Third Point LLC Global Privacy Notice

About this privacy notice

Third Point LLC and its affiliates (collectively, the “Investment Manager”), are data controllers, with respect to your personal data for the purposes of applicable data protection laws, such as the European Union’s General Data Protection Regulation ("GDPR"), and the GDPR as incorporated into and retained by, the laws of the United Kingdom (the "UK GDPR"), the Data Protection Act (2021 Revision) of the Cayman Islands, the Data Protection Act, 2021 of the British Virgin Islands, the Data Protection Bailiwick of Guernsey, 2017 (the “DPLs”), the Gramm-Leach-Bliley Act (“GLBA”), and the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020, and any regulations promulgated thereunder (the “CCPA”, the DPLs, the GLBA, the UK GDPR, together with the GDPR, collectively, the "Data Protection Laws"). The Investment Manager is responsible for ensuring that it uses your personal data in compliance with such Data Protection Laws.

The Investment Manager will generally process personal data provided to it in connection with a potential investment or consummated investment in a fund under its management and in furtherance of its legal obligations under applicable law. International Fund Services (N.A.), L.L.C. (“IFS”), the administrator of the funds managed by the Investment Manager, will process personal data provided to it in connection with an investment in the applicable fund. This privacy notice should be read in conjunction with the Data Privacy Notice of IFS, which can be accessed at https://www.statestreet.com/disclosures-and-disclaimers/privacy.

This privacy notice applies to you to the extent your personal data is subject to any of the Data Protection Laws and (i) you have been or are contacted by the Investment Manager in connection with an investment, (ii) in certain circumstances, your personal data has been provided to the Investment Manager by another person (such as where you are a director, partner, trustee, employee, agent or direct or indirect owner of an investor) in connection with an investment or (iii) in certain circumstances, the Investment Manager otherwise has or uses your personal data. This privacy notice sets out the bases on which personal data about you will be processed by the Investment Manager.

If you are an individual, please take the time to read and understand this privacy notice.

If you are an entity or other body, you must provide a copy of this privacy notice to all individuals whose personal data you have provided (or will provide) to the Investment Manager. These will include, for example, individuals whose information has been provided in relation to know-your-client procedures or the automatic exchange of information for tax purposes (e.g., under FATCA or CRS), individuals who are authorised to give instructions regarding your investment, and individuals who have communicated with the Investment Manager.

Contacting the Investment Manager

If you would like further information on the collection, use, disclosure, transfer or other processing of your personal data or the exercise of any of the rights listed below, please contact Investor Relations at +1 (212) 715-6707, at ir@thirdpoint.com, or via our toll-free number +1 (844) 373-7646.

Personal data that the Investment Manager processes

The Investment Manager processes the following types of personal data about you:

(a) Information provided to the Investment Manager by you or (if different) the investor: This includes your name and address, e-mail address, contact details, date of birth, gender, nationality, photograph, signature, social security number, occupational history, job title, income, assets, account balance, other financial information, bank details, investment and transaction history, financial situation, tax residency and tax identification information. Such information might be provided in a subscription agreement or in other documents (in connection with your subscription, continued investment or at other times), face-to-face, by telephone, by email or otherwise.

(b) Information that the Investment Manager collects or generates: This includes information relating to your (or, if different, an investor’s) emails (and related data), call recordings and website usage data.

(c) Information that the Investment Manager obtains from other sources: This includes information obtained for the purpose of the Investment Manager’s know-your-client procedures (which include anti-money laundering procedures, counter-terrorist financing procedures, politically-exposed-person checks, sanctions checks, among other things) or tax purposes (e.g., under FATCA or CRS), information from public websites and other public sources and information received from your (or, if different, the investor’s) advisers or from intermediaries.

Uses of your personal data

Your personal data may be stored and processed by the Investment Manager for the following purposes:

(a) Assessing and processing potential and actual investments and other share or interest dealings, including eligibility, performing know-your-client procedures, automatically exchanging information for tax purposes (e.g., under FATCA or CRS), issuing and redeeming shares or interests, receiving payments from and making payments to the investor or intermediaries, calculating net asset value, and overseeing these processes.

(b) General business administration, including communicating with and servicing of investors, communicating with service providers and counterparties, accountancy and audit services, risk monitoring, the administration of IT systems and monitoring and improving products.

(c) Compliance with legal and regulatory obligations and industry standards, including know-your-client procedures, the automatic exchange of tax information and legal judgments.

(d) With respect to the business activities relating to the Investment Manager, such as investor relations, discussions with the service providers and counterparties of the funds managed by the Investment Manager, decision-making, business strategy and development, and marketing in relation to the funds managed by the Investment Manager.

