Privacy Policy | A&M Capital

A&M Capital Privacy Notice

Our Commitment To Privacy

This Privacy Notice was last updated April 2025.

Your privacy is important to A&M Capital Advisors, LP, such other companies forming part of the A&M Capital group of companies and our affiliates (together, “AMC”, “our”, “us”, “we” or “Fund”). To better protect your privacy, we are providing information explaining our online information practices.

Applicability of this Privacy Notice

This Privacy Notice (the “Notice”), which is supplemented by the EU and UK Privacy Notice and California Privacy Notice (each, a “Jurisdiction-specific Notice”), as applicable, describes how we collect and process personal data, personally identifiable information, personal information or other similar terms (referred to in this Notice as “personal data”) about you, how we use and protect your personal data and the rights you may have in relation to your personal data. Please read this Notice carefully.

If you are an individual located in the European Union (“EU”), the European Economic Area (“EEA”) or the United Kingdom (“UK”), please refer to the [ EU and UK Privacy Notice] for more information about your rights and how to exercise them, to the extent that the EU and UK Privacy Laws (as defined therein) applies.

If you are a natural person residing in California, please refer to the [California Privacy Notice] for more information about your rights and how to exercise them.

This Notice, and the Jurisdiction-Specific Notices, apply to any personal data we collect about you by us (or our service providers):

on or through our website (www.a-mcapital.com/) or other websites that we may control and where this Notice is posted (together, “Our Website”);
through offline and online communications (including emails);
when you provide information via our “Contact Us” page, or via the “Investor Login” page on Our Website;
when you visit our offices;
about representatives of our vendors, business partners and portfolio companies;
when you apply for a job with us; and/or
through any other data collection points where we refer to this Notice.

This Notice and the Jurisdiction-specific Notices do not apply to any processing of personal data by or on behalf of AMC that is covered by a more specific privacy notice, including with respect to any personal data processed about actual or potential investors of investment vehicles related to AMC.

Information regarding how we process personal data collected via the “Investor Login” page, is set out in our applicable Private Placement Memorandum and/or Subscription Booklet.

Contact Us

If you have any questions regarding our use of your personal data, or this Notice, please contact [email protected].

The Data We Collect About You

We collect, use, store and transfer the following kinds of personal data about you, depending on the nature of our relationship with you:

basic information: such as your name, name of your employer, title, job title, position;
contact information: such as your address, telephone number and email address
information that you give us when you contact us: such as via the “Contact” section or via the “Investor Login” page of Our Website, when you visit our offices, when you communicate with us over email or the telephone, information from your CV when you apply for a job with us, etc.;
information about you collected through automated technology, such as cookies or other online identifiers on Our Website: such as your internet protocol (IP) address, your login data, and other similar identifying data. For further information on the types of cookies and the purposes for which we use such cookies, please see our [Cookie Policy].
identification and background information: such as social insurance number, passport information, financial information and any other information provided by you or collected by us as part of our due diligence and business acceptance processes, in order to comply with our regulatory requirements;
marketing and communications information collected about you or that you provide to us: such as your preferences in receiving marketing information from us and our third parties and your communication preferences;
information in relation to companies that we are evaluating in connection with a potential investment in or purchase of such companies: such as your name, title, email address, passport information, obtained via third parties (i.e., the company in question);
information provided by third parties: such as personal data obtained from placement agents that we engage to market our applicable services; and
any other information: including information relating to you that you may provide to us.

Further information about the legal bases under which we process your personal data is included in the section headed [Why we use your personal data].

You do not need to take any action as a result of this Notice, but you do have certain rights as described below in the section headed [Your rights] .

Why We Use Your Personal Data

We rely on various legal bases under applicable data protection legislation in order to process your personal data, including our legitimate interests, contractual necessity and as required by law. We use the personal data we collect to operate our business and provide you with the services and products we offer and perform essential business operations. Please note that we may process your personal data in other ways for which we provide specific notice at the time of collection and obtain your consent if required by applicable law. We do not collect any special categories of personal data about you, nor information about criminal convictions and offences.

