Privacy Notice

400 Capital Management LLC (the “Investment Manager” or “400CM”) and the investment vehicle or vehicles to which 400CM serves as investment manager or investment adviser in which you invest (each the “Fund” and together with 400CM, “we,” “our,” or “us”) take seriously the privacy of current, former, and prospective investors (who are natural persons). The following privacy notice (the “Privacy Notice”) explains how we collect, use, disclose, and process personal data (as defined below) relating to identifiable individuals who are current, former, and prospective investors, or, in the case of an investor that is not a natural person, that investor’s current, former, and prospective employees, officers, directors, agents, representatives, consultants, partners, members, beneficial owners, any trustee, settlor or protector of a trust or any person for whom the investor is acting as agent or nominee (each a “data subject” or “you”). We are also required to provide Privacy Notices to users of our website, and also must provide certain information depending upon your jurisdiction and relationship to us (e.g., whether you are an individual in the European Union or a business that works with us in California). Please refer to the privacy notices herein for additional information regarding how we comply with certain specific data privacy laws applicable to our securities clients in the U.S. (US Securities Client Privacy Notice) or to residents in Europe (GDPR Notice), the Cayman Islands (Cayman Islands Privacy Notice), and the state of California (California Privacy Notice).

This Privacy Notice applies to 400CM and each investment vehicle to which 400CM serves as investment manager or investment adviser.

400CM reserves the right to change this notice as permitted by applicable law. The effective date of this notice and any revised or changed notice may be found on this page, on the top left corner of the notice. Any changes will be effective only after the effective date of the change and will not affect any dispute arising prior to the effective date of the change.

Keep in mind that the rights discussed in certain sections of this Privacy Notice may be subject to exemptions or other limitations under applicable law.

Table of Contents

Information We Collect
How We Use Information
Information We Share
Safeguards for Personal Information
Tracking
Process for Review and Changes
Children and Minors
Additional Rights
U.S. Securities Client Privacy Notice
California Privacy Notice
GDPR Privacy Notice
Cayman Islands Privacy Notice

Information We Collect

For all users of this website, we log your current Internet address (this is usually a temporary address assigned by your Internet service provider when you log in), the type of operating system you are using, and the type of browser software used. In addition, we may keep track of what portions of this website you are visiting. We aggregate this information to help us improve or create a better experience for users of this website. For example: we may upgrade those parts of the website that are heavily visited. In addition, if you choose to complete certain forms or send us requests, you will be asked to provide the following information: full name, street address, city, state, ZIP, phone number and e-mail address. Our website automatically records website usage information that we analyze statistically to track operational problems, to prevent fraud and to improve the effectiveness, security and integrity of the site. We do not use this information to track or record information about individuals. We will disclose this information to third parties only in aggregate form or as may be required by law.

Cookies

A cookie is a piece of information that a web site sends to your computer that is stored in a file on your computer’s hard drive. A cookie does not tell us your individual identity unless you have chosen to provide it to us. Most cookies expire after a defined period of time.

Using the settings of your Internet browser, you can configure your browser to accept all cookies, reject all cookies, notify you when a cookie is set, or delete cookies that have already been set. Each browser is different, so check the “Help” menu of your browser to learn how to change your cookie preferences. You are always free to decline our cookies if your browser permits, however, if you choose to turn off cookies, you may not have access to many features that optimize your browsing of our Site, and some of our services may not function properly. You may at any time delete any cookies set by using the relevant option of your Internet browser or by deleting the cookies on your hard drive. The site www.allaboutcookies.org includes instructions for managing cookies on many commonly used Internet browsers, or you may consult the vendor documentation for your specific software.

See our Cookies Policy for additional information.

Information Collected From Clients. We collect information from our clients through managed account agreements and subscription agreements and related forms, investor questionnaires, and other information provided by the client in writing, in person, by telephone, electronically or by any other means. Examples of such information include name, address, social security number, birth date, assets, income and investment experience. We also collect information from your transactions with us, such as account activity and balances. Our U.S. clients should see our fact sheet here for additional information about our privacy practices with respect to nonpublic personal information.

Information Collected from Other Sources.

We use collected information consistent with this Privacy Notice and for the purposes described below. We collect personal data through a range of means. Much of the personal data will be collected directly from you and/or your intermediaries through sources such as: (i) account applications, subscription forms, investor questionnaires and other forms or related documentation (including any anti-money laundering, identification, and verification documentation); (ii) written, electronic,or verbal correspondence with us or our service providers; (iii) investor transactions; (iv) an investor’s brokerage or financial advisory firm, financial advisor, or consultant; and/or (v) from information captured on applicable websites. In addition, we may collect personal data from different sources, such as: (i) our affiliates, our service providers, or our affiliates’ service providers; (ii) public websites or other publicly accessible directories and sources, including publicly-available registries or databases, tax authorities, governmental agencies and departments,regulatory authorities, and/or news outlets or other media sources; and/or (iii) from credit reportingagencies, sanctions screening databases, or from sources designed to detect and prevent fraud.

If you are a nominee investor or a corporate entity, this Privacy Notice will be relevant for those individuals connected to you and you should transmit this document to such individuals for their awareness and consideration.

How We Use Information

We may collect, use, retain, share, and store personal information collected from or about you for any of the following purposes:

• To provide and improve the services. We use your personal information – such as your address and transaction details – to respond to your inquiries and provide you with requested information; to fulfill, validate, and manage your orders and transactions; process payments; and to provide and improve our customer service. In addition, we may use personal information to analyze and improve the performance, usage and operations of our services using internal or external software and tools; to better understand who is using the services and how; and to develop new products or services.
• To communicate with you. For example, we may use your personal information – such as your email address, telephone number, usernames, and other contact information – to respond to your inquiries; to provide you with information about your account, purchases, transactions, and Services; to conduct surveys; to engage with you over site features [such as which features you prefer]; to provide you offers by email, mail, and across other websites, mobile applications, social media, and online services as appropriate; and to otherwise communicate with you as needed or permitted to run our business.
• To prevent fraud, comply with applicable law, protect our business, and other purposes. For example, we may use your name, contact information, and other personal information to protect the security or integrity of the services and our business; to prevent fraudulent activity; to assist law enforcement; and/or to comply with legal or regulatory obligations. We may also use and share aggregated or de-identified personal information for any purpose.

Information We Share

As described above, we may disclose the electronic information captured from all users of this website to third parties only in aggregate form or as may be required by law. We may also share cookie information as described above.

