The Company and its respective service providers will collect and process personal data provided by investors in relation to an investment in the Funds (including through completion of the subscription agreement) and/or in the course of operating the Funds or the Sites, including, without limitation, first name, last name, residential address, e-mail address, telephone number and other contact details; demographic information; correspondence with you; date and place of birth, citizenship and profession; identity documents; assets; incomes; tax details; capital account balances; account data; and information about participation in other investments. The Company may also obtain personal data about criminal convictions or offenses concerning investors' representatives, authorized signatories, shareholders, members, partners, underlying investors or beneficial owners from publicly available and accessible registries and sources, and third-party databases used to perform due diligence and other screening activities.

Additionally, when individuals visit the Sites, we may automatically log the following information:

• Device Information: The manufacturer and model, operating system, browser type, IP address, and unique identifiers of the device you use to access the Sites. The information we collect may vary based on your device type and settings.
• Usage Information: Information about how you use our Sites, such as the types of content that you view or engage with, the features you use, the actions you take, and the time, frequency, and duration of your activities. We use Google Analytics, a web analytics service provided by Google to help collect and analyze usage information.
• Location Information: We may derive a rough estimate of your location from your IP address when you visit our website. Depending on the choices you make on your mobile device, we may also collect and maintain a history of your precise location information using WiFi and Bluetooth technologies, as well as your device identifiers and GPS coordinates (e.g. latitude/longitude). If you want to prevent the collection of your location information, please adjust your settings on your device.

This data will be processed for the purposes set out in the Our Data Collection and Use Practices section below.

In connection with forming, managing and operating the Funds and the Sites, we collect and maintain personal data (such as addresses, social security numbers, and information about assets, income and sources of wealth) from the following sources:

• information we or our representatives receive from you in conversations, including over the telephone, in voicemails, through written correspondence, via e-mail, or information set out in any subscription agreements, investor questionnaires, applications or such other forms and documents as we may request to be completed in relation to the management or administration of any investment in the Funds, and any personal data provided by you by way of correspondence or interactions with us by phone, e-mail or otherwise;
• client due diligence documentation we obtain or hold as part of our regulatory obligations;
• information we obtain or hold about your transactions with us or others;
• information we receive from you or third party sources, including as necessary to comply with law and regulations that apply to us, or entities in which we invest which may include, among others:
• entities in which you or someone connected with you has an interest;
• your legal and/or financial advisors;
• other financial institutions who hold and process your personal data to satisfy their own regulatory requirements; or
• credit reference agencies and financial crime databases;
• information we receive when you interact with us on social media platforms such as Vimeo and LinkedIn. When you interact with us on social media, we may receive personal data that you provide or make available to us based on your settings, such as your contact details. In addition, the companies that host our social media pages may provide us with aggregate information and analytics regarding the use of our social media pages; and
• information captured on websites or portals operated by or for us or our affiliates, including registration information and any information captured automatically via 'cookies' or other tracking technologies (such as local storage technologies and web beacons).

Lawful grounds for processing

Each of the Funds, the Manager, the Administrators and the KYC/AML Service Provider is entitled to hold and process your personal data on the following lawful grounds:

• the processing is necessary for our legitimate interests, provided your interests and fundamental rights do not override our legitimate interests;
• where you are a natural person, the processing is necessary to comply with our respective contractual duties to you under the terms of our subscription agreement or any agreement with you;
• to comply with our legal and regulatory obligations;
• on exceptional occasions, where we have obtained your consent or you have directed us to process the personal data; or
• on rare occasions, where holding and processing your personal data is needed in the public interest.
  

Some of the grounds for processing described above will overlap and there may be several grounds which justify our use of your personal data.

Inaccurate or amended information

Please let us know if any of your personal data (including correspondence details) changes as soon as possible. Failure to provide accurate information or to update changed information may have a detrimental impact upon your investment or your returns from it. Failure to provide any information that is required for anti-money laundering or financial crime purposes, pursuant to automatic exchange of information agreements, or due to other legal requirements means that the Company may not, or may no longer, be able to accept you as an investor in the Funds.

