WINDMILL CAPITAL MANAGEMENT LLC ONLINE PRIVACY POLICY

At Windmill Capital Management LLC (“Windmill”), your privacy is very important to us.  This Online Privacy Policy (the “Privacy Policy”) explains Windmill’s practices pertaining to the online collection of personally identifiable information, and the way such information is collected and used.  Links to this Privacy Policy notice are available on our homepage and throughout our website wherever personally identifiable information may be requested or collected.  This Privacy Policy is incorporated in the Terms of Use and by using the Investor Portal you are bound to this Privacy Policy.  This Privacy Policy is effective as of March 2016.  Any changes we may make to this Privacy Policy in the future will be posted on this page.

WHAT INFORMATION WE COLLECT
This Policy applies to information collected from, or which may be submitted to, the Windmill website.  At the present time, we do not collect any personally identifiable information about visitors to the publicly available areas of our website.  We may collect email addresses of those of our limited partners who choose to access the private, restricted area of our website that is reserved for our limited partners.  At times, visitors to our website may choose to email individuals at Windmill using links available on the website; in such instances, a visitor’s email address may be collected as part of the process of sending the email to us in order to enable us to reply to those emails.  We may, however, but have no obligation to, monitor and record other activity on our website for any reason or for no reason.

Our website uses “cookies” technology, through which small amounts of data are sent to your computer from our web server and stored on your computer’s hard drive.  This data identifies you as a unique user when visiting our website, and helps us in the ongoing maintenance of our website.  This technology does not provide us with any information about your name, address phone number or email address, or any other personally identifiable information.  We do, however, log visitor IP addresses.

HOW WE USE INFORMATION WE MAY COLLECT
To the extent we collect information from visitors to the publicly available areas of our website, we do not share such information with any parties outside of our company other than when required by a valid subpoena or court order, or as otherwise required by law.  In the event that a visitor submits his or her email address or any other personally identifiable information to us via our website while requesting information or sending any email to someone at Windmill, other than as described above, we never use such information for any other purpose, and will not disclose such information to any outside party.

This Privacy Policy is in addition to our Windmill Capital Management LLC Privacy Notice applicable to Windmill investors.

DATA AND NETWORK SECURITY
We maintain operational policies, including physical, electronic and procedural protections, to safeguard and secure our data networks against unauthorized access to data we may collect online, and have appropriate policies in place to ensure that any information we collect is used in compliance with this Privacy Policy.

ACCESS TO PORTFOLIO COMPANY AND OTHER THIRD PARTY WEBSITES
Our website contains links to websites controlled and maintained by our current or former portfolio companies and other third parties.  We provide these links solely as a convenience for you.  We do not have any control over the content of these websites, and we assume no liability or responsibility for such sites, the content contained therein, or the manner in which any information collected on such sites are used.  This Privacy Policy does not govern the use of information collected on such third party websites.

INTERNATIONAL USERS
As set forth in the Terms of Use, data we collect from users of the Investor Portal within the European Union, will be transferred to, and stored at, destinations outside the European Economic Area (the “EEA”) including, without limitation, in the United States.  It will also be processed by staff operating outside the EEA who work for us or for one of our suppliers. By submitting your personal data, you consent to its storage, processing and transfer outside the EEA, including, without limitation, in and to the United States.