We at Portfolio Advisors, LLC, understand that users of this Site are concerned about the privacy of information. PALLC has established policies and procedures concerning the collection, use and security of information that will help protect the privacy of users of this Site. Our privacy standards are designed to help us serve our users while maintaining our own strict security standards, and are intended to comply with the data protection laws of the United States.

By using this website, you acknowledge and accept the practices and policies outlined below, and you hereby consent to our collection, use and sharing of your Personal Information as described on this site.

We will collect information about the Internet Service Providers and the Browsers that visitors use to visit our Site and we will use this aggregated information statistically to serve our users better. This Site does serve cookies. A cookie is a small file that is created to help visitors navigate about a website, and is useful to track the traffic to and at a site and to personalize the website. You may refuse the cookies but certain services on a website may not then function properly.

Web Trends Tracking

Portfolio Advisors tracks Web usage information, such as the number and frequency of visitors to this Web site. This information may include the Internet browser you are using and your IP address.

Security

We cannot provide any assurance of privacy over a network that is not a secure network or over a network that we do not control. The Internet is not a secure network and, aside from our own servers, not within our control.

Electronic Message and E-Mail Security – Messages traveling through the Internet using your Internet provider’s e-mail process are subject to viewing, alteration and copying. We are not responsible for the security or confidentiality of communications you send to this Site through the Internet using the e-mail process.

Updates to the Privacy Policy

This Privacy Policy is subject to occasional revision, and if we make any material changes in the way we use your Personal Information, we will notify you by sending you an email to the last email address you provided to us and/or by prominently posting notice of the changes on the Services and updating the effective date above.

Personal Information

We do not disclose non-public personal information about you other than as described below.

In connection with our private investment funds and/or other financial services we provide to you, we collect and maintain non-public personal information about you from the following sources:

• Information we receive from you in subscription agreements, investor questionnaires, applications or other forms;
• Information about transactions effected for your account; and
• Information about the status and value of your account.

To the extent that the SEC regulations permit, or applicable law requires, we may disclose the information we collect, as described above, in connection with processing and servicing fund and/or advised account transactions, partner financial or other reports, or for other permitted purposes to selected third parties and financial service or non-financial service providers, including:

• Financial service providers such as broker-dealers, custodians, banks and others used to facilitate transactions on your behalf;
• Other service providers to the manager and/or our private funds, such as accounting or tax preparation services; and
• Corporate counsel in connection with the rendering of opinions and other matters in connection with our private funds.

We may also disclose non-public personal information about you if we are required to do so by other regulations or by judicial process. We do not otherwise disclose any non-public personal information about you and, as a result, there is no need to provide you with a right to “opt-out of disclosure” of your information as required by the Gramm-Leach-Bliley Act for financial institutions that disclose such information to non-affiliated third parties.

We may also disclose information you provide to us to companies that perform marketing services on our behalf, such as the Fund’s placement agent(s). If such a disclosure is made, the Fund will require such third parties to treat your private information with confidentiality.

We maintain physical, electronic and procedural safeguards designed to protect your non-public personal information in our possession or under our control, including but not limited to social security numbers and account numbers by, among other things, limiting those with access to such information. If we decide to change our privacy policy in the future, we will notify you of the change before it becomes effective. Please be assured that we consider privacy to be fundamental to our relationship with our clients and investors.

As always, please do not hesitate to call us if you have any questions or comments regarding this Privacy Policy.

Contact / Postal Mail

Portfolio Advisors, LLC
9 Old Kings Highway South
Darien, CT 06820

Additional Information for Residents of the European Economic Area and United Kingdom

Unless otherwise defined below, terms in this section have the meaning given to them in the European Union General Data Protection Regulation and equivalent regulation in effect in the United Kingdom (“GDPR”).

How we collect information about you

In addition to the above personal data collection methods, we may collect personal data (including publicly available personal data) about you through:

• information provided directly to us by you, or another person on your behalf, through our website, by email or post, or in person;
• information that we obtain in relation to any transactions between you and us;
• the use of internet “cookies” as described above.

We may also, in some circumstances, receive personal information about you from third parties, such as service providers or trading counterparties, regulatory or law enforcement agencies, credit reference agencies and agencies conducting background checks. Personal information may also be obtained from publicly accessible sources of information, such as public databases, industry associations, social media and online professional networks.