Purposes of processing

Information may be processed by the Company (or any of our affiliates, agents, employees, delegates or sub-contractors) where necessary to comply with the Company's legal obligations, as needed for our legitimate interests indicated below, or where the processing is in the public interest. Specific purposes of processing include the following:

• for identity verification and other anti-money laundering and financial crime checks and related actions for the purpose of preventing fraud or other financial crime, complying with statutory and regulatory requirements in relation to anti-money laundering and terrorist financing requirements including the Funds' own in house procedures. Such use is (A) necessary to perform obligations under the subscription agreement and to comply with legal obligations such as anti-money laundering laws and regulations, (B) necessary for the Company's legitimate interest in preventing, detecting, investigating and prosecuting fraud and/or other criminal activity, and managing risks;
• to facilitate the opening of an investor's account with the Company, the management and administration of an investor's holdings in the Funds and any related account, on an on-going basis, which are necessary for the performance of the investor's obligations under a subscription agreement, articles of incorporation or side letter, including in respect of the processing of subscriptions, transfers, withdrawals and the payment of distributions;
• for administering the business of the Company in an efficient and proper manner, including conducting audits, implementing risk management processes, corporate governance, maintaining and monitoring IT systems and management of third party service providers. Such processing is necessary for the Company's legitimate interests in managing risks and in the efficient management of the business;
• for detecting, investigating and preventing internal and external breaches of internal policy and applicable law and regulation and establishing, exercising and defending legal rights. Such processing is necessary for the Company's legitimate interests in ensuring compliance with the Data Protection Laws, in managing risks and in the efficient management of the business;
• to report tax related information to tax authorities in order to comply with a legal obligation;
  
• to correspond with you, including to send you direct marketing communications notifying you of fundraising initiatives and investment opportunities via email and other means. Where required by applicable laws, we may rely on your consent to send you direct marketing communications or to pursue the Company's legitimate interests;
  
• to provide, operate, maintain, and improve the Sites, and to create new features, and personalize your experience on the Sites. Such processing is necessary for the Company's legitimate interests;
  
• to monitor and record calls and electronic communications, including in connection with: (A) the verification of instructions; (B) investigations and fraud prevention measures; (C) crime detection, prevention, investigation and prosecution; (D) enforcing and defending rights or remedies of the Company or one of its affiliates, together with the rights or remedies of any third parties to whom we delegate any of our rights or responsibilities; (E) pursuing the legitimate interests of the Company in relation to such matters; or (F) otherwise where monitoring or recording is in the public interest;
  
• to disclose information to other third parties such as regulatory or tax authorities or service providers of the Company, including auditors, legal counsel, regulatory authorities, advisers or technology providers, in order to comply with any legal obligations imposed on the Company (including, for the avoidance of doubt, entities in which we invest) or in order to pursue the legitimate interests of the Company;
  
• to monitor and record calls for quality, business analysis, training and related purposes in order to pursue the legitimate interests of the Company to improve its service delivery;
  
• to update and maintain records and carry out fee calculations to pursue the legitimate interests of the Company;
  
• to carry out statistical analysis and market research to comply with our contractual duties and to pursue the legitimate interests of the Company; and
  
• to retain anti-money laundering and other records of individuals to assist with subsequent screening by the KYC/AML Service Provider, including in relation to your investment in other funds administered by the KYC/AML Service Provider in pursuance of the KYC/AML Service Provider's or its clients' legitimate interests.
  

Note that we do not sell or otherwise disclose your personal data for monetary or other valuable consideration. Nor do we process your personal data for cross-context behavioral advertising purposes.

We will only use your personal data for the purposes for which we collected it unless we reasonably determine that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your consent, in compliance with the above rules and where we can rely on another legal basis as set out above, where doing so is required or permitted by law or regulation.