Lawful grounds for processing

Subject to the Data Protection Laws, the Investment Manager processes your personal data in these ways on the following lawful grounds:

(a) If you are the potential investor, you may enter into an investment contract with the Investment Manager and/or with one or more of the funds managed by the Investment Manager and some processing will be necessary for the performance of such contracts, or will be done at your request prior to entering into such contracts.

(b) Processing may be necessary to discharge a relevant legal or regulatory obligation in the EEA, the UK, the British Virgin Islands, Guernsey or the Cayman Islands, as applicable.

(c) The processing will, in all cases, be necessary for the legitimate business interests of the Investment Manager, the fund(s) managed by the Investment Manager, the applicable fund’s administrator, or other service providers, such as:

(i) carrying out the ordinary or reasonable business activities of the Investment Manager, the applicable fund’s administrator or other service providers, or other activities previously disclosed to the applicable fund’s investors or referred to in this privacy notice;

(ii) ensuring compliance with all legal and regulatory obligations and industry standards, and preventing fraud;

(iii) establishing, exercising or defending legal rights or for other purposes relating to legal proceedings; and

(iv) ensuring the security of information systems.

(d) The Investment Manager will only process your personal data in pursuance of its legitimate interests where the Investment Manager has considered that the processing is necessary and, on balance, the Investment Manager’s legitimate interests are not overridden by your legitimate interests, rights or freedoms.

(e) Subject to the Data Protection Laws, in respect of any processing of sensitive personal data falling within special categories, such as any personal data relating to the political opinions of a politically exposed person, the processing will be necessary for reasons of substantial public interest.

Disclosure of your personal data to third parties

The Investment Manager may from time to time, for the purposes described above, disclose your personal data to the following categories of third parties: (a) the applicable fund’s administrator and its affiliates, (b) professional advisors such as law firms and accountancy firms, (c) other service providers of the Investment Manager, including technology service providers, (d) counterparties, (e) courts and regulatory, tax and governmental authorities, and (f) other third parties with your consent. Some of these persons will process your personal data in accordance with the Investment Manager’s instructions as data processors or service providers under applicable Data Protection Laws and others will themselves be responsible for their use of your personal data as data controllers or businesses under such laws.

We do not disclose nonpublic personal information about our investors or former investors to any nonaffiliated parties except as otherwise stated in this privacy notice. The disclosures referenced above are for Third Point related business purposes, such as to process your transactions, maintain your accounts, provide you with account statements, and to respond to court orders and legal investigations.

How we protect your personal data

Third Point employs a layered approach to cybersecurity using multiple overlapping policies, procedures, and technologies to insure the confidentiality, integrity, and availability of our most sensitive assets. We employ many administrative, technical, and physical controls for defense-in-depth. For additional information please reference the overview of cybersecurity policies and controls (Appendix E) in the Third Point DDQ.

Necessity of personal data for an investment in a fund managed by the Investment Manager

The provision of certain personal data is necessary for compliance by the Investment Manager and its service providers with certain legal and regulatory obligations. Accordingly, if certain personal data is not provided when requested, a subscription for shares or interests might not be accepted or shares or interests might be compulsorily redeemed.

Retention of personal data

How long the Investment Manager holds your personal data for will vary. The retention period will be determined by various criteria, including the purposes for which the Investment Manager is using it (as it will need to be kept for as long as is necessary for any of those purposes) and legal obligations (as laws or regulations may set a minimum period for which the Investment Manager has to keep your personal data).

Former investors

We maintain personal data of former investors and apply the same policies and procedures that apply to our current investors.

Individuals Located in (as Residents) the European Union, European Economic Area, United Kingdom, Cayman Islands, the British Virgin Islands or the Bailiwick of Guernsey

This section applies to the extent you have rights under GDPR, UK GDPR, or the DPLs.

Transfers of your personal data outside the European Economic Area

Your personal data may be transferred to and stored by persons outside the European Economic Area (the “EEA”) or the UK, and in particular may be transferred to and stored by affiliates or service providers of the Investment Manager or the applicable fund’s administrator outside the EEA or the UK.

Where personal data is transferred outside the EEA or the UK by the Investment Manager, the Investment Manager will take appropriate safeguards with respect to such transfer. For example, the country to which the personal data is transferred may be approved by the European Commission or the UK Government, the recipient may have agreed to model contractual clauses approved by the European Commission or the UK Government that oblige them to protect the personal data.

You can obtain more details of the protection given to your personal data when it is transferred outside the EEA or the UK by contacting the Investment Manager using the details set out under “Contacting the Investment Manager” above.

Transfers of your personal data outside the Cayman Islands

Your personal data may also be transferred to and stored by persons outside of the Cayman Islands. Where this takes place, we will ensure that the transfer is subject to appropriate safeguards or is otherwise permitted by the DPL or other applicable law.