In order to service your accounts and process your transactions, we will provide your non-public personal information to our affiliates and to firms that assist us in servicing your account and have a need for such information such as administrators. We require third party service providers to protect the confidentiality of your information. California residents that are service providers or business clients should review the special provisions that are applicable here California Residents’ Rights under the CCPA.

We do not disclose any personal information about our clients to anyone other than (1) in connection with the administration, processing and servicing of a client’s accountsas described above, (2) to our accountants, attorneys and auditors, or (3) as otherwise permitted orrequired by law.

We may disclose personal information in order to (a) complete your transaction; (b) comply with legal process; (c) enforce this Privacy Notice or any agreement between us; (d) respond to claims that any information you provide violates the rights of third parties; (e) protect our rights, property, or personal safety or those of our users and/or the public; or (f) in relation to the sale, assignment, merger, transfer or acquisition of all or substantially all of our assets or shares by a third party.

We do not share personal information with affiliated or unaffiliated third parties except under the circumstances noted above. Since sharing under such circumstances is necessary to service a client’s account or is permitted or required by law, clients cannot generally limit this sharing. California residents should review the special provisions that are applicable here.

Safeguards for Personal Information

The Investment Manager will take reasonable steps and use security measures appropriate to the nature of the information and that comply with applicable laws designed to protect investors’ personal data against unauthorized access and exfiltration, acquisition, theft, or disclosure. Given the nature of information security, there is no guarantee that such safeguards will always be successful.

Tracking

We will not respond to Web browser “do not track” signals. If you would like additional information about online tracking and various opt-out mechanisms, please see https://youradchoices.com/.

Because we link to social media sites, and from time to time may include third-party advertisements, other parties may collect your personally identifiable information about your online activities over time and across different web sites when you visit this website.

Please note that not all tracking will stop even if you delete cookies.

Process for Review and Changes

You may review and change your information at any time by contacting us at ir@400capital.com. You may also contact us at that email address if you have any questions.

Children and Minors

We make no active effort to collect personal information from children under the age of 18 and do not wish to receive any such information.

Additional Rights:

Applicable laws may give you additional rights that are not described in the Privacy Policy.

Contact Us

For further information on Privacy matters contact legal@400capital.com.

US Securities Client Privacy Notice

California Privacy Notice

The California law known as California Consumer Privacy Act (“CCPA”), as amended by the California Privacy Rights Act, imposes certain obligations on the Fund, the Investment Manager,and their affiliates (together, “we” or “us”) and grants certain rights to California residents (“California Resident,” “you” or “your”) with regard to “personal information.” If you are a California Resident, please review the following information about your potential rights with regard to your personal information under the CCPA. The rights described herein are subject to exemptions and other limitations under applicable law.

Terms used herein have the meaning ascribed to them in the CCPA. The Fund, the Investment Manager, and their affiliates are a “business.” “Personal information” for the purposes of this section has the same meaning as under the CCPA. It does not include deidentified information, aggregate consumer information or publicly available information, as those terms are defined in the CCPA.

We do not sell your personal information. In the preceding 12 months, we may have disclosed for a business purpose all or some of the categories of personal information listed above in the section “What personal data will be collected and used?”. We also may share your personal information with our service providers, other entities that have agreed to limitations on the use of your personal information, or entities that fit within other exemptions or exceptions in or as otherwise permitted by the CCPA.

What personal data will be collected and used?

By virtue of making an investment in the Fund, the Fund, the Investment Manager, the administrator and their respective affiliates and delegates may collect, record, store, transfer and otherwise process personal data by which individuals may be directly or indirectly identified. Such data includes, for purposes of California residents only (pursuant to the CCPA), “personal information” that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a California resident or a household.

Examples of personal data related to you may include:

• Identifiers and similar information, such as name, title, address, date of birth, email addresses, government identification numbers (e.g., tax, social security, national, driver’s license, or passport number), usernames, telephone / mobile / fax number, IP addresses and other online identifiers or other similar identifiers;
• Bank account details, personal assets, accounts and bank statements, signature or other financial information;
• Characteristics of protected classifications under certain national or local laws, including gender, nationality, or marital status;
• Commercial information, including records of products or services purchased, obtained, or considered, or other purchasing histories or tendencies, including funds invested, investments considered, source of wealth information, your shareholder reference number,payment details and other details of products and services purchased by you;
• Information relating to your subscription or proof of your eligibility to purchase interests in the Fund including financial and investment qualification;
• Copies of passport, utilities bills and other documentation required for identity or address verification purposes;
• Data which, when aggregated with other data, enables an individual to be identified, suchas an IP address and geolocation data or personal data contained in emails;
• Family structure, siblings or offspring;
• Power of attorney information;
• Professional or employment-related information, including occupation, education information, investment experience, compensation, jobtitles, employment history, and employer details;
• Internet or other electronic network activity information, including interactions with ourwebsite or use of certain online tools;
• Data regarding preferences in connection with marketing communications;
• Audio, electronic, visual, or similar information;
• Data obtained pursuant to standard criminal record checks or in accordance with the Fund’sstandard anti-money laundering and client due diligence checks;
• Certain information that may qualify as “special category” data under the GDPR, such as data revealing racial or ethnic origin; trade union membership; political opinions; religious or philosophical beliefs; health data; sexual orientation; genetic or biometric data; and
• Inferences drawn from any of the information identified above to create a profile reflectingyour preferences or similar information, including your potential interest in investing in new funds.

Where do we collect your Personal Data?

We collect personal data through a range of means. Much of the personal data will be collected directly from you and/or your intermediaries through sources such as: (i) account applications, subscription forms, investor questionnaires and other forms or related documentation (including any anti-money laundering, identification, and verification documentation); (ii) written, electronic, or verbal correspondence with us or our service providers; (iii) investor transactions; (iv) an investor’s brokerage or financial advisory firm, financial advisor, or consultant; and/or (v) from information captured on applicable websites. In addition, we may collect personal data from different sources, such as: (i) our affiliates, our service providers, or our affiliates’ service providers; (ii) public websites or other publicly accessible directories and sources, including publicly-available registries or databases, tax authorities, governmental agencies and departments, regulatory authorities, and/or news outlets or other media sources; and/or (iii) from credit reporting agencies, sanctions screening databases, or from sources designed to detect and prevent fraud.

If you are a nominee investor or a corporate entity, this Privacy Notice will be relevant for those individuals connected to you and you should transmit this document to such individuals for their awareness and consideration.

How do we collect and use your personal data?

