This privacy notice (“Privacy Notice”) sets forth the privacy practices of Anchorage Capital Advisors, L.P. and its relying advisors, (collectively, the “Company”, “us”, “our” or “we”) with respect to personal data that we receive including personal data provided by or relating to current, former and prospective: (i) institutional or individual investors (collectively, “Investors”) in funds or other investment vehicles (collectively referred to as “Funds”) for which we serve as investment manager, collateral manager or general partner, or in a similar capacity; (ii) employees; and (iii) service providers.

With respect to Investors, the use of the term “Company” or “we” in this Privacy Notice includes the collection and processing of personal data by Funds and their associated fund administrator. Where a Fund is established in the Cayman Islands, the Fund will be a “data controller” for the purposes of the Cayman Islands Data Protection Law, as amended from time to time (the “DPL”). Where a Fund is established in the European Economic Area (“EEA”) or the United Kingdom (“UK”), and/or where data subjects are located in the EEA or the UK, the Fund (together with the Company, as applicable) will be a “data controller” for the purposes of: (i) Regulation (EU) 2016/279 (General Data Protection Regulation) (“EU GDPR”); and (ii) the UK Data Protection Act 2018 and the EU GDPR as it forms part of the laws of England and Wales by virtue of section 3 of the European Union (Withdrawal) Act 2018 (“UK GDPR” along with the EU GDPR, collectively referred to herein as “GDPR”).

If you are a California resident reviewing this Privacy Notice, the “California Privacy Notice” below contains certain additional information about how we collect and use the personal information of California residents and the associated rights that such residents may have with respect to their information.

If you are a natural person (“Natural Person”), this Privacy Notice will affect you directly. To the extent that you are an institutional Investor, we ask that you provide a copy of this Privacy Notice to those individuals that are beneficial owners of, or otherwise related to you and whose personal data you may disclose to us.

Please review this Privacy Notice periodically, as we may make revisions at our discretion, and post such changes on our website and investor portal. If we make material changes, we will notify you through a notice on our website.

Personal Data That May Be Collected
We may collect personal data (“Personal Data”), including non-public information, from public and non-public sources, including:

• Contact and Identification Information: such as name, residential address, date and place of birth, social security number, email address, telephone number(s), signature, and nationality;
• Financial Information: such as tax identification information and bank account details;
• Other Information: Information from third-party sources (which may include financial institutions, service providers, credit reporting agencies and background checking services to the extent permitted by applicable laws). We may, for example, obtain Personal Data when an Investor makes an investment in a Fund, provides information in subscription documents and related forms, gives contact information, or provides government-issued ID cards, together with any other information required by applicable laws.

Categories of Personal Data, Processing Purposes and Associated Legal Basis
We may use your Personal Data in the following ways:

Disclosure of Personal Data to Third Parties
In circumstances that we deem appropriate, we may disclose Personal Data to third parties:

• As required or permitted by law, including in response to subpoenas, court orders, regulatory or government requests or similar legal process, or to establish, protect, or exercise legal rights and interests or defend against legal claims;
• If we believe it is necessary in order to investigate, prevent, or take action regarding inappropriate or illegal activities, fraud, or situations involving potential threats to the safety of any person or property, to fraud prevention agencies and law enforcement agencies;
• To affiliates, subsidiaries, joint ventures, or other companies under common control with us (in which case we will require such entities to comply with this Privacy Notice);
• To third party service providers in connection with the oversight, safekeeping, administration, distribution or operation of the Funds and our business (or, if applicable, a Fund, including Fund administrators, transfer agents, custodians, depositories); provided that we require that our service providers process Personal Data consistent with this Privacy Notice;
• To brokers and counterparties in connection with transactions (e.g., in connection with “Know Your Customer” purposes);
• To credit reference agencies and other third parties conducting background checks in the context of employment, counterparty, investment or other due diligence;
• As directed by any individual with respect to his or her Personal Data;
• Any third party that acquires, or is interested in acquiring, all or part of our assets, or shares, or that succeeds us in carrying on all or part of our business, whether by merger, acquisition, reorganization or otherwise; and
• Information regarding the tax treatment and structure of investments may also be disclosed consistent with applicable legal requirements.

