PRIVACY POLICY

Legal Information

Last updated on April 2026

General
GI Manager L.P. together with its affiliated funds, separate accounts, and management entities (“GI Partners” or “we”) are committed to protecting the privacy of visitors to our website (the “Site”). This Privacy Policy seeks to help you understand whether and how we collect information about you when you visit the Site and how we use such information. This Privacy Policy does not address our privacy practices concerning any personal information we collect as to our investors; we address those practices in separate notices sent to our investors or potential investors. You may have additional rights under other U.S. state laws that apply to you, including as set forth in our California Privacy Policy.

This Privacy Policy applies when you visit the Site. By using the Site, you accept this Privacy Policy, which may be updated by us at any time. If you do not agree to this Privacy Policy for any reason, please do not use the Site or share your personally identifiable information with us as discussed below.

Please note that this Privacy Policy applies only to the Site and not to any other website that may be linked to it. We do not control the privacy policies or practices of others. We encourage you to ask questions and read the privacy policies of other websites before you disclose any personal information to them. If you have any questions or comments about this Privacy Policy, you can write to us at Privacy Matters, GI Partners, 188 The Embarcadero, Suite 700, San Francisco, CA 94105.

How We Collect, Use, Share, and Protect Your Information

Site Visits: In general, we automatically gather certain information from the Site visitors, such as the number and frequency of your visits, through server logs. This information may include the URL of the last and next website you visit, your browser and operating system, your IP address, how long you spend on the Site, and what pages you view there. We may use this information on an aggregate basis to improve the Site, provide visitors with customized services and information, and for other similar purposes. We may also use this information to understand better how our visitors use the Site and to research our visitors’ demographics, interests, and behavior.

We do not collect any personally identifiable information from you through the Site except as described above. Personally identifiable information is information that personally identifies you, such as your name, postal address, e-mail address, or credit card information (or other information that is associated by us with such above information).

Please be advised that the virtual data room portals that can be accessed through links on the Site by investors in funds managed by GI Partners are maintained by third-party service providers, whose privacy policies apply to those portals and to the personal information you provide in activating and using your account to access those portals; the third party service providers only inform us of who has access to the portals they operate. We encourage you to review those privacy policies.

Further, we do not control any cookies, web beacons, or other similar devices that may be placed on the Site by third parties.

Other: We will collect any other personally identifiable information from you if you voluntarily provide it through the Site – such as by providing your e-mail address and other personal information to receive further information about us – and will use such personally identifiable information for the purpose of processing and responding to your inquiries and requests and to improve the Site and offerings.

We will use your personal information for one or more of the following business or commercial purposes:

To perform services for you, including but not limited to the administrative processes (and related communication) in connection with an investment
To provide, administer, support, monitor, personalize, develop and improve our Site and the products and services that we offer and notify you about changes to our products and services
To provide you with support and to communicate with you, including processing and responding to requests for information submitted by you through our Site
Maintaining a record of your enquires, requests and Site visit
To keep a record of your relationship with us
To conduct ongoing operations, administrative, accounting, reporting, account maintenance and other processes
To audit and verify the quality and effectiveness of our services and compliance
To maintain the safety, security and integrity of our Site, products and services, databases, technology assets and business, including to detect security incidents and to protect against malicious, deceptive, fraudulent, or illegal activity
As needed to comply with U.S., state, local and non-U.S. laws, rules and regulations, including responding to law enforcement requests and as required by applicable law, court order or government regulations

To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Site users is among the assets transferred

We may also use your personal information collected via your Site visits on an aggregate basis to improve the Site provide visitors with customized services and information, and for other similar and compatible purposes. We may also use this information to understand better how our visitors use the Site and to research our visitors’ demographics, interests, and behavior.

Disclosure of Information

We may use service providers to facilitate our services and perform functions on our behalf, such as sending postal mail and e-mail and providing technical, analytical, and hosting functions for the Site. These companies and individuals may have access to your personally identifiable information we collect through the Site, as permitted by law and as needed to perform their functions, but may not use it for any other purpose. We require that these companies and individuals otherwise keep this information confidential.

If GI Partners merges with or transfers substantially all of its assets to another entity, GI Partners has the right to share your personally identifiable information with that entity, to the extent lawfully permissible.

We will not otherwise share your personal information, except as required by law, requested by governmental entity or law enforcement authority, subpoena, court order or discovery request, or when we otherwise believe in good faith that such disclosure is necessary or appropriate in connection with any activity that violates the law (including relating to intellectual property, fraud, contracts, and privacy) or may expose us to liability. We can (and you authorize us to) disclose any of your information in such circumstances.

