Privacy Statement

FUND PRIVACY NOTICE

Introduction

The purpose of this Privacy Notice is to provide you with information on our use of Investor Data (as defined below) in accordance with applicable privacy laws that may be enacted from time to time including the Data Protection Act (As Revised) of the Cayman Islands (the “DPA”) the California Consumer Privacy Act as amended by the California Privacy Rights Act (collectively the “CCPA”) and the General Data Protection Regulation (the “GDPR”) as applicable.

In this Privacy Notice “we” “us” and “our” refers collectively to the Fund the General Partner PSG Equity L.L.C. (the “Investment Manager”) and its or their affiliates. References to the “Fund” refer to the particular investment fund(s) to which you are or seek to be admitted which are managed whether directly or indirectly by the Investment Manager and references to the “General Partner” refer to the general partner or similarly placed entity of such Fund.

This Privacy Notice may be updated periodically. On some occasions we may endeavor to notify you of specific personal information processing activities or certain changes to this Privacy Notice as required by applicable law.

Investor Data

“Investor Data” means personal information that reasonably can be associated or linked to you or any other individual person that is an existing former or prospective investor and includes personal information on yourself that you provide to us as well as the personal information of individuals connected with you as an investor (for example directors trustees employees representatives shareholders investors clients beneficial owners or agents).

In our use of Investor Data the Fund General Partner and Investment Manager are each characterized as a “data controller” “controller” or “business” under various legal regimes including DPA GDPR and CCPA as applicable. Except as otherwise described in this Privacy Notice the affiliates and delegates of the Fund General Partner and Investment Manager may act as “data processors” “processors” or “service providers.”

If you are a natural person this will affect you directly. If you are a corporate investor (including for these purposes legal arrangements such as trusts or exempted limited partnerships) that provides us with Investor Data on individuals connected to you for any reason in relation to your investment with us this will be relevant for those individuals and you should transmit this document to such individuals or otherwise advise them of its content.

What Investor Data do we collect and how?

We collect and process (or otherwise verify) the following forms of Investor Data:

• Identifiers such as your name residential and/or business address mailing address email address personal and/or business contact information proof of address driver’s license tax identification number social security (or national insurance or similar) number and passport number and other government identification information and/or numbers.
• Information classified as personal or protected information by state or federal law including your nationality state and/or country of domicile place and date of birth and correspondence records.
• Commercial information including tax information bank account details source of funds details and details related to your investment activity.
• Visual information including your signature.
• Professional or employment-related information including your job title employer’s name place of work work history and income.
• Background information including information needed for or revealed by know-your-customer fraud terrorist financing sanctions and anti-money laundering checks investor due diligence accreditation and consents.
• Financial information and account history including information about your assets income net worth amounts and types of investment profit and loss allocations capital account balances commitments withdrawals redemptions subscriptions and contributions account data other investment participation information fund transfer information beneficiaries positions percentages of fund share or option numbers and values vesting information investment history and transaction and tax information.
• Inferences that we draw from your personal information to create a profile about your preferences.

As part of our compliance with legal obligations such as AML/KYC we may be required to process special categories of personal data as defined by the GDPR and the DPA as applicable including personal data relating to political opinions as well as criminal convictions and offences.

It is important that we maintain up to date records of key information about you. Please notify us of any significant changes in your personal circumstances as soon as they occur (e.g. change of name address contact information etc.). From time to time we may ask you to complete a new Investor Data form to ensure our records are up to date.

Sources of Investor Data

We collect this Investor Data in various ways including through:

• Your or your employer’s financial intermediary’s and/or designated representative’s correspondence interactions and transactions with us our affiliates delegates or others including by letter email telephone our websites and through information provided in subscription agreements investor questionnaires applications and other agreements or documents completed by you or on your behalf.
• Information from other public sources including public news sources corporate registries government and other public databases and professional social media sites such as LinkedIn and information we receive from consumer reporting agencies our services providers or others we may engage in connection with conducting due diligence know-your-customer anti-money laundering and other checks required to be performed in relation to admitting new investors.

How and on what basis do we use Investor Data?

We use Investor Data for a variety of reasonable and legitimate business purposes including but not limited to the following:

• Where it is necessary to enter into or for the performance of our rights and obligations under a contract with you or to take steps at your request prior to entering into a contract (e.g. to process your subscription agreement and/or the constitutional and operational documents of the Fund provide information you have requested create and administer your account administer your investments maintain registers and communicate with you about your investments).
• Where it is necessary for compliance with legal and regulatory obligations to which we are subject (such as compliance with know-your-customer anti-money laundering and FATCA/CRS requirements) – this may involve collecting specific Investor Data about you where required by law and disclosing such information to applicable regulators government bodies tax and other authorities where required by law.
• Where it is necessary for our our affiliates’ delegates’ and/or other third parties’ legitimate interests (and such interests are not overridden by your interests fundamental rights or freedoms) or (if required by law) with your consent including to operate and facilitate our business and services to you undertake business management planning statistical analysis market research and marketing (including email marketing) activities administer and maintain our core records protect our rights and interests ensure the security of our assets systems and networks prevent detect and investigate fraud unlawful or criminal activities in relation to our services and enforce our terms and conditions.
• Where it is necessary for the establishment exercise or defense of legal claims.

