Enable any actual or proposed assignee or transferee, participant or sub-participant of the partnership’s or Fund vehicles’ rights or obligations to evaluate proposed transactions, Facilitate business asset transactions involving the Fund partnership or Fund-related vehicles, Monitor communications to/from us using our systems, Protect the security and integrity of our information technology systems, Protect the security and safety of our buildings and locations where we operate, Operate, run and schedule online meetings, webinars and conferences (for example, using Zoom and other online meeting platforms), Manage our financing arrangements with our financiers and financing transaction counterparties, including payment providers, intermediaries, and correspondent / agent banks, Monitor the operation of Fund distribution platforms, where these are operated by third parties or service providers.

We only rely on these interests where we have considered that, on balance, the legitimate interests are not overridden by your interests, fundamental rights or freedoms

Monitoring as described in ‘Legitimate Interests’ above

We monitor communications where the law requires us to do so. We will also monitor where we are required to do so to comply with regulatory rules and practices and, where we are permitted to do so, to protect our business and the security of our systems.

Who we share your personal data with

We may share your Personal Data as follows:

Fund Associates: We share your Personal Data with our associates, related parties and members of our group. This is: To manage our relationship with you, For the legitimate interests of a third party in carrying out anti-money laundering, ‘know your client’, and other compliance checks required of them under applicable laws and regulations, For the purposes set out in this Data Privacy Notice,

Fund Managers, Depositories, Administrators, Custodians, Distributors, Investment Advisers: Delivering the services you require, Managing your investment, Supporting and administering investment-related activities, Complying with applicable investment, anti-money laundering and other laws and regulations.

Tax Authorities: To comply with applicable laws and regulations. Where required or requested by tax authorities in the territory in which you are located or domiciled (in particular, Cayman Island or UK/EEA tax authorities) who, in turn, may share your Personal Data with foreign tax authorities. Where required or requested by foreign tax authorities, including outside of the territory in which you are located or domiciled (including outside the Cayman Islands or UK/EEA)

Service Providers: Delivering and facilitating the services needed to support our business relationship with you (including cloud services). Supporting and administering investment-related activities. Where disclosure to the service provider is considered necessary to support 380 Capital with the purposes described in section 5 of this Data Privacy Notice

Financing Counterparties, Lenders, Correspondent and Agent Banks: Assisting these transaction counterparties with regulatory checks, such as ‘know your client’, and anti-money laundering procedures. Sourcing credit for Fund-related entities in the course of our transactions and fund life cycles

Our Lawyers, Auditors and other Professional Advisers: Providing you with investment-related services, To comply with applicable legal and regulatory requirements, Supporting 380 Capital with the purposes described in section 5 of this Data Privacy Notice

In exceptional circumstances, we will share your Personal Data with:

Competent regulatory, prosecuting and other governmental agencies or litigation counterparties, in a country or territory; and

Other organizations and agencies – where we are required to do so by law.

Do you have to provide us with this personal data?

Where we collect Personal Data from you, we will indicate if: Provision of the Personal Data is necessary for our compliance with a legal obligation; or It is purely voluntary and there are no implications for you if you do not wish to provide us with it.

Unless otherwise indicated, you should assume that we require the Personal Data for business and/or compliance purposes.

Some of the Personal Data that we request is necessary for us to perform our contract with you and if you do not wish to provide us with this Personal Data, it will affect our ability to provide our services to you and manage your investment.

Sending your personal data internationally

We may transfer your Personal Data between different countries to recipients in countries other than the country in which the information was originally collected (including to our affiliates and group members, members of the Fund’s partnership, transaction counterparties, and third-party service providers). Where you are based in the UK, the EU, or another country which imposes data transfer restrictions outside of its territory, this includes transfers outside of the UK and the European Economic Area (“EEA”) or that geographical area, to those countries in which our affiliates, group members, service providers and business partners operate. Those countries may not have the same data protection laws as the country in which you initially provided the information.

Where we transfer Personal Data outside of the UK, the EEA, or other territories subject to data transfer restrictions to other members of our group, our service providers or another third party recipient, we will ensure that our arrangements with them are governed by data transfer agreements or appropriate safeguards, designed to ensure that your Personal Data is protected as required under applicable data protection law (including, where appropriate, under an agreement on terms approved for this purpose by the European Commission or by obtaining your consent). Please contact us if you would like to know more about these agreements or receive a copy of them. Please see the ‘Contact Us’ section for details

Consent – and your right to withdraw it

Except as may otherwise be required by local law, we do not generally rely on obtaining your consent to process your Personal Data. In particular, we do not generally rely on obtaining your consent where our processing of your Personal Data is subject only to the data protection laws of the UK/EEA (in these circumstances we will usually rely on another legal basis more appropriate in the circumstances, including those set out in “Why do we process your Personal Data?” above). If we do rely on consent for processing of your Personal Data, you have the right to withdraw this consent at any time. Please contact us or send us an e-mail at PrivacyQueries@Blackstone.com at any time if you wish to do so.