Information Security

The security of your information is important to us. We employ several different technical, administrative, and physical security measures to protect any personal information you provide through the Site from unauthorized access or use. You should be aware, however, that “perfect security” does not exist on the Internet, and there is always the risk that unauthorized persons may access or use your personal information. You use the Site and send us such information at your own risk.

Privacy Policy Changes

We may revise or supplement this Privacy Policy from time to time and such changes will be posted on this page.

International Use

GI Partners makes no claims that the Site is appropriate or lawful for use or access outside the United States. Access to the Site from countries or territories where such access is illegal is prohibited. If you access the Site from outside the United States, you do so at your own risk. You are solely responsible for complying with all local laws, rules, and regulations regarding online conduct and access to the Site. Furthermore, our databases are located in the United States. By sending us your data, you consent to its transfer to and storage within the United States.

CALIFORNIA WEBSITE PRIVACY POLICY

This California Website Privacy Policy supplements the Privacy Policy 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 supplement 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 CCPA supplement is otherwise set forth in the Privacy Policy. 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 does this California Privacy Policy apply to?

This California Privacy Policy applies solely to your interactions with us through the Site (as defined in the Privacy Policy). If you provide personal information to us through another means (e.g., as an investor or an employee seeking employment) you will receive a separate privacy notice and that notice will govern that personal information.

Please note that this Privacy Policy applies only to the Site and not to any other website that may be linked to it.

What Categories of Information Do We Collect About You?

We collect limited types of personal information through our website and investor reporting portals, as well as through other electronic communications (e.g., emails), as applicable (collectively, the “Website”). The types of personal information we collect about you depends on the nature of your interaction with us. The categories of personal information we have collected from individuals on this Website over the last twelve (12) months include the following:

Category	Examples	Collected
A. Identifiers	Name, 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).	YES
B. 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).	NO
C. Protected classification characteristics under California or federal law	Date of birth, citizenship and birthplace.	NO
D. Commercial information	Account 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).	NO
E. Biometric information	Imagery 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.	NO
F. Internet or other similar network activity	Use 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.	YES
G. Geolocation data	Physical location or movements.	NO

We do not knowingly collect or solicit personal information from anyone under the age of 18.

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;
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);
To perform services on behalf of our business;
To verify or maintain the quality or safety of a service or to improve, upgrade, or enhance such service or device; and
To collect or process sensitive personal information where such collection or processing is not for the purpose of inferring characteristics about a consumer.

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. At this time, we do not currently respond to DNT Signals.

We collect personal information for the business or commercial purposes and from the sources set forth in “How We Collect, Use, Share, and Protect Your Information” in the Privacy Policy above. We retain the categories of personal information set forth above in “What Categories of Information Do We Collect About You?” section of this California Website Privacy Policy only as long as is reasonably necessary for those purposes set forth in “How We Collect, Use, Share, and Protect Your Information” in the Privacy Policy above, except as may be required under applicable law, court order or government regulations.

Who Do We Disclose Your Personal Information To?

We do not share (i.e., disclose to a third party for the purpose of cross-context behavioral advertising) or sell (as such terms are defined in the CCPA) any of the personal information we collect about you to third parties.

Within the last twelve (12) months, we have disclosed personal information collected in connection with this Website for a business purpose to the categories of third parties indicated in the chart below. We may also disclose your information to other parties as may be required by law or regulation, or in response to regulatory inquiries.

Personal Information Category	Category of Third-Party Recipients
A. Identifiers	Administrators.
C. Internet or other similar network activity	Administrators.

We take measures to protect your personal information as set forth in “Information Security” in the Privacy Policy above.

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 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.

Disclosure and Access Rights: You have the right to request that we disclose to you certain information regarding our collection, use, disclosure and sale 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 with 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 so, the categories of personal information that each recipient obtained.

Correction Right: You have the right to request that we correct any inaccuracies in the personal information 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: If you would like to contact us by telephone without incurring telephone charges, please submit your request and telephone number either (1) through the online form below or (2) by email at the email address below, and we will call you between 9 a.m. and 6 p.m. Pacific Time.

Submit a request online using the following online form: Contact Us.

Email us at the following email address: legal@gipartners.com

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. If we request you verify your request and we do not receive your response, we will pause processing your request until such verification is received.

Please contact legal@gipartners.com with any questions about this California Privacy Policy.