We may also process your personal data on more than one legal basis depending on the specific purpose for which we are using your personal data. We will only use your personal data for the purposes for which we have collected it, unless we reasonably consider 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 explain the legal basis which allows us to do so.

If we require your personal data due to a legal requirement or obligation or in order to perform a contract with you, we will make you aware of this at the time we collect your personal data, and the possible consequences of you failing to provide this personal data (e.g., we may require your passport details to verify your identity for the purposes of anti-money laundering regulations and failure to provide this information means that we cannot provide our services or products to you). In this case, we may have to cancel a service or investment you have with us but we will notify you if this is the case at the time.

To the extent that you provide us with, or we otherwise collect, any personal data, through or in connection with Our Website, we may use such information for the below purposes and may process your personal data on more than one legal basis depending on the specific purpose:PurposeLegal BasisTo provide you with the services or financial products you have requested and otherwise perform our contractual obligations that you have requested or agreed with us, including responding to your enquires and requests providing you support.Contractual necessity; and / or our legitimate interest in operating our business and providing investment servicesTo communicate with you (including via use of the Global Relay application), to operate, schedule and facilitate meetings (in person and online) and administer your participation in any of our events.Our legitimate interest in operating our business and providing investment services; and / or consentTo keep a record of your relationship with us.Our legitimate interest in operating our business and providing services; and / or legal requirementTo verify your identity (including to conduct anti-money laundering or KYC checks and to enable you to access our offices) or to evaluate a potential investor, business partner or supplier).Legal requirement; contractual necessity; consent; and / or our legitimate interest in operating our business and providing investment servicesTo conduct due diligence activities in connection with an actual or prospective corporate transaction or investment with respect to which we are party to.Our legitimate interest in operating our business and providing our investment services; contractual necessity; and / or legal requirementTo protect against identity and prevent fraud, abuse, money-laundering, cyber-attacks, theft of our property, other threats to the safety, security and integrity of our website, investor portals, products and services, databases, technology assets or our business, and other malicious, or unlawful activity.Legal requirement and / or our legitimate interest in operating our business and providing investment services securely and safelyTo conduct conflict checks.Legal requirementTo monitor and manage our portfolio companies.Our legitimate interest in operating our business; and / or contractual necessityTo process and administer details associated with your investment and service your requests, and to offer and improve our services.Our legitimate interest in operating our business; and/or consentComplying with our legal obligations and corporate governance practices.Legal requirement; our legitimate interest in operating our business; and/or consentTo obtain advice from our professional advisors, including lawyers and accountants.Our legitimate interest in operating our businessLitigation management and conducting internal audits and investigations.Legal requirement and / or our legitimate interest in operating our businessTo administer, market and protect our business and this site.Our legitimate interest in operating our business; and / or consentTo respond to your contact requests via email, post or telephone.Our legitimate interest in operating our businessTo make suggestions and recommendations to you about goods or services that may be of interest to you.Our legitimate interest in operating our businessTo consider job candidates for our existing and potential recruitment needs and those of our portfolio companies whether in respect of permanent roles or temporary assignmentsOur legitimate interest in operating our business; and/or consentTo send you information communications.Consent and legitimate interestFor performance of IT systems.Our legitimate interest in operating our businessFor any other purpose that has been notified, or has been agreed, in writing.Consent

No automated decision-making or profiling, is used when processing your personal data.

Information Requests

We will only send you information communications where you have requested information from us relating to our products and services which you might be interested in, including by emailing the “general enquiries” email address listed in the “Contact” section of Our Website. You may request we stop sending you information communications by emailing [email protected] at any time.

