Investor Data Privacy Notice

Last updated: December 1, 2025

Why are you seeing this notice?

You may need to provide Personal Data to us as part of your investment into a fund or other investment vehicle (as applicable, the Fund) managed or advised by investment advisers or management companies that are subsidiaries of Windmill Capital Management, LLC. or its affiliates (and, where applicable, the general partner of the relevant Fund) (collectively, Windmill).
We want you to understand how and why we use, store and otherwise process your Personal Data when you deal with us or our relevant affiliates (including under applicable data protection laws). If this notice (the Data Privacy Notice) has been made available to you, you may have certain rights with respect to your Personal Data under applicable data protection laws (including as described in this Data Privacy Notice).
“Personal Data” has the meaning given to it under data protection laws that apply to our processing of your personal information, and includes any information relating to an identified or identifiable individual (such as name, address, date of birth, personal identification numbers, sensitive personal information, and economic information).
We ask that investors promptly provide the information contained in this Data Privacy Notice to any individuals whose Personal Data they provide to the Fund or its affiliates in connection with ‘know your client’ / anti-money laundering requests or otherwise.

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

Who is providing this notice?

Windmill is committed to protecting and respecting your privacy. Windmill is a global financial services firm with its primary office at 825 Oak Grove Ave., Suite A206, Menlo Park, CA 94024

For transparency, the Windmill entities on whose behalf this privacy statement is made are: (i) the Fund; and (ii) where applicable, the Windmill general partner, manager and/or investment adviser of the relevant Fund, in each case, with which you contract, transact or otherwise share Personal Data (together, the Fund Parties).
Where we use the terms “we”, “us” and “our” in this Data Privacy Notice, we are referring to the Fund and the Fund Parties.
Please consult your subscription documents, private placement memorandum or other offering documentation provided to you by or on behalf of the Fund Parties which will further specify the entities and contact details of the Fund Parties relevant to our relationship with you.
We welcome investors and their representatives to contact us if they have any queries with respect to the Fund Parties (in particular, which Fund Parties are relevant to their relationship with Windmill). If you have any queries, please see the ‘Contact Us’ section.

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

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

What personal data do we collect about you?

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

Contact information, such as name, e-mail and postal address, and phone number;
Demographic information, such as date and country of birth, gender, country of residence, nationality, and citizenship;
Government-issued identification numbers provided in connection with a subscription to Funds, such as Social Security number, driver’s license number, passport number, national identification number, and tax identification number;
Professional or employment-related information, such as the name of your employer or the organization you represent and your position;
Financial information, such as information related to your transactions with us or others, bank account details (e.g., account and routing number), financial account history, information concerning the source of funds used for investments, and details regarding your investment history (e.g., types and amounts of investments) assets, income, and financial returns and positions;
Investment preferences;
Information related to background checks (e.g., “know your client”, anti-money laundering and sanctions checks) and any information related to applicable restrictions on your investments, such as political exposure or sanctions;
Information collected in the context of monitoring and surveillance where permitted or required by applicable law, including recordings of telephone and video calls and CCTV; and

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

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

Where do we obtain your personal data?

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

What

Personal data that you give to us

How

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

Personal data that we obtain from others

We obtain Personal Data from:

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

Why do we process your personal data?

We may process your Personal Data for the following reasons:

Why

Contract

How

It is necessary to perform our contract with you to:

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

Compliance with law

It is necessary for compliance with an applicable legal or regulatory obligation to which we are subject, in order to:

Undertake our client and investor due diligence, and on-boarding checks
Carry out verification, “know your client”, terrorist financing, sanctions, and
anti-money laundering checks
Verify the identity and addresses of our investors (and, if applicable, their beneficial owners)
Comply with requests from regulatory, governmental, tax and law enforcement authorities
Carry out surveillance and investigations
Carry out audit checks
Maintain statutory registers
Prevent and detect fraud
Comply with sanctions requirements

Legitimate interests

For our legitimate interests or those of a third party (such as a transaction counterparty or lender) to:

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

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

Monitoring as described in ‘Legitimate Interests’ above

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

We may share your Personal Data as follows:

Who

Fund Associates

Why

We share your Personal Data with our associates, related parties and members of our group. This is:

To manage our relationship with you
For the legitimate interests of a third party in carrying out anti-money laundering, ‘know your client’, and other compliance checks required of them under applicable laws and regulations
For the purposes set out in this Data Privacy Notice

Fund Managers, Depositories, Administrators, Custodians, Distributors, Investment Advisers

Delivering the services you require
Managing your investment
Supporting and administering investment-related activities
Complying with applicable investment, anti-money laundering and other laws and regulations

Tax Authorities

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

Service Providers

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

Finance counterparties. Lenders, Correspondent and Agent Banks

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

Our Lawyers, Auditors and other Professional Advisers

Providing you with investment-related services
To comply with applicable legal and regulatory requirements
Supporting Windmill with the purposes described in section 5 of this Data Privacy Notice

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

Competent regulatory, prosecuting and other governmental agencies or litigation counterparties, in a country or territory; and
Other organizations and agencies – where we are required to do so by law.

Do you have to provide us with this personal data?

Where we collect Personal Data from you, we will indicate if:

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

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

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

Sending your personal data internationally

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

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

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

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

Retention and deletion of your personal data

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

Retain Personal Data about you throughout the life cycle of any investment you are involved in; and
Retain some Personal Data after your relationship with us ends.

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

Your rights

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

Access your Personal Data
Restrict the use of your Personal Data in certain circumstances
Have incomplete or inaccurate Personal Data corrected
Ask us to stop processing your Personal Data
Require us to delete your Personal Data in some limited circumstances

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

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

Concerns or queries

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

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

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

Country

Supervisory Authority

Cayman Islands

Cayman Islands Ombudsman (available at: https://ombudsman.ky)

European Union

A list of the EU data protection authorities and contact details is available by clicking this link.

United Kingdom

Information Commissioner’s Office (available at: https://ico.org.uk/global/contact-us/)

Contact Us

Please contact us if you have any questions about this Data Privacy Notice or the Personal Data we hold about you.

P.O. Box 1103
Menlo Park, CA 94026

Changes to this data privacy notice

We keep this Data Privacy Notice under regular review. Please check regularly for any updates at our investor portal (secure.windmillcapitalmanagement.com).