Where we process Investor Data about you on the basis of your consent you have the right to withdraw that consent at any time. If you decline to provide or withdraw your consent to our use of Investor Data about you and under applicable law we are relying on such consent as the legal basis for its processing there are circumstances in which we will not be able to provide you with certain services or take particular action on your behalf.

Where we process Investor Data about you on the basis of our or a third party’s legitimate interests we may do so for our or our affiliates’ delegates’ and/or other third parties’ everyday business purposes— such as to process your transactions maintain your account(s)—or respond to court orders and legal investigations. To the extent permitted by law (including with your consent where required) we may also process Investor Data about you to offer or market products or services to you (including by email) or permit authorized third parties to offer or market their services to you.

Where relevant we may provide you with additional details about how we process your personal information at the time of collection. Should we wish to use Investor Data for other specific purposes (including if applicable any purpose that requires your consent) we will contact you. We will not use Investor Data for any purposes inconsistent with this Privacy Notice without your permission.

With whom do we share Investor Data?

We may share the above categories of Investor Data to carry out and implement any and all purposes described above and for the objects of the Fund including:

• With our affiliates and delegates that may act as data processors processors or service providers (the “Delegates”) such as the Fund’s administrators accountants auditors bankers prime brokers insurers lawyers AML service providers tax information exchange service providers and other back-office service providers which may use Investor Data for example to provide their services to us or to discharge the legal regulatory or self-regulatory requirements that apply directly to us or in respect of which we rely upon the Delegates provided that such use of Investor Data by the Delegates will always be compatible with at least one of the aforementioned purposes for which we process Investor Data. The Delegates will not retain use sell or otherwise disclose Investor Data for any purpose other than the specific business purpose for which we have provided the information to the Delegate.
• With regulatory self-regulatory administrative law enforcement agencies or other oversight bodies in certain circumstances where we and/or our Delegates are obliged to share Investor Data and other information with respect to your interest in the Fund with the relevant regulatory authorities such as the Cayman Islands Monetary Authority the Tax Information Authority or the U.S. Securities and Exchange Commission. They in turn may exchange this information with foreign authorities including tax authorities.
• As authorized for example by subscription agreements or organizational documents of the Fund and as authorized by you or your designated representatives.
• As necessary for us to enter into or to perform a contract with you (e.g. to process your subscription agreement provide information you have requested create and administer your account administer your investments maintain registers and communicate with you about your investments).
• As necessary for our or a third party’s legitimate business interests.
• In connection with certain business transactions with a third party that succeeds the Investment Manager or General Partner in carrying on all or a part of our business or if the Fund is otherwise sold or transferred to a third party.
• As required by law regulation or self-regulatory requirement including to comply with a subpoena or similar legal process including when we believe in good faith that disclosure is legally required.
• As necessary for the establishment exercise or defense of legal claims or where otherwise necessary to protect the Investment Manager the General Partner or the Fund’s rights and property.

We do not sell any Investor Data and have not sold any Investor Data in the past 12 months.

International Data Transfers

Because the Internet and our operations are global your personal information may be transferred to processed in and held in countries (including the United States) other than the one in which you reside or in which the Fund is established. The European Union United Kingdom and Cayman Islands do not consider the United States and many other countries to provide essentially equivalent privacy protections. Such transfers are a necessary part of the services that we provide.

We will ensure application of the same standards of privacy protection as set out in this Privacy Notice regardless of the international transfer or processing of personal data. To the extent required by and in accordance with applicable data protection laws we rely on appropriate or suitable safeguards in respect of international transfers of personal information including:

• Using standard contractual clauses approved by relevant authorities as ensuring adequate safeguards (“Model Clauses”);
• Obtaining your consent to transfer Investor Data about you after first informing you about the possible risks of such a transfer;
• When the transfer is necessary for the performance of a contract between you and us or if the transfer is necessary for the performance of a contract between us and a third party and the contract was entered into in your interest;
• When the transfer is necessary to establish exercise or defend legal claims.

Investors can request further details in relation to international transfers including a copy of the Model Clauses by using the contact details provided below.

How do we protect Investor Data?

Any processing of Investor Data by us or our duly authorized Delegates shall be in accordance with all applicable legal requirements including those of the DPA and GDPR.

We and our duly authorized Delegates shall apply appropriate technical physical and administrative information security measures designed to protect against unauthorized or unlawful processing of Investor Data and against accidental loss or destruction of or damage to Investor Data.

How long do we retain Investor Data?

We retain Investor Data only for as long as is necessary for the purposes set out in this Privacy Notice subject to your rights under certain circumstances to have your data erased.