Disclosure and Transfer of Personal Data

Your personal data may be shared with and processed by third parties, including our group companies and affiliates, certain service providers and our agents as necessary to fulfil the purposes set out in this Notice, including, but not limited to legal and financial professional advisors, auditors, recruitment firms, agents, contractors, IT and data security providers and data hosting providers, and in some instances, placements agents and other fund administrators. We require anyone who provides a service to, or for us, enters into an agreement with us to ensure the provider meets our standards for data security and treats your personal data in accordance with applicable data protection law. We do not allow third-party service providers to use your personal data for their own purposes in accordance with our instructions. We do not authorise these third-party service providers to use or disclose the personal data except as necessary to perform services on our behalf or comply with legal requirements.

Mobile information shared with the use of the Global Relay application in connection with any business performed for you by us will not be shared with third parties/affiliates for marketing/promotional purposes. We will not send you text messages without your prior consent, and will include clear opt-out procedures so that you can stop receiving such communications at any time. Notwithstanding anything else herein, to the extent text messaging originator opt-in / opt-out data and consents are collected, such information will be solely used by our third-party providers to manage the text message opt-in / opt-out procedures.

We reserve the right to disclose your personal data as required by law, or when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, request from a regulator, national security, for the purposes of public importance or any other legal or investigatory process involving us. Should we, or any of our affiliated entities, be the subject of a takeover, divestment or acquisition we may disclose your personal data to the new owner of the relevant business and their advisors.

Security and Retention of Personal Data

We are committed to protecting the personal data you entrust to us. We adopt robust and appropriate security measures and policies, so the information we have about you is protected to the extent possible from unauthorized access, loss, destruction or improper use. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Although we do our best to protect your personal data, we cannot guarantee the security of any information or data transmitted to or through Our Website; any transmission of information or data by you to or through this site is at your sole risk.

We will keep your personal data only for as long as is reasonably necessary for the purposes set out in this Notice, unless a longer retention period is required by law. We will not keep more information than we need for those purposes. We may also retain your personal data so that we can continue to improve your experience with us and to ensure that you receive any information or marketing materials which would benefit you. We will also keep your personal data where we need to do so in connection with regulatory requirements, legal action or an investigation involving AMC and our affiliates. Once our processing of your personal data is no longer necessary, we will securely destroy your personal data in accordance with applicable laws and regulations. For further information about how long we will keep your personal data, please contact [email protected].

Capacity

Our Website is only intended for individuals who are at least eighteen (18) years of age. We do not knowingly encourage or solicit visitors to this site, or collect personal data (without parental consent), from anyone who is under the age of eighteen (18). If we learn we have collected or received personal data from an individual under the age of eighteen (18), we will delete that information.

Your Rights

Under certain circumstances, by law you have the right to:

ask us about the processing of your personal data, including to be provided with a copy of your personal data;
request the correction and/or deletion of your personal data; request the restriction of the processing of your personal data, or object to that processing;
request receipt or transmission to another organization, in a machine readable form, of the personal data that you have provided to us; and
complain to your local supervisory authority if your privacy rights are violated, or if you have suffered as a result of unlawful processing of your personal data.

Please also refer to the [EU and UK Privacy Notice] and [California Privacy Notice] (as applicable) for more specific information about your rights. If you would like more information about your rights, or have any concerns about AMC’s processing of your personal data, please let us know by getting in touch with us using the details in the [Contact us] section above.

Links to External Sites

Our Website may provide access or contain links to websites and services owned and operated by third parties. AMC does not review or monitor any such websites linked from or to the Website and is not responsible for the content of any such sites, or any products or services contained on or accessible through such other sites, their terms of use or privacy policies. Accordingly, AMC disclaims responsibility for the information, materials, products or services obtained on or from such other websites, nor will AMC be liable in any respect for any damages arising from your access to such websites.

Third party websites may have a privacy policy or security practices different from Our Website so it is important to read the policies of those sites before sharing your personal information.

Notification of Changes

We reserve the right to amend this Notice, and the Jurisdiction-specific Notices from time to time. If we decide to change this Notice, we will post those changes so our users are always aware. If at any point we decide to collect personal data or use any collected information in a manner different from that stated at the time it was collected, we will notify applicable users. We will use information only in accordance with the Notice under which the information was collected.