The Investment Manager will collect, use, and process (or arrange the processing of) your personal data for the following business and commercial purposes: (i) to perform services on behalf of the Fund, including to market the Fund, to process subscriptions and redemptions, to maintain and service accounts, to provide investor relations services, to process subscriptions and withdrawals/redemptions, to verify information, to process payments, and to otherwise under take the necessary and appropriate actions in order to operate the Fund and manage its assets; (ii) performing our contractual obligations to subscribers to a fund, including to provide updates on a fund’s performance, to provide tax reporting, and other operational matters; (iii) to detect security incidents and protect against malicious, deceptive, fraudulent, or illegal activity, including to prevent fraud and conduct “Know Your Client,” anti-money laundering, terrorist financing, and conflict checks; (iv) to enable or effect commercial transactions, including to use bank account details to remit funds and process distributions; (v) to comply with the applicable legal and regulatory obligations and to exercise its rights at law or under contract, including reporting to national and international regulatory bodies; and (vi) to manage and administer the Fund’s and the Investment Manager’s business and to improve relationships with investors in the Fund or investors in other funds or vehicles managed or advised by the Investment Manager, to assist with investor relationship management, and for marketing and business development activities and analysis.

How do we share your personal data with third parties?

The Investment Manager may share your personal data with third parties (including legal advisors and law enforcement agencies) in circumstances where we believe in good faith that disclosure is required or permitted under law, to cooperate with regulators or law enforcement authorities, to protect our rights or property, or, for our investors, upon reasonable request by the fund in which you have invested. The Investment Manager also may disclose personal data about you to a third party at your request or direction or with your consent.

The Investment Manager may also use non-public personal data in order to provide you with information of investments or products the investor may be interested in. If you object to being contacted in respect of prospective products, please contact the Fund or the Investment Manager at ir@400capital.com.

Who do we share your personal data with?

The Investment Manager may share certain of your personal data with the following categories of third parties for the following reasons:

• The administrator and such of its affiliates and other sub-processors as may be necessary to provide the fund administration services for the purposes of carrying out money laundering checks and administering the investor’s investment in the Fund;
• Advisers (e.g. auditors, legal counsel and tax advisers) to the Investment Manager relating to or in connection with the investor’s subscription to the Fund;
• Brokers, prime brokers, banking and other financial services providers to the Fund or the Investment Manager;
• Affiliates of the Investment Manager (including their officers, directors, partners or employees) for the purpose of the management of the Fund or the Investment Manager’s business; and
• At times, it may also be necessary to share relevant personal data with (i) a prospective service provider of the Fund including one which is replacing an existing service provideror (ii) to people or companies where required in connection with a potential or actual corporate restructuring, merger, acquisition, transfer of all or a portion of the Fund’s business or assets (including in the event of a reorganization, dissolution or liquidation) or takeover of the Fund and/or the Investment Manager;
• Investors’ service providers at investors’ request or with investors’ permission.

They may in turn use the services of their affiliates or service providers to process your personal data where necessary or appropriate. Where we share your personal data with a third party, we generally take steps to ensure the recipients of that personal data will process it appropriately and otherwise in accordance with the instructions of the Fund and the Investment Manager and/or with the Data Protection Legislation.

We may also share your personal data with law enforcement agencies, regulatory or tax authorities and other governmental or public agencies or authorities in order to comply with our legal or regulatory obligations or at their request in furtherance of their objectives.

How do we secure personal data?

The Investment Manager will take reasonable steps and use security measures appropriate to the nature of the information and that comply with applicable laws designed to protect investors’ personal data against unauthorized access and exfiltration, acquisition, theft, or disclosure. Given the nature of information security, there is no guarantee that such safeguards will always be successful.

California Residents’ Rights under the CCPA

If your personal information is subject to the CCPA, you may have certain rights concerning that information, subject to applicable exemptions and limitations, including:

• The right to be informed, at or before the point of collection, of the categories of personal information to be collected and the purposes for which the categories of personal information shall be used;
• The right to not be discriminated against because you exercise any of your rights under the CCPA;
• The right to request that we delete any personal information about you that we collected or maintained, subject to certain exceptions (“request to delete”);
• The right to data portability, to the extent technically feasible, readily usable format. a consumer may exercise this right no more than two times per calendar year.
• The right to opt-out of the “sale” or “sharing” of your personal information (as those terms are defined by CCPA) by us, although we do not “sell” or “share” your personal information; and
• The right to request that we, as a business that collects personal information about you andthat discloses your personal information for a business purpose, disclose to you (“request to know”): (a) the categories of personal information we have collected about you; (b) the categories of sources from which we have collected the personal information; (c) the business or commercial purpose for collecting the personal information; (d) the categories of third parties with which we share personal information; (e) the specific pieces of personal information we have collected about you; and (f) the categories of personal information we have disclosed about you for a business purpose.

The CCPA does not restrict our ability to do certain things like comply with other laws or comply with regulatory investigations. In addition, the CCPA does not apply to certain information like personal information collected, processed, sold or disclosed pursuant to the U.S. Gramm-Leach- Bliley Act and its implementing regulations. We also reserve the right to retain, and not to delete, certain personal information after receipt of a request to delete from you where permitted by the CCPA.

How to Submit a Request under the CCPA

You may submit a “request to know” or “request to delete” by contacting the Investment Manager directly at ir@400capital.com.

We are required to provide certain information or to delete personal information only in response to verifiable requests made by you or your legally authorized agent. Any information gathered as part of the verification process will be used for verification purposes only.

In order to verify requests to know and requests to delete, we may require you to provide clarifying or identifying information. Such information may include, at a minimum, depending on the information you are requesting and the type of request you are making, account login credentials or other account information, answers to security questions, name, government identification number, date of birth, contact information, or other personal information.

If an authorized agent seeks to submit a request on behalf of a California Resident, the authorized agent may do so by the aforementioned methods, however, they must provide: (i) signed authorization from the California Resident authorizing them to act on the California Resident’s behalf, unless they can provide proof that the California Resident has granted them power of attorney pursuant to California Probate Code sections 4000 to 4465; and (ii) proof of their registration with the California Secretary of State to conduct business in California.

We also require that the California Resident directly verify their own identity with us and directly confirm with us that they provided the authorized agent permission to submit the request. For your protection, we reserve the right to deny any request from an agent who does not submit proof that they have been authorized to act on your behalf.

