CRIMSON Asset Management is an independent investment manager domiciled in Canada, headquartered at Brookfield Place in Toronto, with an office at Brookfield Place in New York (“CRIMSON”, “we”, or “our”). We are committed to protecting our clients’ privacy and the confidentiality of their Personal Information in our possession. Personal Information is information about our clients provided by them or that we collect from other sources such as credit reporting agencies, and includes name, address, date of birth, email, tax identification number, and other personal data of clients or their directors, officers, beneficial owners, employees, agents, or representatives. Additionally, we are committed to ensuring that anyone who accesses our website understands what data may be collected, how we may use it, and how to opt out of sharing any information. Here are the ways we fulfill these commitments.

Accountability

We have strict policies and procedures governing how we deal with your Personal Information. Each and every one of our employees is responsible for respecting and protecting the Personal Information to which the employee has access.

Our Privacy Officer oversees privacy governance including policy, dispute resolution, education, communications activities, and reporting to our partners on privacy matters. Please refer to Contact Us below for information on how to reach our Privacy Officer.

Identifying Purpose

We are legally required to collect clients’ Personal Information as a result of providing and in order to provide discretionary investment management services to clients. We collect Personal Information about you from applications or forms you may complete, agreements you enter into with us, and in the course of you establishing or maintaining a client relationship with us. All of our forms and the information obtained from clients are designed to collect only information needed for the purposes set out below and for no other purpose. Regulatory requirements include but are not limited to know-your-client requirements and anti-money laundering requirements which are applicable to us as an adviser and fund manager.

We collect and use your Personal Information to:

• verify your identity;
• ensure we have accurate information about you;
• understand your financial needs and confirm your eligibility under applicable accredited or sophisticated investor requirements;
• manage our relationship;
• protect against fraud and manage other risks;
• communicate with you regarding products and services that may be of interest (but not to send unsolicited marketing communications);
• understand our clients, including through analytics, and to develop and tailor our products and services;
• comply with legal or regulatory requirements, or as required by law; and
• respond to questions you may have.

If we use your Personal Information for a different purpose, we will identify that purpose.

Consent and Your Choices

When you apply for or accept a new product or service, we obtain your consent to collect, use, or disclose your Personal Information for the purposes set out in Identifying Purpose above. Those purposes are with respect to information sharing only, and do not include marketing without your consent. We will not market products to you or send you marketing communications without your consent.

You can manage any existing marketing preferences by opting out of some or all of our direct marketing communications at any time. If you want to change these privacy preferences, please contact us.

If you opt out of certain communications, you will still continue to receive information that we are required by law to provide to you, service messages that we need to send to you, and relevant information about our products and services in the course of providing services to you. Please note that you cannot withdraw your consent to the collection, use, and disclosure of your Personal Information if we are legally required to collect, use, or disclose your Personal Information.

Withdrawing your consent in certain situations may also mean that we may not be able to provide you with the products or services you request.

Limited Collection

We only collect the Personal Information that we determine we need for the purposes set out in Identifying Purpose above.

For example, we may collect:

• Contact Information including address, telephone number, and email address.
• Tax Identification Numbers (Social Insurance Number for Canadian investors, Social Security Number or Tax Identification Number for U.S. investors, equivalent identifiers for international investors) as required to comply with tax reporting obligations.
• Financial Information to confirm your eligibility under applicable investor qualification requirements and to ensure that any investment we provide is suitable for you.
• Device Information such as information about your operating system, browser, software applications, IP address, geolocation, security status, and other device information in order to improve your experience, to protect against fraud, and to manage risk. For more information, see our Cookie Policy below.
• Website Use Information such as browsing behavior on our sites and links, location you select, form data and downloads, as well as other data gathered from the use of web tools (for example, Cookies, Web Beacons, Tagging).
• Employment Information including information about your previous and current employers, where relevant to confirming your investor qualification.

We may collect Personal Information about you from you and from third parties or sources that are available to the public for the purposes set out in Identifying Purpose above.

You can choose not to provide us with certain information in some situations, but if you make this choice, we may not be able to provide you with the product, service, or information you request.

We may monitor or record our incoming or outgoing telephone calls with you to ensure accuracy, security, service quality, for training purposes, to protect you against fraud, and to establish a record.

Limited Use and Disclosure

We will only use or disclose your Personal Information for the purpose(s) it was collected and as otherwise identified in this Privacy Policy.

We do not sell the names or other Personal Information of our clients. We do not disclose the names or other Personal Information of our clients to third parties without your consent, except as set out below or unless required or permitted by law.