Where required by applicable law, we will obtain your consent for the processing of your Personal Data for direct marketing purposes. If you do receive direct marketing communications from us (for example, by post, e-mail, fax or telephone), you may opt-out by clicking the link in the relevant communication, completing the forms provided to you (where relevant), or by contacting us (see the ‘Contact Us’ section for details).

Retention and deletion of your personal data

We keep your Personal Data for as long as it is required by us for our legitimate business purposes, to perform our contractual obligations or, where longer, such longer period as is required or permitted by law or regulatory obligations which apply to us. We will generally:

Retain Personal Data about you throughout the life cycle of any investment you are involved in; and

Retain some Personal Data after your relationship with us ends.

As a general principle, we do not retain your Personal Data for longer than we need it. We will usually delete your Personal Data (at the latest) after you cease to be an investor in any fund and there is no longer any legal / regulatory requirement, or business purpose, for retaining your Personal Data.

Your rights

You may, subject to certain limitations, have data protection rights depending on the data protection laws that apply to our processing of your Personal Data, including the right to:

Access your Personal Data

Restrict the use of your Personal Data in certain circumstances

Have incomplete or inaccurate Personal Data corrected

Ask us to stop processing your Personal Data Require us to delete your Personal Data in some limited circumstances

You also have the right in some circumstances to request us to “port” your Personal Data in a portable, re-usable format to other organizations (where this is possible).

We review and verify requests to protect your Personal Data, and will action data protection requests fairly and in accordance with applicable data protection laws and principles. If you wish to exercise any of these rights, please see the ‘Contact Us’ section for details

Concerns or queries

We take your concerns very seriously. We encourage you to bring to our attention any concerns you have about our processing of your Personal Data. This Data Privacy Notice was drafted with simplicity and clarity in mind. We are, of course, happy to provide any further information or explanation needed. Please see the ‘Contact Us’ section for details.

Please also contact us via any of the contact methods listed below if you have a disability and require an alternative format of this Data Privacy Notice.

If you want to make a complaint, you can also contact the body regulating data protection in your country, where you live or work, or the location where the data protection issue arose.

Contact Us

Please contact us if you have any questions about this Data Privacy Notice or the Personal Data we hold about you by emailing support@380capital.com Changes to this data privacy notice We keep this Data Privacy Notice under regular review.

This California Consumer Privacy Statement (“Statement”) supplements the Privacy Notice. It applies solely to California consumers, which includes visitors to our premises and our public-facing websites and mobile apps, 380 Capital job applicants and representatives of our suppliers and business partners.

This Statement does not apply to (1) 380 Capital personnel, their emergency contacts or their relatives for whom we administer benefits; or (2) information collected, processed or disclosed in connection with the provision of financial products or services pursuant to the Gramm-Leach-Bliley Act or the California Financial Information Privacy Act.

This Statement uses certain terms that have the meaning given to them in the California Consumer Privacy Act of 2018 (the “CCPA”), as amended by the California Privacy Rights Act of 2020 (the “CPRA”), and its implementing regulations (the “CCPA/CPRA”).

Collection and Use of Personal Information

We may collect (and may have collected during the 12-month period prior to the effective date of this Statement) the following categories of personal information about you:

Identifiers: identifiers such as a real name, alias, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; customer number, unique pseudonym, or user alias; telephone number and other forms of persistent or probabilistic identifiers), online identifier, internet protocol address, e-mail address, account name, Social Security number, driver’s license number, passport number, and other similar identifiers

Additional Data Subject to Cal. Civ. Code § 1798.80: signature, state identification card number education, and financial information

Protected Classifications: characteristics of protected classifications under California or federal law, such as race, color, national origin, age, sex, gender, gender expression, sexual orientation, medical condition, citizenship status, and military and veteran status

Commercial Information: commercial information, including records of products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies

Online Activity: Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications, or advertisements

Sensory Information: audio, electronic, visual, thermal and similar information

Employment Information: professional or employment-related information, such as information relating to your job position (e.g., job title, job description and office location), work authorization status, talent management information (e.g., résumé information, current or past employment history, performance evaluations, education history, professional designations and qualifications, and other information about your background)

Inferences: inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes

We may use (and may have used during the 12-month period prior to the effective date of this Statement) your personal information for the purposes described in our Privacy Notice and for the following business purposes specified in the CCPA/CPRA:

Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytics services, providing storage, or providing similar services

Providing advertising and marketing services to you, except for cross-context behavioral advertising

Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance

Short-term, transient use, including, but not limited to, non-personalized advertising shown as part of your current interaction with us

Helping to ensure security and integrity to the extent the use of your personal information is reasonably necessary and proportionate for these purposes

Debugging to identify and repair errors that impair existing intended functionality

Undertaking internal research for technological development and demonstration

Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us

We do not collect or process sensitive personal information with the purpose of inferring characteristics about California consumers covered by this Statement. To the extent we process deidentified information, we will maintain and use the information in deidentified form and will not attempt to reidentify the information unless permitted by applicable law.