You can obtain more details of the protection given to your personal data when it is transferred outside the Cayman Islands by contacting the Investment Manager using the details set out under "Contacting the Investment Manager" above.

Transfers of your personal data outside the British Virgin Islands

Your personal data may also be transferred to and stored by persons outside of the British Virgin Islands. Where this takes place, we will ensure that the transfer is subject to appropriate safeguards or is otherwise permitted by the DPL or other applicable law.

You can obtain more details of the protection given to your personal data when it is transferred outside the British Virgin Islands by contacting the Investment Manager using the details set out under "Contacting the Investment Manager" above.

Transfers of your personal data outside the Bailiwick of Guernsey

Your personal data may also be transferred to and stored by persons outside of the Bailiwick of Guernsey. Where this takes place, we will ensure that the transfer is subject to appropriate safeguards or is otherwise permitted by the DPL or other applicable law.

You can obtain more details of the protection given to your personal data when it is transferred outside the Bailiwick of Guernsey by contacting the Investment Manager using the details set out under "Contacting the Investment Manager" above.

Your rights

Depending on where you are located and subject to the Data Protection Laws, you may have a number of legal rights in relation to the personal data that the Investment Manager holds about you. These rights include the following:

(a) The right to obtain information regarding the processing of your personal data and access to the personal data that the Investment Manager holds about you.

(b) In some circumstances, the right to receive some personal data in a structured, commonly used and machine-readable format and the right to request that the Investment Manager transmits that data to a third party where this is technically feasible. Please note that this right only applies to personal data which you have provided to the Investment Manager.

(d) The right to request that the Investment Manager erases your personal data in certain circumstances. Please note that there may be circumstances where you ask the Investment Manager to erase your personal data but the Investment Manager is legally entitled to retain it.

(e) The right to object to, and the right to request that the Investment Manager restricts, its processing of your personal data in certain circumstances. Again, there may be circumstances where you object to, or ask the Investment Manager to restrict, its processing of your personal data but the Investment Manager is legally entitled to continue processing your personal data or to refuse that request.

(f) The right to stop or not begin direct marketing.

(g) The right to be informed of a personal data breach (unless the breach is unlikely to be prejudicial to you).

(h) The right to lodge a complaint with the data protection regulator (details of which are provided below) if you think that any of your rights have been infringed by the Investment Manager.

(i) The right to be free from unlawful discrimination for exercising your data protection rights.

You can exercise your rights by contacting the Investment Manager using the details set out under “Contacting the Investment Manager” above. You can find out more information about your rights by contacting an EU data regulator (https://edpb.europa.eu/about-edpb/about-edpb/members_en), or about the rights you may have under the UK GDPR by contacting the UK’s Information Commissioner’s Office, or by searching their website at ico.org.uk. For more information about the rights you may have under the Cayman Islands DPL, please contact the Cayman Islands Data Protection Ombudsman whose details are available at www.ombudsman.ky. The office of the British Virgin Islands Information Commissioner has not yet been established, but this privacy notice will be updated on its establishment. For more information about the rights you may have under the Bailiwick of Guernsey DPL, please contact the Office of the Data Protection Authority whose details are available at https://www.odpa.gg.

Automated decision-making

The Investment Manager will not take decisions producing legal effects concerning you, or otherwise significantly affecting you, based solely on automated processing of your personal data, unless the Investment Manager has considered the proposed processing in a particular case and concluded in writing that it meets the applicable requirements under the DPLs.

Individuals Located in (as Residents) California

If you are a California resident, this section provides you with information concerning your rights under the CCPA. Please note that these disclosures and the rights described below do not apply to information collected, processed, used, and used by the Investment Manager under the GLBA (and its implementing regulations) or the California Financial Privacy Act.

Categories of Personal Information Collected and Disclosed

The following section details the categories of personal information about California residents we may have (i) collected and/or (ii) disclosed for our business and commercial purposes in the past 12 months. Not all categories have been collected or disclosed for every individual.

Category A. Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, IP address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.

• We Collected: Yes — Name, alias, postal address, unique personal identifier, online identifier, email address, account name, social security number, driver’s license number, passport number.

• We Disclosed: Yes, to affiliates, service providers, and other vendors for provision of services.

Category B. Personal information as defined in the California customer records law, meaning information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

• We Collected: Yes – Name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, education, employment, employment history, financial information, medical information.

• We Disclosed: Yes, to affiliates, service providers, and other vendors for provision of services.

Category C. Characteristics of protected classifications under California or federal law including Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression), pregnancy or childbirth and related medical conditions, sexual orientation, veteran or military status, genetic information (including familial genetic information).

• We Collected: Yes – collected characteristics of protected classifications under California or federal law, such as citizenship, sex, and national origin.