We may disclose your Personal Information:

• To businesses we buy or sell. We may transfer Personal Information as part of a corporate reorganization or other change in corporate control.
• To a party acting for you or at your request — for example, your legal counsel, accountant, or financial advisor.
• To a person who holds an account jointly with you.
• To third parties including legal or regulatory authorities in cases of suspected criminal activity or contravention of law, for the detection and prevention of fraud, or when required to satisfy the legal or regulatory requirements of domestic or international governments, government agencies, tax authorities, securities regulators, regulatory authorities, or other self-regulatory organizations, or to comply with a court order or for the protection of our assets.
• To service providers who provide services on our behalf such as fund administration, custody, audit, tax preparation, data processing, account administration, analytics, and technology services. Such providers will be given only the Personal Information needed to perform those services and we do not authorize them to use or disclose Personal Information for their own marketing or other purposes. We have contracts in place holding these providers to the same standards of confidentiality by which we are governed. In some cases, these providers may be located outside of your province or country (including in the United States). These providers may be required to disclose information to courts, government authorities, regulators, or law enforcement in accordance with applicable law in that country. In some cases, your information may be subject to the laws and access rights of authorities in foreign countries.

Retention

We have policies in place that govern the retention of your Personal Information so it will be kept only for as long as reasonably necessary to fulfill its intended purpose or to satisfy legal requirements.

To determine the appropriate retention period, we consider different criteria, including the purposes for which we hold your Personal Information, the need for maintaining your Personal Information to provide you with products and services, and all applicable legal and regulatory requirements. We may retain Personal Information beyond our designated retention periods due to regulatory requirements, in response to a legal matter, or to serve you better. These requirements also apply to third parties who work with us.

Accuracy

We are committed to maintaining the accuracy of your Personal Information and ensuring it is complete and up-to-date. If you discover inaccuracies in our records, or your Personal Information changes, please notify us immediately so that we can make the necessary changes. Failure to notify us of changes to your Personal Information may negatively impact the way we communicate or provide services to you. Where appropriate, we will advise others of any material amendments to your Personal Information that we may have released to them. If we do not agree to make the amendments that you request, you may challenge our decision as described in Contact Us.

Accuracy

We are committed to maintaining the accuracy of your Personal Information and ensuring it is complete and up-to-date. If you discover inaccuracies in our records, or your Personal Information changes, please notify us immediately so that we can make the necessary changes. Failure to notify us of changes to your Personal Information may negatively impact the way we communicate or provide services to you. Where appropriate, we will advise others of any material amendments to your Personal Information that we may have released to them. If we do not agree to make the amendments that you request, you may challenge our decision as described in Contact Us.

Safeguards

We use physical, electronic, and procedural safeguards to protect against unauthorized use, access, modification, destruction, disclosure, loss, or theft of your Personal Information in our custody or control. We have agreements and controls in place with our third-party service providers requiring that any information we provide to them must be safeguarded and used only for the purpose of providing the service we have requested.

Openness

From time to time, we may make changes to this Privacy Policy. We will post the current version of the policy on our website and indicate the effective date. Please go to Contact Us to answer any questions you may have about this Policy.

Individual Access and Rights

You can make a request to access and verify the Personal Information we hold about you. You must make the request in writing to us and we will need specific information from you to process your request. We may charge you a token fee depending on the nature of your request, and we will advise you of any fee prior to proceeding with your request. If we are unable to provide some of the Personal Information we hold about you, we will tell you why.

Contact Us

If you have any questions or concerns about our privacy practices, the privacy of your Personal Information, or you want to know more about your privacy choices, or if you wish to raise a complaint on how we have handled your Personal Information, you can contact our Privacy Officer, who will then investigate the matter:

If you are not satisfied with our response or believe we are not processing your Personal Information in accordance with applicable law, you may make a complaint to the Office of the Privacy Commissioner of Canada:

• Call: 1-800-282-1376
• Visit: www.priv.gc.ca

Cookie Policy

If you access our website, certain information about your computer or device will automatically be generated, collected, and logged by technological means such as cookies and related technologies like pixel tags or beacons (collectively referred to as “cookies”). This information may include the type of browser you are using, your general geographic location, device models, operating system version, click rates, and web pages visited. Note that these cookies by themselves do not identify you personally or tell us your email address, and your Internet Protocol (IP) Address is anonymized by default. The data collected is aggregated and used to analyze the number of unique visitors to our site and geographic origin trends, but not to identify individual site visitors.

A notification banner will appear on our website allowing you to manage your consent to collect cookies. Below are the types of cookies we collect and how withholding your consent would affect certain features of the site:

• Strictly necessary and functional cookies — these are essential to enable users to navigate the website and use its features. They must be enabled and cannot be blocked, or the site will not function properly.
• Analytics and performance cookies — these gather data to enhance performance of the site. You can manage your consent for performance cookies by using the cookie banner or by updating your browser’s setting (generally under the Tools or Preferences menu) to decline cookies.
• Advertisement cookies — these are rarely used but may be activated as part of CRIMSON promotional campaigns on platforms such as LinkedIn.

We may, from time to time, use cookies and the information they generate to:

• Improve your user experience — for example, make certain content or pages more readily accessible.
• Enable certain website functions — for example, set your language preferences.
• Provide us with analytics — we use Google Analytics, a third-party analytics tool that helps us understand how visitors use our site, which allows us to improve our content. The data is aggregated and covers things such as total visits or page views.

If you would like to delete cookies or instruct your web browser to delete or refuse cookies, please visit the help pages of your web browser. Note that if you delete or refuse to accept cookies, you might not be able to use all of our website features or to store your preferences, and some of our site pages may not display properly.