For the avoidance of doubt, Personal Data including mobile opt-in information is NOT shared with any third party for marketing or promotional purposes.

Data Security
We maintain appropriate physical, electronic, technical and organisational measures to safeguard and keep confidential the Personal Data to which we process, including by ensuring, to the extent required by applicable law, the secure and permanent destruction of Personal Data that is no longer being retained for the purposes for which it was processed. We intend to use commercially reasonable steps to protect Personal Data against loss or theft, as well as from unauthorized access, disclosure, copying, use or modification. However, such safeguards may not always be adequate to prevent all breaches of security. In the event of unauthorized access to or use of Personal Data, the affected person(s) may receive notice of the breach to the extent required by applicable law.

Rights
Individuals may exercise rights under applicable law, subject to certain limitations and restrictions, including: (i) the right to access Personal Data held by us; (ii) to rectify or delete Personal Data which is factually incorrect, incomplete or irrelevant for the purpose for which it is processed; and (iii) to raise any questions or concerns regarding the use of their Personal Data, including making a request not to receive marketing communications, by contacting us.

Under the GDPR and DPL, individuals may have a right: (i) to request access to and rectification or erasure of their Personal Data; (ii) to obtain restriction of processing or to object to processing of their Personal Data; (iii) to data portability; and (iv) to be informed of a Personal Data breach if likely to be prejudicial to their rights and freedoms. Individuals in the EEA and the UK may have the right to lodge a complaint about the processing of their Personal Data with their local data protection authority; and where a Fund is a “data controller” for DPL purposes, complaints may be filed with the Cayman Islands Ombudsman.

In certain circumstances, California residents may have the right to, among other things, access or delete their Personal Data. For a description of these rights, please see the section below titled “California Disclosures and Rights.”

We will respond to your request in writing, or orally if requested, as soon as practicable and within the time frame prescribed under applicable data protection laws. We may request proof of identification to verify your request. For more details in relation to your rights, including how to exercise them, please contact us using our “Company Contact” information below.

International Transfers of Personal Data
In order to use and disclose Personal Data subject to the Cayman Islands, EEA, or UK data protection laws (as applicable) for the purposes described above, we may disclose Personal Data to recipients located in countries outside of the Cayman Islands, the EEA, and UK, including in the U.S., which may not have data protection laws that the Cayman Islands, EEA, and UK deem to be ‘adequate’. Any such transfer shall be in accordance with the requirements of applicable data protection laws.

Retention of Personal Data
We will retain Personal Data in accordance with our data retention policies. We will generally retain Personal Data 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 for the purposes of other legitimate interests. At a minimum, Personal Data is generally expected to be retained for the entire duration of any applicable business relationship, and for a minimum period of five (5) years after the termination of any such relationship.

Consequences of Not Providing Required Personal Data
Where we require your Personal Data to comply with anti-money laundering or other legal requirements, failure to provide this information could prevent a Fund from accepting you as an Investor and/or we may be unable to process, or release your investment in a Fund. This may result in a Fund terminating its relationship with you. When asking for Personal Data in connection with your investment or potential investment in the Funds, we will inform you whether it is a statutory or contractual requirement to give us such information and the consequences of not providing the information.

Company Contact
For questions regarding this Privacy Notice, how to exercise your data subject rights, or any other data protection questions, communications can be directed to the Chief Compliance Officer, Anchorage Capital Advisors, L.P., 610 Broadway, 6th Floor, New York, NY 10012, Tel: (212) 432-4600 or (844) 462-4600, or via email at compliance@anchoragecapital.com.