The Company does not make decisions about you based on automated processing of your personal data.

Our Sites may contain links to other websites and services that we do not operate or control. The information that you share with such third-party services will be governed by the specific privacy policies and terms of service of those sites and not by this Privacy Notice. By providing these links, we do not imply that we endorse or have reviewed these sites. Please contact the relevant services directly for information on their privacy practices and policies.

We do not disclose any personal data about you, except to affiliates, relevant parties associated with portfolio investments and third party service providers for everyday business purposes (such as to process transactions, maintain accounts, respond to court orders or legal investigations), as permitted by law or regulation, or at your direction. In particular, we may disclose your personal data, as follows:

• to the Company's affiliates and third party service providers, transfer agents, accountants, legal service providers, broker-dealers or custodians. These parties perform certain services and functions as required by or in connection with an investor’s investment and to ensure performance of the subscription agreement. Subject to the Company's permission and instructions, such parties may provide personal data to sub-processors;
• to other service providers that assist the Company in meeting business operations needs and as necessary in connection with an investor’s affairs, investment and the affairs of the Company or for complying with legal obligations as described above. These parties include providers of certain services and functions such as hosting and cloud services and other information technology providers, email archiving services, production of investor notices and financial statements, providers of client relationship management, investment management, reporting software and other software used to meet business operation needs. Pursuant to the Company's instructions, these parties may access, process or store personal data in the course of performing their contractual duties;
• to third parties such as other investment funds, bank account providers, managers, directors, officers, employees, attorneys, financiers (including senior lenders), auditors or any other service providers together with their respective advisers, agents and service providers in relation to the operations of the Company;
• to governmental, regulatory or tax authorities, or other investors/limited partners, including in connection with the disclosure of tax treatment and tax structure of the Company and all related documentation relating to such tax treatment and tax structure, financial markets or other intermediaries or counterparties or courts, pursuant to applicable laws and regulations;
  
• to prospective investors for the purposes of enabling others to make investments in the Company; and
  
• to retain anti-money laundering and other records of individuals to assist with subsequent screening by the KYC/AML Service Provider including in relation to your investment in other funds serviced by the KYC/AML Service Provider in pursuance of the KYC/AML Service Provider's or its clients' legitimate interests. The KYC/AML Service Provider processes your personal data in accordance with its Privacy Statement which details equivalent levels of protection to this Privacy Notice. You will be requested to review the Privacy Statement upon registering in the KYC/AML Service Provider’s online application.
  

Notwithstanding the foregoing, we may share your personal data over the course of a business transaction, such as with counterparties and others assisting with a merger, acquisition, financing, reorganization, bankruptcy, receivership, dissolution, asset sale, or similar transaction, including formation or operation, and with successors or affiliates as part of or following that transaction.

Personal data may be processed by us or our service providers in jurisdictions including: the United States, Canada, the Cayman Islands, the EEA, the United Kingdom, Singapore, India, Switzerland, the Philippines, South Africa, Mauritius and Guernsey. Data protection laws in such countries may be less stringent than or otherwise different from the data protection laws in your jurisdiction and therefore may not offer the same level of data protection. When transferring personal data internationally, we shall comply with the requirements of DPA and GDPR, as amended, together with any successor legislation or binding ordinances or regulations made in pursuance thereof from time to time. Where required by applicable laws (for example, where personal data is being transferred to a country which is not recognized as providing adequate protection in your jurisdiction), the Company has, or has authorized the KYC/AML Service Provider as its agent to, put in place standard contractual clauses with relevant parties to whom personal data will be transferred, which clauses are available upon request. If you require further information, please contact chris@tuckersfarm.com.

The Company will retain your personal data for as long as required in order for them to perform the aforementioned services or carry out the purposes for which the information was collected, depending on the legal basis for which the information in question was obtained or whether additional legal or regulatory obligations mandate that the Company retains your personal data. The Company applies criteria to determine the appropriate periods for retaining personal data depending on its purpose, nature, and sensitivity and any retention periods provided by applicable laws and regulations.