• We Disclosed: Yes, to affiliates, service providers, and other vendors for provision of services.

Category D. Commercial Information, including personal property records, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

• We Collected: Yes – products or services purchased, obtained, or considered.

• We Disclosed: Yes, to affiliates and service providers.

Category E. Biometric information, including imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information.

• We Collected: No

• We Disclosed: No

Category F. Internet or other electronic network activity information, such as browsing history, search history, and information regarding interactions with our Websites, applications, or advertisements.

• We Collected: Yes

• We Disclosed: Yes, to affiliates and service providers.

Category G. Geolocation Data, such as device location and IP location

• We Collected: Yes, in regards to your interactions with Third Point owned websites.

• We Disclosed: Yes, to affiliates and service providers.

Category H. Audio, electronic, visual, thermal, olfactory, or similar information.

• We Collected: Yes – audio, visual, electronic.

• We Disclosed: Yes, to affiliates, service providers, and other vendors for provision of services.

Category I. Professional or employment-related information, such as employer name and role/title.

• We Collected: Yes

• We Disclosed: Yes, to affiliates and service providers.

Category J. Education information subject to the federal Family Education Rights and Privacy Act, such as student records.

• We Collected: No

• We Disclosed: No

Category K. Inferences drawn from any of the information listed above to create a profile or summary about, for example, an individual’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

• We Collected: No

• We Disclosed: No

We also collect, or may collect, sensitive personal information such as the following personal information that consists of:

• Government Identifiers, such as Social Security Number, driver’s license, state ID, or passport number;

• Racial or ethnic origin, religious or philosophical beliefs; and

• Contents of postal mail, email, and text messages unless Third Point is the intended recipient of the communication.

We do not “sell” or “share” (as such terms are defined by the CCPA) personal information or sensitive personal information about California residents, including those residents we know to be under sixteen years old.

We only use and disclose sensitive personal information as reasonably necessary (i) to perform our services requested by you; (ii) to prevent, detect, and investigate security incidents; (iii) to detect, prevent, and respond to malicious, fraudulent, deceptive, or illegal conduct; (iv) to verify or maintain the quality and safety of our services, (v) for compliance with our legal obligations; (vi) to our service providers who perform services on our behalf; and (vii) for purposes other than inferring characteristics about you. We do not use or disclose your sensitive personal information other than as authorized by section 7027 of the CCPA regulations (Cal. Code. Regs., tit. 11 § 7027 (2022)).

Sources and purposes for collecting personal information

The categories of sources from which we collect personal information and the business and commercial purposes for which we collect and disclose the personal information are set forth above in the sections titled “Personal data that the Investment Manager processes” and “Uses of your personal data,” respectively.

Individual Rights and Requests

If you are a California resident, you may request that we:

1. Right to Know & Right to Access. Disclose to you the following information covering the 12 months preceding your request:

• The categories of personal information we collected about you;

• The categories of sources from which we collected personal information about you;

• The specific pieces of personal information we collected about you;

• The business or commercial purpose for collecting personal information about you; and

• The categories of personal information about you that we disclosed, and the categories of third parties to whom we disclosed such personal information. You also have the right to receive your personal information in a structured and commonly used format so that it can be transferred to another entity.

2. Right to Delete. Delete personal information we collected from you (under certain circumstances)

3. Right to Correct. Rectify your Personal Data if it is inaccurate, outdated, or incomplete (in certain circumstances).

4. Right to Opt-Out. Opt you out of the sale or sharing of your personal information to Third Parties. As noted above, however, we do not currently “sell” or “share” personal information about California residents, including those we know to be under sixteen years old.

5. Right to Limit Sharing or Disclosure of Sensitive Personal Information. Limit the use and disclosure of your sensitive personal information that go beyond uses and disclosures specifically authorized by the CCPA. However, as stated above, we do not use or disclose sensitive personal information about California residents beyond those authorized purposes.

6. Right to Non-Discrimination. You have the right to be free from unlawful discrimination for exercising your rights under the CCPA.

We will verify and respond to your request consistent with applicable law, taking into account the type and sensitivity of the personal information subject to the request. For your protection, we may need to request additional information from you (such as your name, email address, mailing address, and relationship with us) in order to verify your identity and protect against fraudulent requests. If you make a deletion request, we may ask you to verify your request before we delete your personal information. We reserve the right to deny your request in accordance with applicable law if we cannot verify you or your authority to make the request.

You may designate someone to act on your behalf as your authorized agent to exercise some of your privacy rights. Your authorized agent may need to provide documentation supporting the agent’s authority to make a request on your behalf. We may also require that you directly verify your identity and the authority of the authorized agent.

For questions and concerns regarding our privacy policies and information practices, please feel free to contact us in accordance with the “Contacting Us” section above.

February 2024