A&M Website Cookie Policy

Introduction

We set and use cookies to run website analytics on Our Website. The use of cookies aims to help improve your user experience. More information about how we use cookies and how you can manage your settings, is set out below.

What is a Cookie and Types of Cookies

A cookie is a small text file placed on your device or computer and is used to identify the user or device and to collect data. In summary, the cookies help remember you and how you’ve used the website every time you revisit it.

At any time, you can reset your browser so as to refuse any cookie or to alert you to when a cookie is being sent. Web browsers allow you to control cookies stored on your hard drive through the web browser settings. If you wish to know more about cookies, you will find links to some useful resources below. https://us.norton.com/internetsecurity-how-to-what-are-cookies.html https://computer.howstuffworks.com/internet/basics/question82.htm

What We Use Cookies For

We use cookies for several purposes. To make it easier for you to understand why we need them, we have put our cookies into the following categories (based on the guidelines found in the [UK Information Commissioner’s Office’s Cookie Guide] ):

1. Strictly Necessary Cookies: These cookies are essential to enable you to move around the website and use its features. Without these cookies, we may not be able to provide certain services you have asked for. Further details are provided in the table below:Cookie NameFunctionDurationCloudFlareThis cookie is used to distinguish between humans and bots.30 minutes.OneTrustThese cookies are set by the cookie compliance solution from OneTrust. One stores information about the categories of cookies the site uses and whether visitors have given or withdrawn consent for the use of each category. This enables site owners to prevent cookies in each category from being set in the users browser, when consent is not given. It contains no information that can identify the site visitor. The other cookie is set after visitors have seen a cookie information notice and in some cases only when they actively close the notice down. It enables the website not to show the message more than once to a user. The cookie contains no personal information.These cookies have a normal lifespan of one year.

2. Performance Cookies: These cookies collect information about how you use the website. This information may include the internet browser used, the domain name of a website previously visited, and traffic log data to identify which pages are being used. These cookies are used to help us analyze data about web page traffic, optimise the website and make it more user-friendly. Further details are provided in the table below:Cookie NameFunctionDurationGoogle AnalyticsGoogle Analytics sets separate cookies to collect information about how visitors use the website.The primary Google Analytics cookie expires in 2 years. Their second cookie expires in 24 hours and the third expires in 1 minute. They have a campaign cookie which expires in 90 days, a user and session cookie which expires in 2 years.

Additional Google cookies expire in the following rates: 10 minutes, 30 minutes, end of browser session, 6 months, 2 years, 18 months, 18 months, and 90 days.

An AMP cookie expires in 30 seconds to 1 year.

3. Functionality Cookies: These cookies allow the website to remember choices you make and provide enhanced, more personal features. For example, we may store your intranet username and password, language preference, or your geographic location. We may also remember preferences such as text size, fonts and other customisable site elements. The information these cookies collect may be anonymised, will not personally identify you and cannot track your browsing activity on other websites.

We use Google Analytics to collect statistical information about how you use the website. We use the information to improve the website. The cookies collect information relating to the number of visitors to the website, and where the visitors have come to the website from. Further details are provided in the table below:Cookie NameFunctionDurationGoogle AnalyticsGoogle Analytics sets separate cookies to collect information about how visitors use the website.The primary Google Analytics cookie expires in 2 years. Their second cookie expires in 24 hours and the third expires in 1 minute. They have a campaign cookie which expires in 90 days, a user and session cookie which expires in 2 years.

Additional Google cookies expire in the following rates: 10 minutes, 30 minutes, end of browser session, 6 months, 2 years, 18 months, 18 months, and 90 days.

An AMP cookie expires in 30 seconds to 1 year.