Questions or complaints

If you have any questions or complaints regarding the processing of your personal data by the Investment Manager, in the first instance, please contact the Investment Manager directly at ir@400capital.com. This California-specific Privacy Policy was last updated in March 2024.

We reserve the right to change this Privacy Notice at any time. We encourage you to regularly review this and any updated Privacy Notice to ensure that you are always aware of how personal data is collected, used, stored and disclosed.

GDPR Notice

DATA PROTECTION INFORMATION AND DISCLOSURES
March 2024

In the course of our correspondence and other dealings with you, we will receive information relating to you and/or, where you act as an agent or a representative of a legal person or other entity (rather than a natural person), information relating to other officers, directors, partners, members or employees of that legal person or other entity (such information, “personal information”). If the personal information you provide to us does not relate to you, you agree to provide the disclosures set out below to the individuals whose personal information you have provided.

Personal information is subject to certain legal safeguards specified in the General Data Protection Regulation (2016/679) (“GDPR”), the GDPR as retained in the UK legislation by virtue of the European Union (Withdrawal) Act 2018 (“UK GDPR”) and any secondary and domestic legislation implementing the GDPR/UK GDPR (together, the “Data Protection Legislation”). 400 Capital Management Europe Limited (“400CME”), and in certain limited circumstances 400 Capital Management LLC (“400CM” and together with 400CME, “we”, “us” or “our”) are ‘controllers’ of your personal information for the purposes of the Data Protection Legislation. The Data Protection Legislation prescribes the way in which we may collect, retain and handle personal information. 400CME acts as the EU representative of 400CM, where applicable.

What personal information will we process?

The types of personal information relating to you may include, for example:

• name, business and/or private email address, postal address and/or telephone number, date of birth and gender;
• domicile and other geographic location data;
• bank account details, source of wealth information, accounts and bank statements (and similar information required to meet our anti-money laundering and client authentication requirements i.e. for AML/KYC purposes). This may include details of your transactions with us, subscriptions or holdings with us or our affiliate.
• If applicable, criminal offences and convictions, any information indicating potential fraud (for example, suspicious transactions), any reference on a politically exposed person and/or sanctions list;
• information relating to regulatory status or eligibility to make investments;
• information that establishes your identity, such as copies of passports and other documentation required for identity or address verification purposes;
• Our correspondence with you;
• marketing preference information, including details of your marketing and communication preferences and information relevant to selecting appropriate products and services to offer you;
• survey information if we ask you to complete surveys for research purposes;
• website usage information collected through cookies and other tracking technologies;
• IP address and other device information; and
• if applicable, information relating to the organisation you represent (i.e. your role and any authorisations, statements etc that you make on behalf of that organisation)

Where do we collect your Personal Information?

We may collect personal data through a range of means. These may include direct interactions (where a person provides personal data to us through correspondence or other direct methods of communication, including communications relating to investments), third-parties (such as the organisation that you represent) or publicly available sources (where the Fund receives personal data through a publicly available source such as a website or publicly-available registry).

How do we use your personal information?

We will process your personal information in order to:

• market our investment products. If you do not wish to receive marketing, please contact us at ir@400capital.com;
• communicate with you in respect of any products offered by us, process queries, undertake normal investment business activities, offer our services and manage assets on behalf of clients;
• exercise our rights at law or under contract;
• inform you of changes to our services and products;
• where required, comply with our legal and regulatory obligations set out under the laws of countries outside the European Economic Area (“EEA”) and the United Kingdom. This may include, without limitation, establishing investor eligibility, detecting and preventing fraud, carrying out money laundering checks or conflict checks, and reporting to national and international regulatory and tax authorities.
• manage and administer our business (including in connection with any restructure and to analyse and improve our business relationships);
• analyse and improve relationships with our clients and service providers, and for business development activities;
• undertake risk assessment and operational control exercises; for statistical and trend analysis; for systems administration, operation, testing and support and to manage and ensure the security of our information systems;
• help detect, prevent, investigate, and prosecute fraud and/or other criminal activity;
• disclose information to a governmental, tax or regulatory body, financial market, broker or other intermediaries, counterparties, court, auditors or other third parties and to undertake compliance activities, when this is in our interests, or in the interests of any of our clients, including where the laws of the EU or a member state of the EEA do not require us to do the same;
• to establish, exercise or defend legal claims; and in order to protect and enforce our or our clients’ rights, property, or safety or to assist our clients or investors or others to do the same;
• to investigate and respond to any complaints about us and our business or any incidents relating to us and to help maintain quality and to deal with complaints and disputes; and
• to make certain assessments about you in order to assess your investment objectives, risk tolerance, and understanding of investment risk to assess the suitability of an investment in any investment product offered by us.

Lawful bases for processing your personal information

The lawful bases for our processing of your personal information are as follows:

Performance of contract: to ensure our ability to perform our obligations under investment contracts and other documents that form the basis for our contractual relationship with you, and certain required pre- contractual steps. If we cannot process personal information as required, it may not be possible for us to perform our obligations under the relevant contract, and we may be required to terminate the contract. We rely on performance of a contract for the following processing:

• to process queries, undertake normal investment business activities, offer our services and manage assets on behalf of clients; and
• to exercise our rights and obligations under our contract with you.

If you don’t provide us with this information, we might not be able to enter a contract with you or perform it or provide goods or services to you. In this case, we might have to cancel the contract or service you have with us but we will notify you if this is the case at the time.

Legal obligations: we are required to comply with applicable legal and regulatory requirements (where those obligations derive from the laws of the United Kingdom, the European Union or the member states of the European Economic Area), including, for example, any regulatory or tax reporting requirements; to carry out money laundering/terrorist financing checks, conflict checks, for purposes of fraud prevention, to comply with any applicable auditing or financial reporting requirements; and to comply with information disclosure requests from regulatory, tax or other governmental or public authorities. We rely on our legal obligations in respect of the following processing:

• investor eligibility;
• detecting and preventing fraud;
• carrying out money laundering checks or conflict checks; and
• reporting to national and international regulatory and tax authorities.

Public interest: We process some of your personal data, including special category personal data contained within sanctions data about you, on the basis of the public interest in preventing or detecting unlawful acts or for disclosures in relation to suspicion of terrorist financing or money laundering.