Retention of Personal Information

We will retain your personal information as described in the “Retention and Deletion of your Information” section of our Privacy Notice.

Sources of Personal Information

During the 12-month period prior to the effective date of this Statement, we may have obtained personal information about you from the following categories of sources:

Directly from you, such as when you contact us

Your devices, such as when you visit our websites or mobile apps

Our affiliates and subsidiaries

Vendors who provide services on our behalf

Professional services organizations, such as auditors, accountants and law firms

Our business clients and partners

Philanthropic, charitable and advocacy partners

Our portfolio companies

Other individuals, such as in connection with a referral

Recruiting and talent agencies

Data analytics providers

Government entities

Social networks

Publicly accessible databases

Data brokers, such as credit reporting agencies and background check services

Sources of Personal Information

We do not sell your personal information in exchange for monetary compensation. We may disclose your personal information by allowing certain third parties (such as online advertising services) to collect personal information via automated technologies on our websites and apps for cross-context behavioral advertising purposes. Under California law, these kinds of disclosures may be considered a “sale” when the personal information is exchanged for non-monetary consideration, or “sharing” when the personal information is disclosed for cross-context behavioral advertising purposes. You have the right to opt out of these types of disclosures of your information.

We may sell or share for cross-context behavioral advertising purposes (and may have sold or shared during the

12-month period prior to the Last Updated date of this California Consumer Privacy Statement) the following categories of personal information about you to online advertising services:

Identifiers

Commercial Information

Online Activity Inferences

We do not have actual knowledge that we sell or share the personal information of minors under 16 years of age.

Disclosure of Personal Information

During the 12-month period prior to the effective date of this Statement, we may have disclosed the following categories of personal information about you for a business purpose to the following categories of third parties:

Identifiers: Our affiliates and subsidiaries, Vendors who perform services on our behalf, Professional services organizations, such as auditors, accountants and law firms, Our business clients and partners, Philanthropic, charitable and advocacy partners, Internet service providers and operating systems and platforms, Data analytics providers, Data brokers, such as credit reporting agencies and background check services, Our portfolio companies

Additional Data Subject to Cal. Civ. Code § 1798.80: Our affiliates and subsidiaries, Vendors who perform services on our behalf, Professional services organizations, such as auditors, accountants and law firms, Our business clients and partners, Philanthropic, charitable and advocacy partners

Protected Classifications: Our affiliates and subsidiaries, Vendors who perform services on our behalf, Professional services organizations, such as auditors, accountants and law firms, Our business clients and partner, Philanthropic, charitable and advocacy partners

Data analytics providers: Online Activity, Our affiliates and subsidiaries, Vendors who perform services on our behalf, Professional services organizations, such as auditors, accountants and law firms, Internet service providers and operating systems and platforms, Data analytics providers

Sensory Information: Our affiliates and subsidiaries, Vendors who perform services on our behalf Professional services organizations, such as auditors, accountants and law firms, Our business clients and partners, Philanthropic, charitable and advocacy partners, Data analytics providers

Employment Information: Our affiliates and subsidiaries, Vendors who perform services on our behalf, Professional services organizations, such as auditors, accountants and law firms, Our business clients and partners, Philanthropic, charitable and advocacy partners, Our portfolio companies, Data analytics providers

Inferences: Our affiliates and subsidiaries, Vendors who perform services on our behalf, Professional services organizations, such as auditors, accountants and law firms, Our business clients and partners, Philanthropic, charitable and advocacy partners, Our portfolio companies, Data analytics providers

In addition to the categories of third parties identified above, during the 12-month period prior to the effective date of this Statement, we may have shared personal information about you with: (1) government entities, such as law enforcement authorities and regulators; (2) self-regulatory organizations; and (3) third parties in connection with an actual or proposed corporate transaction, such as a merger, acquisition, joint venture, reorganization, divestiture, dissolution or liquidation.

California Consumer Privacy Rights

You have certain choices regarding your personal information, as described below.

Access: You have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected, used, disclosed and sold about you during the past 12 months.

Correction: You have the right to request that we correct the personal information we maintain about you, if that information is inaccurate.

Deletion: You have the right to request that we delete certain personal information we have collected from you.

Opt-Out of Sale or Sharing: You have the right to opt-out of the sale of your personal information or the sharing of your personal information for cross-context behavioral advertising purposes.

How to Submit a Request. To submit an access, correction or deletion request, you can email support@380capital.com. You can opt out of the sale or sharing of your personal information by emailing support@380capital.com.To submit a request as an authorized agent on behalf of a consumer, contact us at support@380capital.com.For questions or concerns about our privacy policies and practices, contact us at support@380capital.com

Verifying Requests. To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request. If you request access to, correction of or deletion of your personal information, we may require you to verify your e-mail address or certain of your information in our records, such as your name, e-mail address, mailing address, phone number, company name and job-details, or other information about your interactions with us. In addition, if you ask us to provide you with specific pieces of personal information, we may require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request.

Additional Information. If you choose to exercise any of your rights under the CCPA/CPRA, you have the right to not receive discriminatory treatment by us. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.