This California Privacy Notice applies to California residents, in accordance with the requirements of the California Consumer Privacy Act of 2018 (the “CCPA”) and other California privacy laws. The disclosures made in this section regarding the Personal Information we collect and maintain, and the rights afforded by the CCPA with respect to such information do not apply to Personal Information collected, processed, sold, or disclosed pursuant to the federal Gramm-Leach-Bliley Act (Public Law 106-102) and its implementing regulations (the “GLBA”). When engaging with us as an Investor, your Personal Information will largely or entirely, be covered by the GLBA.

These California Disclosures and Rights do not apply to California employees, independent contractors or job applicants.

Our Practices with Respect to Personal Information
For the purposes of this section of the Privacy Notice, “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“Consumer”). It does not include de-identified, aggregate, or public information lawfully available from governmental records, nor does it include information that we have a reasonable basis to believe is lawfully made available to the general public by a Consumer or information made available by a natural person or entity to whom a Consumer has disclosed the information if the Consumer has not restricted the information to a specific audience.

Notice at Collection: Personal Information We Collect

• Identifiers: email address, address, phone number, facsimile number, IP address, account log in information;
• Commercial and financial information: records of personal property, products or services purchased, obtained, or considered, information on investments, assets, net worth, tax status, tax identification number, holdings, transaction history, bank account details, wire transfer instructions;
• Internet or other electronic activity information: information regarding an individual’s interaction with a website, emails sent and received;
• Professional or employment-related information: name of employer, job title.

Notice at Collection: Purposes for Collection of Personal Information

• Managing and administering Fund investments, including assessing and processing subscription agreements, facilitating the transfer of funds and administering and facilitating any other transactions, and communicating about investments and related activities on an ongoing basis;
• Managing and maintaining our relationships with you and for ongoing client services;
• To enforce or defend our rights, ourselves or through third parties to whom we delegate such responsibilities;
• Investigating and resolving complaints, regulatory matters, investigations and litigation;
• Monitoring electronic communications for investigation and fraud prevention purposes, crime detection, prevention and investigation;
• To share information with police, law enforcement, tax authorities or other government and fraud prevention agencies where we have a legal obligation, including screening transactions, reporting suspicious activity, and complying with court orders;
• To comply with any of our applicable legal, tax or regulatory obligations, which derive from anti-money laundering and counter-terrorism legislation;
• To report tax related information to tax authorities;
• To monitor, maintain and improve the processes, information and data, technology and communications solutions and services used by the Funds;
• Performing general, financial and regulatory accounting and reporting;
• To monitor or record telephone calls and electronic communications for purposes of compliance with applicable law; and
• To contact you about products and services offered by us which we believe may interest you or your employer or the entity you represent, unless you advise us that you do not wish to receive marketing communications from us.

Notice at Collection: No Sale or Sharing of Personal Information
We do not sell Personal Information or share it for purposes of cross-context behavioral advertising.

Notice at Collection: Retention Periods
We will retain Personal Information 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 for the purposes of other legitimate interests. At a minimum, we retain Personal Information for the entire duration of any applicable business relationship, and for a minimum period of five (5) years after the termination of any such relationship.

Sources From Which We Collect Personal Information
We collect Personal Information from you directly; from referral sources; from your interactions with our website and investor portal; and financial institutions, service providers, credit reporting agencies and background checking services.

No Use or Disclosure of Sensitive Personal Information for Inferring Characteristics
We do not use or disclose sensitive personal information to create profiles about or infer characteristics about individuals, or for any purposes other than providing our Services.

Disclosure of Personal Information For Business Purposes in the Past 12 Months
The following chart describes the categories of personal information we disclosed to third parties for a business purpose in the 12 months prior to the date of this Notice:

Business Purposes for Such Disclosures
We disclosed the aforementioned categories of personal information to the categories of third parties identified above for the following purposes: to conduct identity verification services, customer relationship management services, financial services, technical services and support, research and analytics, operate our IT systems and secure our systems, prevent fraud and other illegal activities, and to obtain professional advice about legal and accounting matters.