Legitimate interests: In addition to the above lawful bases for processing your personal information, your personal information will also be processed on the basis of our legitimate interests (to manage our business effectively):

• to exercise and comply with our rights and obligations at law or under regulation, where such obligations are set out under the laws of countries outside the European Economic Area (“EEA”) and the United Kingdom;
• to manage and administer our business and to analyse and improve our business relationships;
• to communicate with you in respect of any products offered by us;
• to send you marketing communications (unless you have opted out of these);
• to undertake risk assessment and operational control exercises; for statistical and trend analysis; for systems administration, operation, testing and support and to manage and ensure the security of our information systems;
• to help detect, prevent, investigate, and prosecute fraud and/or other criminal activity;
• to disclose information to a governmental, tax or regulatory body, financial market, broker or other intermediaries, counterparties, court, auditors or other third parties and to undertake compliance activities, when this is in our interests, or in the interests of any of our clients, including where the laws of the European Union or a member state of the European Economic Area do not require us to do the same;
• to establish, exercise or defend legal claims; and in order to protect and enforce our or our clients’ rights, property, or safety or to assist our clients or investors or others to do the same;
• to investigate and respond to any complaints about us and our business or any incidents relating to us and to help maintain quality and to deal with complaints and disputes; and
• to make certain assessments about you in order to assess your investment objectives, risk tolerance, and understanding of investment risk to assess the suitability of an investment in any investment product offered by us.

With whom do we share your personal information?

We may share certain of your personal information with the following categories of third parties for the following reasons:

• broker-dealers that provide trade execution services, custodians that provide custody services and other business services providers in connection with investment decisions, with respect to an investment account you hold with us and/or to enable us to provide services and operate our business;
• advisers (e.g. auditors, legal counsel and tax advisers) relating to or in connection with the operation of our business, compliance with our legal, regulatory or contractual obligations and/or your investments with us;
• our affiliates for the purpose of undertaking investment advisory and investment management business;
• new business owner if your personal data is transferred in connection to a sale or purchase of business assets;
• anti-fraud organisations, law enforcement agencies; regulatory or tax authorities and other governmental or public agencies or authorities in order to comply with our legal or regulatory obligations or at their request in furtherance of their objectives or to comply with a court order or for the protection of our assets (for example, collection of overdue accounts); and
• firms that assist us in servicing your account and have a need for such information such as administrators, firms assisting us with data processing, fraud prevention and detection, analytics and marketing or IT service providers.

They may in turn use the services of their affiliates or service providers to process your personal information where necessary or appropriate. Where we share your personal information with a third party, we generally take steps to ensure the recipients of that personal information will process it appropriately and in compliance with the Data Protection Laws.

Transfers of your personal information outside the UK/EEA

Your personal information is held by 400CM in its offices in the United States and the data collected by or on behalf of 400CME is transferred to 400CM in the United States. Your personal information may be further shared with advisers, service providers, and disclosed to regulatory, tax or other governmental or public authorities outside the EEA and the UK, as described above. Such transfers may be made at least to the following jurisdictions: the United States.

Where we share your personal information with persons outside the EEA and the UK to a country not found to have an adequate level of data protection pursuant to applicable EEA/UK law we will generally rely on the standard contractual clauses approved by the European Commission governing the transfer of personal data outside the EEA, where possible (modified in accordance with relevant regulatory guidance for exports from the UK). These include contractual safeguards requiring the recipient to process the personal information in accordance with the EU/UK data protection law standards, for example, to protect the confidentiality and security of your personal information. We may also supplement the standard contractual clauses with additional measures if we consider that these are required. Please contact us at ir@400capital.com if you would like a copy of the standard contractual clauses.

Security of your personal information

We will ensure that the personal information that we hold is subject to appropriate security measures. We maintain commercially reasonable physical, electronic and procedural safeguards to protect your personal information in accordance with legal requirements.

How long is your personal information retained?

We will not retain your personal information for longer than is necessary in relation to the purposes for which your personal information is processed and in accordance with regulatory requirements. Generally, we will retain your personal information concerning your investments for 5 years after the end of any relevant contractual relationship. Personal information may be retained for longer if it is required by law, or by a tax or regulatory authority, a law enforcement agency or other governmental or public body, or considered necessary in order to allow us to act in accordance with a specific set of circumstances, for example, in light of an actual or a potential legal action or a regulatory investigation.

Additionally, there may be laws or regulation which set a minimum period for which we have to keep your personal information. We will only hold your information for the defined retention period, before anonymizing the information or deleting it. Anonymising the personal information means making it so that it can no longer be identifiable to you personally. This can be achieved either by aggregating the data (for example, to make a finding about a group of people as opposed to a specific individual) or by removing any personal identifiers (for example, contact information) so that it can still be used to identify trends and patterns but cannot be linked back to a specific individual.

If you choose to unsubscribe from a service, we may keep a ‘suppression list’ containing your details so we know you have unsubscribed and to ensure you are not contacted again. Your personal information held on a suppression list will not be used for any other purpose.

Your rights in relation to the personal information we process about you

You have various rights under Data Protection Legislation in relation to the personal information relating to you. These include, where certain conditions are met:

• the right to request access to your personal information;
• the right to have your personal information rectified where it is inaccurate;
• the right to have your personal information erased in certain circumstances;
• the right to restriction of our processing of your personal information is only used for restricted purposes;
• (in certain circumstances if the lawful basis for processing your personal information is the legitimate interest of the Fund/ the Investment Manager) the right to object to your personal information being processed, for example, for marketing purposes;
• (in some circumstances) the right to require certain of your personal information to be transferred to you or a third party; and
• the right to lodge a complaint with the relevant applicable data protection regulator (please see “Applicable Regulator” below).

You can seek to exercise any of these rights by contacting us at legal@400capital.com. We may ask you to verify your identity before we can process your query.

Our representatives

In the UK, our representative is: 400 Capital Management Europe Limited, 27 Old Gloucester Street, London WCIN 3AX England, 44 20 3931 9948.

Questions or complaints

If you have any questions or complaints regarding the processing of your personal information, please contact us directly at ir@400capital.com.

If you are still not satisfied with the way we use your Personal Data and you believe this is not in accordance with data protection laws, you have the right to lodge a complaint with your local data protection authority.

In the UK, the relevant supervisory authority is the Information Commissioner’s Office (ICO). You can contact the ICO via their web-form at https://ico.org.uk/make-a-complaint/ or call the ICO helpline on +44 (0)303 123 1113. If you are a resident of an EU country and would like to contact your relevant supervisory authority, you can find a list of authorities via: https://edpb.europa.eu/about-edpb/about- edpb/members_en

400 Capital Management Europe Limited

GDPR Data Protection Policy
March 2024

400 Capital Management Europe Limited (the “Firm”; We, Our, Us) will be subject to UK/EEA Data Protection Laws (as applicable) where:

• Personal Data is Processed (i.e. collected and used) by a Firm branch or entity established in the UK/EEA;
• The Firm offers goods and/or services to individuals located in the EEA/UK; or
• The Firm monitors the behavior of individuals located in the EEA/UK.