4. Advertising Cookies: Advertising cookies are used to make advertising messages more relevant to you. They prevent the same ad from continuously reappearing, ensure that ads are properly displayed for advertisers, and in some cases select advertisements that are based on your interests. Further details are provided in the table below:Cookie NameFunctionDurationNot applicableNot applicableNot applicable

5. Analytics and Customization Cookies: Analytics and customization cookies [, including Google Analytics] are used to provide enhanced functionality and make our website easier to use, by remembering your preferences, including the preferences you have indicated on our cookies tool. As third parties set these cookies, you must use your browser settings or visit the third party site and follow the instructions in their cookie notice in order to refuse them. Further details are provided in the table below:Cookie NameFunctionDurationGoogle AnalyticsGoogle Analytics sets separate cookies to collect information about how visitors use the website.The primary Google Analytics cookie expires in 2 years. Their second cookie expires in 24 hours and the third expires in 1 minute. They have a campaign cookie which expires in 90 days, a user and session cookie which expires in 2 years.

Additional Google cookies expire in the following rates: 10 minutes, 30 minutes, end of browser session, 6 months, 2 years, 18 months, 18 months, and 90 days.

An AMP cookie expires in 30 seconds to 1 year.

To learn more about opting out of Google Analytics, please click [here].

Managing Cookies

It is important that you understand what cookies are being used by us, so please make sure you read this policy carefully. Where cookies are not necessary for us to provide the services you have requested, we will ask you to consent to their use when you first visit the website. If you wish to then manage the cookies we use, you have the ability to change the settings on your internet browser to see what cookies you have and delete them individually, accept all cookies, to notify you when a cookie is set, or to not receive cookies at any time. You can visit the ‘options’ or ‘preferences’ menu on your browser to change cookie settings. We will not need your consent to use non-privacy intrusive cookies which are necessary for the functioning of the website (i.e. the ‘Strictly Necessary Cookies’ as described in the [What We Use Cookies For] section above. Please note that if you ‘opt-out’ and choose not to consent to the use of particular cookies, we may be unable to provide certain services to you (which we will indicate at the point you opt-out).

You may wish to know more about cookies. Below are some useful resources that will provide you with detailed information about types of cookies, how they are used, and how you can manage your cookie preferences: www.aboutcookies.org/ or www.allaboutcookies.org/.

Contact Us

If you have any questions about this Cookie Policy, please contact us at [email protected].

A&M Capital California Privacy Notice

Last Updated: April 2025

This California Privacy Notice (the “California Privacy Notice”) supplements the Notice with respect to specific rights granted under the California Consumer Privacy Act of 2018, as amended (the “CCPA”) to natural person California residents and provides information regarding how such California residents can exercise their rights under the CCPA. This California Privacy Notice is only relevant to you if you are a resident of California as determined in accordance with the CCPA. Information required to be disclosed to California residents under the CCPA regarding the collection of their personal information that is not set forth in this California Privacy Notice is otherwise set forth in the Notice. To the extent there is any conflict with the privacy requirements under the Gramm-Leach-Bliley Act and/or Regulation S-P (“GLB Rights”), GLB Rights shall apply.

What Information Do We Collect About You?