When deciding how long to retain Investor Data we take into account our legal and regulatory obligations the amount nature and sensitivity of the Investor Data the potential risk of harm from unauthorized use or disclosure of Investor Data the purposes for which we process Investor Data and whether we can achieve those purposes through other means. We may also retain Investor Data to investigate or defend against potential legal claims in accordance with the limitation periods of countries where legal action may be brought.

Contact and Complaints

We take very seriously any complaints we receive about our use of Investor Data. If you have questions comments requests or complaints regarding this Privacy Notice or wish to discuss your data protection rights with us please contact Aaron W. Fine at 617-544-8828.

Data Subject Rights

Individuals in Andorra Argentina Australia Canada Cayman Islands the European Economic Area Faroe Islands Guernsey Hong Kong Israel Isle of Man Japan Jersey Mexico New Zealand Singapore South Korea Switzerland the United Kingdom Uruguay and certain other jurisdictions and investors in our Cayman Islands funds may have certain data subject rights. These rights vary but they may include subject to certain limitations the right for individuals to:

• Request access to and rectification or erasure of their personal data;
• Restrict or object to the processing of their personal data;
• Obtain a copy of their personal data in a portable format; and
• The right to limit our use of sensitive personal information.

Individuals may also have the right to lodge a complaint about the processing of personal data with a data protection or supervisory authority.

State Privacy Rights

State consumer privacy laws may provide their residents with additional rights regarding our use of their personal information. Residents of Colorado Connecticut Virginia and Utah may have the right to:

• Confirm whether we process their personal information.
• Access and delete certain personal information.
• Correct inaccuracies in their personal information taking into account the nature of the information and the purposes of the processing of the information.
• Data portability.
• Opt-out of personal data processing for targeted advertising and sales.
• Opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects.

Nevada law permits our users who are Nevada consumers to request that their personal data (as defined under applicable Nevada law) not be sold even if their personal data is not currently being sold. Requests may be sent using the contact information below.

Please be aware that we collect relatively limited amounts of consumer personal information subject to the CCPA and other state laws because the personal information we obtain is largely exempted from CCPA and other state laws as personal financial data subject to the federal Gramm-Leach-Bliley Act (GLBA) or Fair Credit Reporting Act (FCRA).

CCPA Notice and Rights

In the last 12 months we have collected and disclosed the categories of personal information described above for the business purposes described under “How and on what basis do we use Investor Data?” and will retain the information as described under “How long do we retain Investor Data?.” We only disclose and use sensitive personal information for these purposes which are permitted under the CCPA without requiring us to provide you with a notice regarding the “right to limit” as defined therein. Nevertheless if you have any further questions about our uses or disclosures of sensitive personal information you should contact us using the contact information below.

The CCPA provides California residents (consumers) with specific rights regarding their personal information including the following:

If you wish to exercise any of these rights please contact us at the contact information below. In order to respond to a request you will be required to supply a valid means of identification as a security precaution. Depending on the sensitivity of the information in question we may require additional proof of identification. We will not disclose or delete any information until the individual’s identity is verified. If an agent makes a request on your behalf they will be required to verify the request by submitting your written authorization and we may still ask that you verify your identity with us before we can proceed with the request. We will not honor any requests from agents until authorization is verified. We will maintain records of consumer requests made under CCPA and how we responded to those requests in accordance with the CCPA.

California Shine the Light Disclosure

California’s “Shine the Light” law permits California residents to annually request and obtain information free of charge about what personal information is disclosed to third parties for direct marketing purposes in the preceding calendar year. We do not distribute your personal information to outside parties without your consent for their direct marketing.

How to exercise your Data Subject Rights

To exercise any of these rights please contact us by calling 1-617-544-8800 or emailing privacy@psgequity.com.

Depending on your jurisdiction you may also be entitled to direct any complaints in relation to our processing of Investor Data to your national or local data protection or supervisory authority.

Individuals who submit requests related to personal information about themselves will be required to verify their identity by answering certain questions and supplying a valid means of identification as a security precaution. We will not process any such requests until such individual’s identity is verified.

You may designate an authorized agent to submit a request on your behalf by providing that agent with your written permission. If an agent makes a request on your behalf we may still ask that you verify your identity directly with us before we can honor the request.

Agents who make requests on behalf of individuals will be required to verify the request by submitting written authorization from the individual. We will not honor any requests from agents until authorization is verified.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive repetitive or manifestly unfounded. If we determine that the request warrants a fee we will tell you why we made that decision and provide you with a cost estimate before completing your request. We will process your request within the time provided by applicable law.

Non-Discrimination

We will not discriminate against you based on the exercise of your privacy rights.

Children’s Privacy

We are committed to protecting the privacy needs of children and we encourage parents and guardians to take an active role in their children’s online activities and interests. Our services are not intended for and may not be used by children under the age of 13. We do not knowingly collect information from children under the age of 13 and we do not target children under the age of 13.

Linked Sites

Any links to third-party websites contained in this Privacy Notice are provided strictly for your convenience. We make no warranty or representation regarding and do not accept any responsibility for such websites or the information appearing thereon or any of the products or services described thereon. You acknowledge and agree that use of third-party websites is strictly at your own risk.