Action: If you are not sure whether a particular instance of Processing falls within scope of the UK/EEA Data Protection Regime, please contact legal@400capital.com.

What Personal Data the Firm Processes

The UK/EEA Data Protection Laws require the Firm to provide privacy notices, explaining how Personal Data will be Processed by the Firm, to all individuals whose Personal Data We Process.

Action: If you are commencing a new Processing purpose or varying an existing Processing purpose and you are not sure whether this is described in the relevant privacy notice, please contact legal@400capital.com.

Data protection principles

The Processing of Personal Data subject to the UK/EEA Data Protection Laws must be undertaken in accordance with the following principles.

1. Lawfulness, fairness, and transparency, which means that We:

• must inform the Data Subject of the Processing We carry out, by providing Our privacy notice to them or requiring a third party to provide this on Our behalf (see “What Personal Data the Firm Processes” above);
• ensure that the Processing matches the description provided in Our privacy notice, is not re- purposed for any new purpose and is not used in ways that Data Subjects would not reasonably expect; and
• must have a lawful basis for Processing the data (see “Lawful basis for Processing” below).

2. Purpose limitation, which means that We:

• must only collect Personal Data for specified, explicit, and legitimate purposes (you must only use Personal Data that you have access to for the purposes of performing your approved work activities); and
• must not Process the Personal Data in a manner that is incompatible with those purposes, except under limited circumstances. If you are not sure whether you are authorised to carry out a particular Processing activity, you must check with legal@400capital.com.

3. Data minimisation, which means that Personal Data Processed by Us must be:

• adequate;
• relevant; and
• limited to what is necessary for the purpose of Processing.

We must ensure that We only collect and retain Personal Data We need to achieve Our identified purposes.

4. Accuracy, which means that Personal Data must be:

• accurate and kept up-to-date; and
• corrected or deleted without delay when inaccurate.

We must ensure that give individuals the tools to update their data, or ensure that We update it should they contact Us advising Us of any change / error.

5. Storage limitation, which requires Us to keep Personal Data in an identifiable form only for as long as necessary to fulfil the purposes Us collected it for, subject to limited exceptions. We must identify appropriate retention periods for each Processing purpose and ensure that We purge Personal Data.

6. Integrity and confidentiality, which requires Us to secure Personal Data by implementing appropriate technical and organisational measures against unauthorised or unlawful Processing, and against accidental loss, destruction, or damage.

7. Accountability, which means that We must be capable of demonstrating its compliance with the principles outlined above. We achieve this through developing this Policy and ensuring that all staff members comply with this Policy and any other policies, standards and procedures that are relevant to their roles and through a framework of record-keeping and privacy governance.

To assist in achieving the above data protection principles, the Firm is subject to policies and procedures of 400 Capital Management LLC (the “Adviser”) which are designed and implemented with the following core principles:

• Being proactive in preventing rather than reactive in responding to Personal Data Breaches
• Placing a higher value on privacy than data collection
• Integrating and embedding privacy into designs and updates
• Valuing privacy over the cost of safeguarding and protecting Personal Data
• Designing full lifecycle protection for collected data
• Promoting transparency with your users in your Privacy Policy and legal agreements
• Placing the user first when it comes to their data

Action: If you have reviewed this Policy and completed the relevant training but are not sure how to comply with the data protection principles, please contact legal@400capital.com.

Lawful basis for Processing

To comply with the data protection principles and specific obligations under the GDPR, the Firm must only Processes Personal Data where it has a lawful basis to do so under Data Protection Laws. The available lawful bases are as follows:

1. Consent – the individual has given consent to the Processing for one or more specific purposes. Consent under Data Protection Laws is a high standard and so We typically do not rely on consent unless We have to.

Action: If you think that you need to collect or rely on consent for a particular use of Personal Data, please contact the legal@400capital.com.

2. Necessary for performance of a contract – the Processing is necessary for the performance of a contract with the individual or in order to take steps at the request of the individual prior to entering into a contract (for example, where an individual who is not yet a customer has requested an insurance quote);

3. Legal obligation – the Processing is necessary for compliance with a legal obligation provided for in UK or EU law (as applicable) to which the Firm is subject;

4. Vital interests – the Processing is necessary in order to protect the vital interests of the individual or of another natural person;

5. Public functions – the Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Firm; and

6. Legitimate interests – the Processing is necessary for the purposes of the legitimate interests pursued by the Firm or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the Data Subject which require protection of Personal Data, in particular where the Data Subject is a child.

Action: If you are considering any proposed new use of Personal Data or a variation to Our use of Personal Data, please contact legal@400capital.com so that they can determine the appropriate lawful basis.

Summary of Data protection obligations

To address its obligations under the GDPR the Firm will:

1. Conduct Data Protection Impact Assessments where required to do so.

Action: If you are making any changes to the work you perform or to any of the Firm’s business activities or services that will require a new data Processing operation to be introduced, please contact legal@400capital.com so they can consider whether a Data Protection Impact Assessment is necessary.

2. As set forth in the Adviser’s Electronic Transfer of Non-Public Personal Information Policy and Procedures and Cybersecurity Policies and Procedures, establish reasonable safeguards to protect data of Data Subjects from compromise or loss. Such safeguards include the use of encryption and anonymization/pseudonymization of Personal Data.

3. As set forth in the Adviser’s Business Continuity Plan and Cybersecurity Policies and Procedures, develop an incident response plan to include Personal Data Breach notification requirements. The Adviser has established information and reporting controls to identify and report Personal Data Breaches to Supervisory Authorities (Sas) within 72 hours of becoming aware of the Personal Data Breach.

Action: If you become aware of any actual or suspected Personal Data Breach or security breach, please contact legal@400capital.com and the Chief Technology Officer immediately.

4. Respond to Data Subject Rights Requests in a timely and compliant manner and in any case within 1 month unless the request is particularly complex. The Firm will continue to keep a record of the request and response.

Action: You must consider whether a communication from a Data Subject constitutes a Data Subject Rights Request. In practice, you must treat any request received from a Data Subject which relates to Our Processing of their Personal Data as a Data Subject Rights Request in the first instance. If you receive a Data Subject Rights Request, please contact legal@400capital.com immediately.