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

We consider the protection of personal data to be a sound business practice, and to that end we employ physical, electronic and procedural safeguards to protect your personal data in our possession or under our control from unauthorized access and use, unlawful processing, and accidental loss, destruction, or damage, including security measures required to ensure compliance with laws and regulations.

The Company will endeavor to store your personal data securely in accordance with accepted market standards, and may do so either electronically or manually.

While the Company has taken every reasonable care to ensure the implementation of appropriate technical and security measures, we cannot guarantee the security of your personal data (including in respect of any transmission over the internet, via email or via our websites), nor do we accept, to the fullest extent permitted by law, any liability for any errors in data transmission, machine, software or operating error or any other cause.

Marketing Communications: You may opt out of marketing-related communications by following the opt-out or unsubscribe instructions contained in the marketing communications we send you.

Limit Online Tracking: Most browsers let you remove or reject cookies that we or our service providers may place on our Sites. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. Our Sites currently do not respond to "Do Not Track" or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Personal Data Requests: You have, in certain circumstances, the following rights in relation to your personal data:

• the right to learn more about what personal data of yours is being processed, how and why such information is processed and the third parties who have access to such personal data under the CCPA. We have made this information available to you without having to request it by including it in this Privacy Notice;
• the right to access your personal data under the DPA, GDPR, DPL or CCPA;
• the right to rectify/correct your personal data under the DPA, GDPR, DPL or CCPA;
• the right to restrict the use of your personal data where permitted under the DPA, DPL or GDPR, as amended, or other applicable law;
• the right to request that your personal data is erased/deleted where permitted under the DPA, DPL, GDPR or CCPA, as amended, or other applicable law;
• the right to data portability (i.e. receive your personal data or have it transferred to another controller in a structured, commonly-used, machine readable format) where permitted under the DPA, DPL, GDPR or CCPA, as amended, or other applicable law; and
  
• the right to object to processing of your personal data or to direct us not to share your personal data with a non-affiliated third party where permitted under the DPA, DPL or GDPR, as amended, or other applicable law.
  

Where you have provided your consent to processing for the purposes indicated above, you may withdraw your consent at any time (or otherwise exercise your aforementioned rights in relation to your personal data) by contacting the Manager (see contact details below).

In order to comply with your request, you may need to provide us with personal data and other information to verify your identity and the nature of your request. Depending on your jurisdiction, you may designate an authorized agent to make a request on your behalf. We will require the authorized agent to have a written authorization confirming that authority.

Please note that in some circumstances, we may not be able to fully comply with your request, for example if we are required to retain certain information about you to comply with applicable laws and regulations or if the information is necessary in order for us to provide the services you requested. In particular, we, and our collection and processing of your personal data, may be governed by laws and regulations on anti-money laundering, fraud prevention, taxation and financial services. We will not discriminate against you for exercising your rights. We will not deny you access to our services, or provide you a lower quality of services if you exercise your rights.

You may also appeal to certain courts against (A) any failure of the relevant authority (as applicable) to give written notice of whether the complaint is either being investigated or not being investigated and, where applicable, the progress and the outcome of the investigation or (B) a determination of the relevant authority (as applicable) not to investigate the complaint or a determination that a controller or processor has not breached or is not likely to breach an operative provision in connection with the complaint.

You can contact us via email at chris@tuckersfarm.com to exercise the foregoing rights.

We reserve the right to change this Privacy Notice, or any other relevant policies or procedures, at any time, without notice, in which case the date of this Privacy Notice will be revised. The examples contained within this Privacy Notice are illustrations only and are not intended to be exclusive or exhaustive.

You may have additional rights in respect of data protection under other U.S. or foreign laws (including those of states or other subdivisions) that may apply to you.