Your privacy is important to Whistler Capital Partners LLC and its affiliates (“Whistler Capital” or the “Firm”). We are committed to protecting your privacy when you provide Personally Identifiable Information (“PII”) to us. Our privacy statement explains our personal information policies and practices including the types of PII we may collect about you, the purposes for collecting your PII, the circumstances where we may disclose the information to third parties, the measures we take to secure the confidentiality of your PII, and the information you will need to contact us to address your privacy concerns including the exercise of your rights.

Collection and use of your personal information

We may collect PII from you when you visit Whistler Capital’s website to browse, conduct transactions with, or otherwise interact with us, both on and offline. In addition, as part of our obligation to comply with all applicable laws and regulations, we may indirectly collect PII from you by monitoring email and other network traffic.

PII is any information that can be used to identify an individual. The PII we may collect from you includes but is not limited to, name, email, address, phone number, age, occupation, login information, marketing preferences, national identity cards, social security numbers, and drivers licenses where required by law, and any other information that can be used to identify you.

Collection of PII from third parties: From time to time we receive personally identifiable information from third parties who help us market or service our financial products.

Lawful basis of collection and use of your PII: Our collection and use of your PII is lawful. We may process your PII as required to support our legitimate business interests and your interests and rights do not override those interests.

Consequences of not providing your personal information: In order to provide you with relevant information about our financial services and products, we will need to collect some personal information to contact you. Without some of your personal information we cannot provide you with the services you may request. If you are currently receiving information or marketing communications from us, you may opt-out of receiving further communications at any time.

Uses of personal information: We collect your personal information for a variety of purposes including:

• Processing your transactions;

• Maintaining your accounts and investments;

• Managing employment applications;

• Contacting you or your designated representative by phone, email, fax, or post;

• Sharing information about our services, including investment research;

• Providing you or your representative with marketing communications;

• Facilitating financial transactions; and

• Fulfilling our legal and regulatory obligations.

When and how we share personal information

We may share your personal information within Whistler Capital and with our affiliates, business partners, and third parties for the purposes of operating our business and delivering and improving the financial services we provide to you. We may also share your personal information for other legitimate purposes permitted by applicable law including sending marketing and other communications related to our business.

We share personal information for a variety of purposes including, but not limited to, the following ways:

• Within Whistler Capital and among our affiliates and subsidiaries for data processing or storage purposes;

• With business partners and suppliers to provide services and help facilitate transactions;

• In response to requests from or obligations relating to law enforcement, government authorities, or other third parties as necessary to comply with legal process or meet national security requirements; and

• For other purposes after we have provided you notice and received your consent to share information for that purpose.

Whistler Capital does not sell your data to any third parties.

Data Subject Rights

The European Union’s General Data Protection Regulations (GDPR) and other national privacy laws provide data subjects with certain rights. This privacy statement is intended to inform you of your rights with respect to your personal data and to provide you with the information necessary to exercise those rights.

Individuals who reside in the EU and whose personal data is collected and processed by Whistler Capital have the right to the following:

• To request access to your data

• To rectify your data

• To take your data (portability) to another service provider

• To erase your personal data

• To restrict or object to the processing of your personal data

• To lodge a complaint with a Member State Supervisory Authority