5. Prepare and deliver a privacy notice to individuals with information on the purpose for which Personal Data is used.

6. In conjunction with the Adviser’s Cybersecurity Policies and Procedures, build and maintain detailed Personal Data Processing records including detailing:

• name and contact details of the Controller and, where applicable, the joint controller, the Controller’s representative and the data protection officer;
• the categories of Personal Data Processed and Data Subjects;
• the purpose of Processing the data;
• lawful basis for the Processing;
• categories of recipients of that data, including recipients in third countries or international organisations;
• transfers of the data to non-European Economic Area (“EEA”) and non-UK countries,
• retention periods, and,
• where possible, a description of the technical and organizational safeguards the Firm has implemented to protect the data; and
• additionally, where We act as a Processor, the name and contact details of the Controller on behalf of which We are acting, their representative and data protection officer and the categories of Personal Data carried out on behalf of each Controller.

7. Conduct training on a periodic basis, no less than annually, to promote privacy and data protection awareness among the Firm’s staff.

8. Only disclose or transfer Personal Data to a third party where it has a legal right to do so under the UK/EEA Data Protection Laws. For this, We must determine the scope and purpose of the data sharing, whether the sharing is really necessary for the purpose, whether this represents a new instance of Processing and whether a data transfer (export) arises (including where data is just accessed from a non-UK/EEA country).

9. Conduct due diligence to verify that Our vendors are capable of performing their respective duties in accordance with requirements under UK/EEA Data Protection Laws. As part of this effort the Firm will ensure that mandatory data protection provisions are included within each vendor agreement under which the vendor acts as a Processor on behalf of the Firm.

Action: If you consider sharing or transferring Personal Data with a third party, particularly, in a non-UK/EEA country, you must keep a record of the data sharing agreement and provide a copy to legal@400capital.com.

Glossary

Adviser means 400 Capital Management LLC

Controller means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the Processing of Personal Data

Data Subject means an individual to whom Personal Data relates

Data Subject Rights Requests are requests to: understand what Personal Data is held by the Firm or to receive access to or a copy of that Personal Data (a Data Subject Access Request or DSAR or in some cases, a data portability request); rectify inaccurate Personal Data; erase Personal Data; restrict or limit Our use of Personal Data; object to the issue of direct marketing; or object to the Processing of their Personal Data. Firm means 400 Capital Management Europe Limited

Personal Data is very widely defined (and defined more widely than “Personal Identifying Information” for example) and includes any information relating to an identified or identifiable natural person (Data Subject); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person

Personal Data Breach means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, Personal Data transmitted, stored or otherwise Processed

Processed/Processing essentially means the collection and use of Personal Data and includes any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction

Processor means a natural or legal person, public authority, agency or other body which Processes Personal Data on behalf of the Controller

Supervisory Authority an independent public authority which is established by a Member State pursuant to Article 51 GDPR or the Information Commissioner’s Office in the UK

UK/EEA Data Protection Laws comprises (1) in the UK, the UK version of the GDPR, the UK Data Protection Act 2018 and Privacy and Electronic Communications (EC Directive) Regulations 2003, and (2) in the EU, the European Union General Data Protection Regulation 2016 (the GDPR), local legislation that supplements and interprets the GDPR and local legislation implementing Directive 2002/58/EC of the European Parliament and of the Council of 12 July 2002 concerning the processing of personal data and the protection of privacy in the electronic communications sector (Directive on privacy and electronic communications)

Cayman Islands Privacy Notice

Personal data is subject to the Data Protection Law, 2017 of the Cayman Islands, as amended from time to time and any regulations, codes of practice or orders promulgated pursuant thereto (“DPL”).

If your personal data is subject toeither the DPL, please review the following information.

For the purposes of the DPL, in its use of personal data, the Fund will be characterised as a ‘data controller’, whilst certain of the Fund’s service providers, affiliates and delegates may be characterised as ‘data processors’. For the avoidance of doubt, the Investment Manager is not a ‘data controller’ for purposes of the DPL.

1. What are the lawful bases for processing your personal data?

For purposes of compliance with the DPL, we have reviewed the purposes and appropriateness of our activities, and those of the processors of your personal data, in each case, as related to the processing of your personal data. The lawful bases for processing your personal data are as follows:

Performance of contract: to ensure the ability of the Fund to perform its obligations under the subscription agreement, the constitutional documentation of the Fund, and other documents that together form the basis for the investor’s contractual relationship with the Fund, and certain required pre-contractual steps. This may include the following circumstances:

• to operate the Fund, including managing and administering the Fund on an on-going basis which enables the Fund and its investors to satisfy their contractual duties and obligations to each other;
• to process your subscription, investment or redemption in the Fund or any payment or distribution to you, such as recording your information in the registers and accounts of the Fund;
• to send you statements in relation to your investment in the Fund;
• to facilitate the continuation or termination of the contractual relationship between you, other investors and the Fund; and/or
• to administer and facilitate the transfer of funds and other transactions between you, other investors and the Fund.

The Fund and the Investment Manager may be legally obliged to process certain personal data in order to be able to perform services and business operations or to comply with contractual requirements. If individuals choose not to provide the Fund and the Investment Manager with the necessary personal data or to restrict the Fund and the Investment Manager from processing personal data, the Fund and the Investment Manager may not be able to meet their obligations or deliver the products or services requested. This may lead to cancellation of contracts; if this is the case, the Fund or the Investment Manager, as applicable, will endeavor to contact the individuals to discuss this.

Legal obligations: the Fund and the Investment Manager are required to comply with legal and regulatory requirements applicable to them. This may include the following circumstances:

• to undertake investor due diligence and on-boarding checks;
• any regulatory or tax reporting requirements (including FATCA, CRS and other comparable legislation);
• to carry out know-your-client, client due diligence, and money laundering/terrorist financing/proliferation financing checks;
• to carry out conflict checks;
• for purposes of fraud prevention;
• to comply with any applicable auditing or financial reporting requirements (including carrying out audit checks and to instruct auditors);
• to comply with applicable sanctions and embargo legislation;
• to maintain statutory registers;
• for purposes of enhanced due diligence, investigation activities and security and other checks on various counterparties; and
• to comply with information disclosure requests from regulatory, tax or other governmental or public authorities.

Consent: Your personal data may also be processed where you have provided your consent to such processing.