Why we collect information about you

PALLC and its affiliates (including Portfolio Advisors Capital UK, Ltd) may collect and use your personal information for the purposes of administering the relationship between us, marketing our products and services to you or the businesses with which you are associated, monitoring and analyzing our activities, and complying with applicable legal or regulatory requirements.

We will use one of the permitted grounds under the applicable law to process your information. Such grounds include instances where you have given your consent and cases where your consent is not required under applicable law, such as where we are required to comply with a legal obligation, or where we, or a third party, determine that it is necessary for our legitimate interests to collect and use your personal information.

The legitimate interests to collect your personal information may include any of the purposes identified above and any other purpose where we or a third party have determined that you have a reasonable expectation for us or a third party to collect or use your personal information for such purpose. You have the right to object to the use of your personal data for direct marketing purposes.

The types of personal data we may collect and use

The categories of personal data we may collect will depend on the nature of our relationship with you and the purpose for which information is being collected. Such personal data may include names, residential addresses or other contact details, signature, nationality, date and place of birth, national insurance or other tax identification number, photographs, copies of identification documents, bank account details, information about assets or net worth, credit history, criminal and administrative offences, source of funds details, or other sensitive information, such as certain special categories of personal data contained in relevant documents or materials [(including, in some circumstances, information about a person’s ethnic origin, religious beliefs, or health)] ¹.

Do we use automated decision-making processes?

No.

Do we share your personal information with third parties?

In addition to the above sources we may disclose personal data to, we may (to the extent relevant to the purpose for which we collect your information), share your personal data (including publicly available personal data) with third parties, such as:

• our affiliates or other entities that are part of our group or with our clients;
• any person to whom we have a right or obligation to disclose personal data, or where we determine that disclosure is necessary to protect or defend our rights or property, including with regulators, courts of law, governmental, regulatory or law enforcement agencies;
• our internet, IT, telecommunications and other service providers;
• service providers and trading counterparties to our clients;
• credit reference agencies and other third parties conducting background checks in the context of employment or client, counterparty, or investment due diligence;
• any person, as directed by you; or
• any person to whom we transfer any of our rights or obligations under any agreement, or in connection with a sale, merger or consolidation of our business or other transfer of our assets, whether voluntarily or by operation of law, or who is otherwise deemed to be our successor or transferee.

International transfers of personal data

Due to the international nature of our business, your personal data may be transferred to countries outside of the European Economic Area or United Kingdom (as applicable), such as to jurisdictions where we or our clients conduct business or have a service provider, including countries that may not have the same level of data protection as that afforded by the GDPR (including or other data protection rules applicable to us (collectively, “Data Protection Law”). In these circumstances, we take steps to ensure that the recipient agrees to keep your information confidential and that it is held securely in accordance with the requirements of Data Protection Law, such as by requesting appropriate contractual undertakings in our legal agreements with service providers.

For how long do we keep your personal information?

We will generally keep personal information about you for as long as necessary in relation to the purpose for which it was collected, or for such longer period if required under applicable law or necessary for the purposes of our other legitimate interests.

The applicable retention period will depend on various factors, such as any legal obligation to which we or our service providers are subject as well as on whether you decide to exercise your right to request the deletion of your information from our systems. As a minimum, information about you will be retained for the entire duration of any business relationship we may have with you, and for a minimum period of five years after the termination of any such relationship.

We will, from time to time, review the purpose for which we have collected information about you and decide whether to retain it, update it, or securely delete it, if the information is no longer required.

What are your rights?

You have certain rights under Data Protection Law in respect of the personal data we hold about you and which you may exercise. These rights are:

• to request access to your information;
• to request rectification of inaccurate or incomplete information;
• to request erasure of your information (a “right to be forgotten”);
• to restrict the processing of your information in certain circumstances;
• to object to our use of your information, such as where we have considered such use to be necessary for our legitimate interests (e.g. in the case of direct marketing activities);
• where relevant, to request the portability of your information;
• where you have given consent to the processing of your data, to withdraw your consent; and
• to lodge a complaint with the competent supervisory authority.

Complaining to EU Supervisory Authority or UK Information Commissioner’s Office

You may make a complaint to the relevant supervisory authority of the country where you are resident. A complaint in respect of Portfolio Advisors Capital UK, Ltd may also be made to the Information Commissioner's Office in the United Kingdom.

Click here for additional contact information.

 ¹ [Portfolio Advisors to please confirm if such data is obtained as part of DEI monitoring initiatives.]