We collect limited types of personal data through Our Website as well as through other electronic communications (e.g., emails), as applicable. The types of personal data we collect about you depends on the nature of your interaction with us. The categories of personal data we collect or have collected from individuals over the last twelve (12) months include the following:CategoryExamples as outlined in the CCPACollectedA. IdentifiersName, contact details and address (including physical address, email address and Internet Protocol address), and other identification (including social security number, passport number and driver’s license or state identification card number).YESB. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))Telephone number, signature, bank account number, other financial information (including accounts and transactions with other institutions and anti-money laundering information), and verification documentation and information regarding investors’ status under various laws and regulations (including social security number, tax status, income and assets).YESC. Protected classification characteristics under California or federal lawDate of birth, citizenship and birthplace.NOD. Commercial informationAccount data and other information contained in any document provided by investors to authorized service providers (whether directly or indirectly), risk tolerance, transaction history, investment experience and investment activity, information regarding a potential and/or actual investment in the applicable fund(s), including ownership percentage, capital investment, income and losses, source of funds used to make the investment in the applicable fund(s).NOE. Biometric informationImagery of the iris, retina, fingerprint, face, hand, palm, vein patterns and voice recordings or keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contains identifying information.NOF. Internet or other similar network activityUse of our website, fund data room and investor reporting portal (e.g., cookies, browsing history and/or search history), as well as information you provide to us when you correspond with us in relation to inquiries.YESG. Geolocation dataPhysical location or movements.NOH. Sensory dataAudio, electronic, visual, thermal, olfactory, or similar information.NOI. Professional or employment-related informationCurrent or past job history or performance evaluations.NOJ. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.NOK. Inferences drawn from other personal informationProfile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.NOL. Sensitive Personal Information (see further information on use of sensitive personal information below)Social security, driver’s license, state identification card, or passport numbers; account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation; racial or ethnic origin; religious or philosophical beliefs; union membership; genetic data; the contents of a consumer’s mail, email, and text messages unless you are the intended recipient of the communication; biometric information for the purpose of uniquely identifying a consumer; and personal information collected and analyzed concerning a consumer’s health, sex life, or sexual orientation.YES, as to the following types of information: account log-in, financial account in combination with any required security or access code password, or credentials allowing access to an account only.

We do not collect or use sensitive personal information other than:

To perform services, or provide goods, as would reasonably be expected by an average consumer who requests those goods or services;
As reasonably necessary and proportionate to detect security incidents that compromise the availability, authenticity, integrity, and confidentiality of stored or transmitted personal information;
As reasonably necessary and proportionate to resist malicious, deceptive, fraudulent, or illegal actions directed at us and to prosecute those responsible for such actions;
As reasonably necessary and proportionate to ensure the physical safety of natural persons;
For short-term, transient use (but not in a manner that discloses such information to another third party or is used to build a profile of you or otherwise alter your experience outside of your current interaction with us); and
To perform services on behalf of your business.

Some internet browsers have incorporated “Do Not Track” features. Most of these features, when turned on, send a signal or preference (the “DNT Signal”) to websites you visit indicating that you do not wish to be tracked.

How Do We Use Your Personal Data?

We may use your personal data for one or more of the business or commercial purposes set forth above in the “Why We Use Your Personal Data” section of the Notice. We retain the categories of personal information set forth above in the “Information We Collect” section of this California Privacy Policy only as long as is reasonably necessary for those business or commercial purposes set forth in the “Why We Use Your Personal Data” section of the Notice, except as may be required under applicable law, court order or government regulations.

Who Do We Disclose Your Personal Data To?

We do not sell or share (as such terms are defined in the CCPA) any of the personal data we collect about you to third parties, nor have we done so in the past twelve (12) months.

We do not disclose any nonpublic personal data about you to anyone, except as permitted or required by law or regulation and to affiliates and service providers, including, but not limited to, administrators, lenders, banks, auditors, law firms, state and federal governmental agencies or pursuant to legal process, regulatory entities, self-regulatory organizations, consultants, third-party due diligence providers and placement agents. We may also disclose your information to other parties as may be required by law or regulation, or in response to regulatory inquiries.

Within the last twelve (12) months, we have disclosed each of the categories of personal data collected with affiliates and service providers for a business or commercial purpose as set forth in the chart below.Personal Information CategoryCategory of Third-Party RecipientsA. IdentifiersAdministrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants and placement agents.B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))Administrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants and placement agents.C. Protected classification characteristics under California or federal lawN/AD. Commercial informationN/AE. Biometric informationN/AF. Internet or other similar network activityAdministrators, law firms, governmental agencies or pursuant to legal process, consultants and placement agents.G. Geolocation dataN/AH. Sensory dataN/AI. Professional or employment-related informationN/AJ. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))N/AK. Inferences drawn from other personal informationN/AL. Sensitive Personal InformationAdministrators, law firms, governmental agencies or pursuant to legal process, consultants and placement agents.