Legitimate Interests: In addition to the above lawful bases for processing your personal data, your personal data will also be processed on the basis of the legitimate interests of the Fund and the Investment Manager,including their legitimate interests:

• to exercise and comply with the Fund’s and/or the Investment Manager’s rights and legal, tax or accounting obligations at law or under regulation, or under contract (including for the purposes ofsubscription to funds or the provision of investment management services);
• to manage and administer the Fund’s and/or the Investment Manager’s business and to improve relationships with other investors in the Fund or investors in other funds managed by the Investment Manager, and assist with investor relationship management, and for marketing and business development activities and analysis;
• to communicate with the investor in respect of the Fund or other products offered by the Investment Manager or its affiliates, for risk assessment and control, for statistical and trend analysis, for system administration, operation, testing and support and to operate control systems and management information systems;
• to help detect, prevent, investigate, and prosecute fraud and/or other criminal activity;
• to manage the Investment Manager’s information and technology and to ensure the security of the Investment Manager’s systems;
• to disclose information to a governmental, tax or regulatory body, financial market, broker or other intermediaries, counterparties, court, auditors or other third parties and to conduct compliance activities, when any of the Investment Manager and the Fund think this is in any of their, or someone else’s interests,;
• to establish, exercise or defend legal claims and in order to protect and enforce the Investment Manager’s and/or the Fund’s rights, property, or safety, or to assist the investors in the Fund or investors in other funds managed or advised by the Investment Manager, or others to do this;
• to investigate and respond to any complaints about the Investment Manager and its business or any incidents relating to the Fund and/or the Investment Manager’s business and to help maintain quality and to deal with complaints and disputes; and
• to make certain assessments about the investor in order to assess the investor’s investment objectives, risk tolerance, and understanding of investment risk to assess the suitability of an investment in the Fund or other product offered by the Investment Manager or its affiliates.

When processing your personal data, the Fund will be subject to, and shall comply with, the relevant requirements contained in the DPL.

2. Transfers of your personal data outside the Cayman Islands, as applicable.

Any transfer of personal data outside of the Cayman Islands shall be in accordance with the requirements of the DPL. Where necessary, we will ensure that separate and appropriate legal agreements are put in place with the recipient of that data. For example, where data is to be transferred to a person in a country that does not provide an adequate level of data protection, the Fund will ensure it puts in place appropriate safeguards, such as contracts which seek to ensure that any data processor is contractually bound to provide an adequate level of protection in respect of the personal data transferred to it and that any such transfer complies with the requirements of the DPL.

3. Your rights in relation to the personal data we process about you

You may have various rights under the DPL in relation to your personal data. These include:

• the right to be informed as to how we collect and use your personal data;
• the right to request access to your personal data;
• the right to have your personal data rectified;
• the right to have your personal data erased in certain circumstances;
• the right to request that your personal data is only used for restricted purposes;
• (if the lawful basis for processing your personal data is legitimate interest) the right to object to your personal data being processed, for example, for marketing;
• the right to withdraw your consent and require us to stop processing or restrict the processing, or not begin the processing of your personal data;
• the right to be notified of a data breach (unless the breach is unlikely to be prejudicial);
• the right to obtain information as to any countries or territories outside the Cayman Islands, to which we, whether directly or indirectly, transfer, intend to transfer or wish to transfer your personal data, general measures we take to ensure the security of personal data and any information available to us as to the source of your personal data;
• (in some circumstances) the right to require certain of your personal data to be transferred to you or a third party; and
• the right to lodge a complaint with the relevant data regulator in your jurisdiction.

You can seek to exercise any of these rights by contacting the Investment Manager at ir@400capital.com.

Please note that if you do not wish to provide us with requested personal data or subsequently withdraw your consent, you may not be able to invest in the Fund or remain invested in the Fund as it will affect our ability to provide our services to you and manage your investment.

Complaints regarding the processing of your personal data by the Investment Manager may also be made directly to the relevant data protection regulator.

Cookies Policy as of March 2024

At 400 Capital Management, accessible from 400capital.com, one of our main priorities is the privacy of our visitors. This Cookies Policy page explains what cookies are, how we use them, the types of cookies we utilize, how third-party cookies are used on our website, and your choices regarding cookies.

What Are Cookies?

Cookies are small text files that are used to store small pieces of information. They are stored on your device when the website is loaded on your browser. These cookies help us make the website function properly, make it more secure, provide better user experience, and understand how the website performs and to analyze what works and where it needs improvement.

How Do We Use Cookies?

As most of the online services, our website uses first-party and third-party cookies for several purposes. First-party cookies are mostly necessary for the website to function the right way, and they do not collect any of your personally identifiable data.

The third-party cookies used on our website are mainly for understanding how the website performs, how you interact with our website, keeping our services secure, providing advertisements that are relevant to you, and all in all providing you with a better and improved user experience and help speed up your future interactions with our website.

What Types of Cookies Do We Use?

Essential: Some cookies are essential for you to be able to experience the full functionality of our site. They allow us to maintain user sessions and prevent any security threats. They do not collect or store any personal information.

Statistics: These cookies store information like the number of visitors to the website, the number of unique visitors, which pages of the website have been visited, the source of the visit, etc. This data helps us understand and analyze how well the website performs and where it needs improvement. Our website uses Google Analytics for this purpose. The cookies used by Google Analytics are:

• Google Tag Manager, Google API, Google Static, and fontawesome.

Explanation:

• Purpose: Describes what each cookie is used for.
• Duration: Indicates how long the cookie will stay on the user’s device. Google Analytics cookies like ga and _ga typically have a default expiration time of 2 years, which resets on each visit. _gid expires after 24 hours, and _gat expires after 1 minute.
• Necessary: Specifies whether the cookie is essential for the website’s operation. In this context, “No” is used because these cookies are for analytics purposes, which are not strictly necessary for the website’s basic functionality but are crucial for understanding user behavior and improving the site.
• Description: Provides a rationale for the use of each cookie, emphasizing the importance of analytics in enhancing website performance and user experience.

How Can You Control the Cookie Preferences?

You can manage your cookies preferences by adjusting your browser settings accordingly. Thus, you can remove cookies stored in your computer via your browser settings. Additionally, most browsers offer functionality that lets you review and erase cookies, including [Your Website Name] cookies. Please note that our website may not work properly without the essential cookies.

For more information about managing cookies, please visit your browser’s help material.

Privacy Policy

For more information about how we use information collected by cookies and other tracking technologies, please refer to our Privacy Policy page. This Cookies Policy should be read in conjunction with our Privacy Policy.

By using our website, you consent to the use of cookies in accordance with this Cookies Policy.

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