ACCOLADE CAPITAL MANAGEMENT LLC

 Website Privacy Notice

Effective Date: May 16, 2024

This Privacy Notice describes how Accolade Capital Management LLC (together with its affiliates, “Accolade” “we,” “our,” or “us”) processes personal data we collect through our website at www.accoladepartners.com (the “Website”). A separate Global Investor Privacy Statement applies if you are an investor, former investor, or prospective investor in funds managed by Accolade.

Your visit to the Website is subject to this Privacy Notice. By visiting the Website, you agree to this Privacy Notice, which may be updated by us at any time and constitutes a legal agreement between you and Accolade. We will post any updates to this Privacy Notice here, and any changes will be effective upon publication. You should consult the Privacy Notice on this Website each time you visit it; if you do not agree with its terms, please do not use the Website.

When we use the term “personal data” in this Privacy Notice, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual.

Information We Collect About You

When you visit and browse the Website, we may collect two different types of data about you: information you provide us and information we automatically collect.

Information You Provide. Information you may choose to provide Accolade using any means of contact listed on the Website, such as the “Contact Us” form, includes your first and last name, email address, and other personal data from the message submitted. You may provide additional information—including your password, account information, and certain financial information—when signing into and navigating our online investor portal.

Information We Automatically Collect. We automatically collect certain information when you access and use our Website, such as your IP address, browser type, operating system, device used, geolocation data, the pages you view on the Website, time spent on each page, traffic sources, the pages you view immediately before and after you access the Website, and date/time stamps. We and third parties, including our service providers, collect information using “cookies,” web beacons, and similar technologies.

How We Use Your Information

We collect personal data about you for the purposes of and pursuant to the legal bases of contract performance, legal compliance, legitimate interests, and with your consent. Specifically, we use the information for the following purposes: (i) to verify your identity when you communicate or engage with us; (ii) to communicate with you; (iii) to improve our Website; and (iv) to exercise our legal rights as provided to us by applicable law and where it is in our legitimate interests and necessary to do so, for instance, to detect, prevent, and respond to fraud claims, IP infringement claims, or misuse of our information or Website.

How We Share Your Information

We disclose and have disclosed over the last 12 months information collected about you to affiliates and  selected third parties, including:

·         Recipients to whom we must disclose such information when required by a valid subpoena or court order, or as otherwise required by applicable law, regulation, legal or judicial process or audit, decision of a court or arbitral tribunal, decision of a governmental authority with relevant powers, or by the rules of applicable stock exchange or recognized market place, or requested or required by a regulator, bank examiner or self-regulatory organization or pursuant to mandatory ethics rules; and

·         Providers of professional advisory or information technology services, including consultants, legal advisors, accountants, and other third-party service providers.

We may also share your information in connection with an asset sale, merger, bankruptcy, or other business transaction, to enforce any applicable terms of service, to ensure the safety and security of Accolade, and when you request that we share certain information with third parties.

We do not sell personal data or share such data for purposes of cross-context behavioral advertising and have not done so within the last 12 months.

Data Retention and Protection

We will retain your personal data for as long as is necessary for the processing purposes set out in this Privacy Notice, subject to your rights. Under certain circumstances, you may have the right to have certain personal data erased (see Data Subject Rights below), unless a longer retention period is required under applicable Data Protection Laws.

We implement administrative, technical, and physical safeguards designed to protect personal data from unauthorized access or use. Unfortunately, no data transmission or storage system is completely secure. If you have reason to believe that your personal data is being misused or is no longer secure, please immediately notify us.

Do Not Track Signals and Cookies

Accolade does not track its visitors over time and across third party websites to provide targeted advertising and does not respond to Do Not Track (“DNT”) signals. However, some third party sites do keep track of your browsing activities when they provide content, which enables them to tailor what they present to you. If you are visiting such sites, your browser allows you to set the DNT signal so that third parties know you do not want to be tracked. You should consult the help pages of your browser to learn how to set your preferences so that websites do not track you.

We use cookies primarily to capture anonymous analytics to improve your experience with the Site and its performance. You may control the way in which your devices permit the use of cookies and other tracking technologies. If you so choose, you may block or delete our cookies from your browser; however, blocking or deleting cookies may cause some aspects of the Website to work incorrectly.

Data Subject Rights

Residents of some U.S.  states—as well as individuals outside the U.S. in Andorra, Argentina, Australia, Canada, Europe, Faroe Islands, Guernsey, Hong Kong, Israel, Isle of Man, Japan, Jersey, Mexico, New Zealand, Singapore, South Korea, Switzerland, the United Kingdom, Uruguay, and other jurisdictions—may have certain data subject rights. These rights vary, but they may include the right to: (i) request additional disclosures about the personal data we collect, use, and disclose, i.e., a “Request to Know (Categories of Information”); (ii) obtain a copy of personal data in a portable format, i.e., a “Request to Know (Specific Pieces of Information),” sometimes called the Right to Access or Right to Data Portability; (iii) request erasure of personal data, i.e., a “Request to Delete Information,” sometimes called the Right to Be Forgotten; (iv) request the correction/rectification of personal data; (v) restrict or object to the processing of personal data; and (vi) opt out of the sale of personal data, sharing of personal data for purposes of cross-context behavioral advertising, targeted advertising, and profiling in furtherance of decisions that produce legal or similarly significant effects, i.e., a “Request to Opt Out.”

Individuals may also have the right to not be discriminated against for exercising applicable data subject rights and may lodge a complaint about the processing of personal data with an applicable data protection authority or other regulator. If you wish to exercise one of these rights, please send us your request using the Contact Information below. The rights described herein are not absolute and we reserve all of our rights available to us at law in this regard.

We will need to verify your identity prior to addressing your request. Only you, or someone legally authorized to act on your behalf, may make a verifiable request related to personal data collected about you. To designate an authorized agent, the authorized agent must provide sufficient information that allows us to reasonably verify that they have been authorized by you to act on their behalf. We will process your request within the time provided by applicable law.

Children

Although this Website is not targeted toward children, we are concerned about the safety and privacy of children who use the internet. We do not knowingly collect personal data from children under the age of 16, nor do we disclose such information to third parties. However, if a parent or guardian informs us that their child under the age of 16 provided personal data to us through the Website without our knowledge, we will allow the parent or guardian to review the information and will delete it from our database, subject to applicable law.

International Use

Our Website is hosted in the United States, and the personal data it collects is stored in the United States. If you access this Website from outside the United States, you do so at your own risk and are responsible for compliance with local laws, rules, and regulations. By sending us your personal data, you consent to its transfer to and storage within the United States.

Contact Information

If you would like further information about the processing of your personal data or to exercise any right listed above, please contact our Chief Compliance Officer at compliance@accoladepartners.com or by phone at 202-775-5595.