We may also share your personal data with applicable third parties in the event of a reorganization, merger, sale, acquisition, assignment, bankruptcy proceeding or other disposition of all or a portion of our business, assets or shares.

Your Rights Under the CCPA

Deletion Rights: You have the right to request that we delete any of your personal information that we retain, subject to certain statutory exceptions, including our compliance with U.S., state, local and non-U.S. laws, rules and regulations. We will notify you in writing if we cannot comply with a specific request and provide an explanation of the reasons.

Disclosure and Access Rights: You have the right to request that we disclose to you certain information regarding our collection and use of personal information specific to you. Such information includes:

The categories of personal information we collected about you;
The categories of sources from which the personal information is collected;
Our business or commercial purpose for collecting such personal information;
The categories of third parties to whom we disclose the personal information;
The specific pieces of personal information we have collected about you; and
Whether we disclosed your personal information to a third party, and, if yes, the categories of personal information that each recipient obtained.

Correction Right: You have the right to request that we correct any inaccuracies in the PII that we retain, subject to certain statutory exceptions, including, but not limited to, our compliance with U.S., state, local and non-U.S. laws, rules and regulations. We will notify you in writing if we cannot comply with a specific request and provide an explanation of the reasons.

No Discrimination: We will not discriminate against you for exercising your rights under the CCPA, including by denying service, suggesting that you will receive, or charging, different rates for services or suggesting that you will receive, or providing, a different level or quality of service to you.

How to Exercise Your Rights: To exercise any of your rights under the CCPA, or to access this notice in an alternative format, please submit a request on your behalf using any of the methods set forth in the Contact us section below.

Contact Us

For any requests relating to the exercise of your rights under the CCPA, or questions regarding our processing of your personal information, please submit or have your authorized representative submit a request using any of the methods set forth below.

Call us using the following toll-free number: 1-844-977-2060

Submit a request online using the following online form: https://www.a-mcapital.com/#contact.

Submit a request online using the following email: [email protected]

We will contact you to confirm receipt of your request under the CCPA and request any additional information necessary to verify your request. We verify requests by matching information provided in connection with your request to information contained in our records. Depending on the sensitivity of the request and the varying levels of risk in responding to such requests (for example, the risk of responding to fraudulent or malicious requests), we may request further information or your investor portal access credentials, if applicable, in order to verify your request.

You may designate an authorized agent to make a request under the CCPA on your behalf, provided that you provide a signed agreement verifying such authorized agent’s authority to make requests on your behalf, and we may verify such authorized person’s identity using the procedures above.

Please contact the Chief Compliance Officer at the email address above with any questions about this California Privacy Notice.

A&M CAPITAL EU AND UK PRIVACY NOTICE

This EU and UK Privacy Notice supplements the general [Privacy Notice] with respect to individuals located in the EU, the EEA, or the UK, to the extent that EU and UK data protection laws, including the General Data Protection Regulation (EU) 2016/679 (“GDPR”), the UK implementation of the GDPR, and the UK Data Protection Act 2018 (collectively, “EU and UK Privacy Laws”) applies to the personal data processing activities set out in the general Privacy Notice. Information that is required to be disclosed to individuals located in the EU, EEA or UK that is not set out in this EU and UK Privacy Notice is otherwise set out in the general Privacy Notice.

For the purposes of applicable EU and UK Privacy Laws, AMC and/or one or more of our affiliates will be a controller of any personal data collected by us. As a “controller” under applicable data protection laws, we are responsible for deciding how we collect and use personal data about you and for the information contained in this EU and UK Privacy Notice.

If you are a natural person in the EU or the UK and the EU and UK Privacy Laws apply to you, and have any questions about the EU and UK Privacy Notice, including any requests to exercise your legal rights, you may contact us at [email protected].

Personal Data We Process

Our general Privacy Notice sets out [The Data We Collect about You] . We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data, etc.).