Additional Information About How We May Disclose Personal Information and Purposes for Disclosures
We may also disclose your personal information as required or permitted by law to comply with a subpoena or similar legal process or government request, or when we believe in good faith that disclosure is legally required or otherwise necessary to protect our rights and property or the rights, property or safety of others, including to law enforcement agencies, and judicial and regulatory authorities. We may also disclose your personal information to third parties to help detect and protect against fraud or data security vulnerabilities. And we may disclose or transfer your personal information to a third party in the event of an actual or potential sale, merger, reorganization of our entity or other restructuring.

Do Not Track Signals
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals.

California Rights
The CCPA grants California residents certain rights with respect to their Personal Information, including, as described below, the right to access or delete their Personal Information.

Right to Request Access to Information We Collect About You
You can submit a request to us for the following Personal Information about you that we have collected:

• The categories of Personal Information we’ve collected about you;
• The categories of sources from which we collected the Personal Information;
• The business or commercial purposes for which we collected the Personal Information;
• The categories of Personal Information that we have disclosed for a business purpose.
• The categories of third parties with which we shared the Personal Information.
• The specific pieces of Personal Information we collected.

Right to Request the Deletion of Personal Information We Have Collected from You
Upon your request, we will delete the Personal Information we have collected from you, with the exception of situations where the CCPA authorizes us to retain specific information. We will act on your request within the timeframes set forth below.

Your Right to Request to Correct Personal Information We Hold About You
You have the right to request that we correct Personal Information we hold that you believe is not accurate. We will take steps to determine the accuracy of the information that is the subject of your request to correct, and in doing so will consider the totality of the circumstances relating to the Personal Information you have identified as being incorrect. We may ask that you provide documentation regarding your request to correct in order to assist us in evaluating the request.

Exercising Your Rights and How We Will Respond
To exercise any of the rights listed above, or to ask questions, communications can be directed to the Chief Compliance Officer, Anchorage Capital Advisors, L.P., 610 Broadway, 6th Floor, New York, NY 10012, Tel: (212) 432-4600 or (844) 462-4600, or via email compliance@anchoragecapital.com.

For requests for access, deletion, or correction, we will acknowledge receipt of your request within 10 business days of receipt. We will provide a substantive response to your request as soon as possible, generally within 45 days of the receipt of your request; however, the process may take longer under certain circumstances. We will inform you if we expect your request will take longer than normal to fulfill.

We would provide the information requested free of charge, but under certain circumstances may charge a reasonable fee to cover the administrative costs of providing the information requested.

Please note that the law may permit us to refuse to act on certain requests. If this circumstance were to arise, we would endeavor to provide you with an explanation of such refusal.

Our Commitment to Honoring Your Rights
If you exercise any of the rights explained in this Privacy Notice, you will continue to be treated fairly, will not be denied or charged different rates for services, or provided a different level or quality of services than others.

Verification of Identity – Access, Deletion or Correction Requests
Should you request access to, deletion of, or correction of your Personal Information, we will ask you for information to verify your identity, which may include your name, email address, phone number, and account information. If any of the verifying information was not previously provided to us, we may ask for alternative information in order to verify your identity.

If we are unable to verify your identity with the degree of certainty required, we will not be able to respond to your request. If this situation were to occur, we would provide you with an explanation of the basis of such denial.

Authorized Agents
You may designate an agent (“Agent”) to submit requests on your behalf. The Agent must be a natural person or a business entity that is registered with the California Secretary of State.

We will require verification of the Agent’s identity and evidence that you gave the Agent signed permission to submit a request on your behalf. Additionally, you may be required to verify your identity by providing us with certain Personal Information as described above or provide us with written confirmation that you have authorized the Agent to act on your behalf.

Please note that this subsection does not apply when an Agent is authorized to act on your behalf pursuant to a valid power of attorney. Any such requests will be processed in accordance with California law pertaining to powers of attorney.

Contact Us
To ask questions, communications can be directed to the Chief Compliance Officer, Anchorage Capital Advisors, L.P., 610 Broadway, 6th Floor, New York, NY 10012, Tel: (212) 432-4600 or (844) 462-4600, or via email compliance@anchoragecapital.com.