Other Legal Bases

We rely on various legal bases under the EU and UK Privacy Laws in order to process your personal data, as we have set forth in the general Privacy Notice in the section [Why We Use Your Personal Data] . The section also sets out the specific purposes for which we use your personal data, which in general is to operate our business, conduct business with you and perform essential or legitimate business operations.

Transfers outside the EEA or UK

Your personal data may be transferred to, and stored at, a destination outside the EEA which may not always have data protection laws providing equivalent protection. To the extent your personal data is transferred to countries outside of the EEA, such transfers will only be made in accordance with applicable data privacy laws and we will take steps to ensure that your information is protected by appropriate organizational and security measures, and that any such transfers are done using specific legally-approved safeguards. For further information about the safeguards used and details of any relevant non-EEA countries, please contact [email protected].

Your Rights

Note that this section of the EU and UK Privacy Policy only applies to the extent that the EU and UK Privacy Laws apply to you. You have the right to access and control (in certain ways) the personal data we process about you. To exercise these rights and controls, please contact [email protected].YOUR RIGHTPURPOSEAccessYou have the right to ask for a copy of the personal data that we hold about you free of charge, however we may charge a ‘reasonable fee’, if we think that your request is excessive, to help us cover the costs of locating the information you have requested.CorrectionYou may notify us of changes to your personal data if it is inaccurate or it needs to be updated.DeletionIf you think that we shouldn’t be holding or processing your personal data any more, you may request that we delete it. Please note that this may not always be possible due to legal obligations.Restrictions on useIf you think that we shouldn’t be holding or processing your personal data any more, you may request that we delete it. Please note that this may not always be possible due to legal obligations.ObjectionYou have the right to object to processing, including: (i) for direct marketing; (ii) for research or statistical purposes; or (iii) where processing is based on legitimate interests.PortabilityIf you wish to transfer your personal data to another organisation (and certain conditions are satisfied), you may ask us to do so, and we will send it directly if we have the technical means.Withdrawal of consentIf you previously gave us your consent (by a clear affirmative action) to allow us to process your personal data for a particular purpose, but you no longer wish to consent to us doing so, you can contact us to let us know that you withdraw that consent.

We may need to request specific information from you to help us confirm your identity and ensure your right to exercise the above rights. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Complaints

Should you wish to lodge a complaint with regards to how your personal data has been processed by us, please contact your local supervisory authority. We would, however, appreciate the opportunity to deal with your concerns before you approach a relevant supervisory authority, so please contact us in the first instance.

In the UK, this is the Information Commissioner’s Office – https://ico.org.uk/global/contact-us.

In the EU, please contact your local supervisory authority in particular in the EU Member State of your habitual residence, place of work, or place of the infringement, concern or complaint.

Updates to this EU and UK Privacy Notice

This EU and UK Privacy Notice may be updated periodically to reflect changes in our personal data practices or as required by law. We reserve the right to amend this EU and UK Privacy Notice from time to time by updating this EU and UK Privacy Notice. Accordingly, users should review this EU and UK Privacy Notice regularly. If at any point we decide to collect personal data or use any collected personal data in a manner different from that stated at the time it was collected, we will notify applicable users by posting changes on this page.

Contact Us

If you have any questions or requests regarding this Notice or the personal data that we hold about you, or need additional information, please contact [email protected].

The following companies are your “controllers” and are responsible for the collection, use, disclosure, retention and protection of your personal data in accordance with our privacy standards as well as the EU and UK Privacy Laws:

A&M Capital Europe

6 Grosvenor Street
Mayfair, London W1K 4PZ

8 Rue Lou Hemmer, L-1748,
Senningerberg, Luxembourg

A&M Capital North America

1 Pickwick Plaza
3rd Floor
Greenwich, CT 06830

1201 Morningside Drive
Suite 200 – 2nd Floor
Manhattan Beach, CA 90266

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Please refer to our Cookie Policy for more information.