Privacy Policy

Our commitment to privacy

Polychain Capital Group and the PolychainCapital Funds recognize the importance of maintaining the privacy of personal information about our current and prospective customers.

As used in this privacy policy, personal information means information about an individual that is collected or maintained for business purposes and by which the individual can be identified. Please note that information by which an individual cannot be identified (for example, anonymous, de-identified, or aggregate information) is not considered personal information and therefore is not subject to this policy.

Please note that certain details of this policy may depend on whether you deal with us through an investment professional, directly as an individual investor, or whether PolychainCapital provides services to your employer or plan sponsor. In addition, some of PolychainCapital's products, services or digital offerings may have a different or additional privacy policy which may be made available to you if you choose to use those products, services or digital offerings.

This policy is reviewed annually and updated to reflect any changes.

Polychain Capital Group privacy policy

How and why we obtain and use personal information

PolychainCapital recognizes the importance of maintaining personal information about you and when we use it, we do so with respect for your privacy. We obtain and use personal information about you to service, maintain, and protect your account; process transactions in your account; respond to inquiries from you or your representative; develop, offer, and deliver products and services; operate and manage our business; and fulfill legal and regulatory requirements. PolychainCapital collects public and non-public personal information from customers and visitors from various sources. Some examples include:

• You or your representative on applications or forms (for example, when you interact with our customer service staff, and when you visit our websites or use our applications)
• You or your representative regarding your preferences (for example, your choice of electronic statement delivery, or the screen layout you specify if you use our websites)
• You or your employer or plan sponsor if PolychainCapital provides them with recordkeeping and/or employee benefits advisory services (for example, payroll, human resources, or benefits information)
• Transactional activity in your account (for example, trading history and balances)
• Other interactions with PolychainCapital (for example, discussions with our customer service staff, including telephone or chat, information you enter into our websites, or when you enroll in our authentication services)
• Information from consumer reporting agencies (for example, to assess your creditworthiness for margin products)
• Information from other third-party sources (for example, to verify your identity and to better understand your product and service needs)
• Other sources with your consent or with the consent of your representative (for example, from other institutions if you transfer positions into PolychainCapital)

How we protect information about you

We implement and maintain physical, administrative, technical and organizational measures designed to protect personal information and we regularly adapt these controls to respond to changing requirements and advances in technology.

At PolychainCapital, we restrict access to personal information to those who require it to develop, support, offer and deliver products and services to you and to operate our business.

How we share information about you with third parties

PolychainCapital does not share or sell personal information about our customers with unaffiliated third parties for use in marketing their products and services. We may share personal information with the following entities:

• Unaffiliated service providers (for example, printing and mailing companies, securities clearinghouses, marketing service providers, and other entities who may provide services at PolychainCapital's direction)
• Government agencies, other regulatory bodies and law enforcement officials (for example, for tax purposes or for reporting suspicious transactions)
• Other third-parties, with your consent or as directed by your representative (for example, if you request to transfer assets from another financial institution, or if you use an external aggregation website or service that you have provided permission to access your PolychainCapital financial account on your behalf)
• Other third parties whose products, services and investment offerings are made available through PolychainCapital, and which you decide to utilize
• Other organizations as permitted or required by law (for example for fraud prevention or to respond to a subpoena)
• In connection with corporate business transactions, such as a merger or sale of a business.

Our service providers are obligated to keep the personal information we share with them confidential and use it only to provide services specified by PolychainCapital.

In addition, if you choose to use or indicate your interest in using a product, service or investment offering that is offered by a third party and made available through PolychainCapital, we may share personal information with that third party in connection with your use or interest of that product, service or investment offering.

Based on the nature of your relationship with PolychainCapital, we may exchange information with other third parties as described below:

• If PolychainCapital provides workplace services to your employer or plan sponsor, such as payroll, human resources or employee benefits advisory and/or recordkeeping services, PolychainCapital may exchange any information received in connection with such services with your employer or plan sponsor or others they may authorize.
• If you conduct business with PolychainCapital through your investment professional, we may exchange information we collect with your investment professional or with others they may authorize.
• If you transact business through PolychainCapital's life insurance companies, we may validate and obtain information about you from an insurance support organization. The insurance support organization may further share your information with other insurers, as permitted by law. We may also share medical information about you to learn if you qualify for coverage, to process claims, to prevent fraud, or otherwise at your direction, as permitted by law.

How we provide information about you with our affiliates

We may provide personal information about you to various PolychainCapital corporate affiliates including internal service providers which perform, for example, printing, mailing, and data processing services.

If you interact with PolychainCapital directly as an individual investor (including joint account holders), we may provide certain information about you to PolychainCapital affiliates, such as our brokerage and insurance companies, for their use in marketing products and services as allowed by law.

Where PolychainCapital provides services to you under an arrangement with your employer or plan sponsor, to the extent permitted by you or under our agreement with your employer or plan sponsor and as allowed by law, we may provide information about you to PolychainCapital's affiliates, such as our brokerage and insurance companies, for their use in marketing products and services.

Information collected from investment professionals' customers is not provided to PolychainCapital affiliates for marketing purposes, except with your or your representatives' consent and as allowed by law.

Your digital privacy

When you interact with us by using our websites, online services or applications (including mobile apps) that are owned and controlled by Polychain Capital Group ("our digital offerings"), or via electronic communications, PolychainCapital manages personal information in accordance with all of the practices and safeguards described in this policy.

When you use or interact with us via our digital offerings, or interact with us via electronic communications, we (or our service providers on our behalf) may automatically collect technical and navigational and location information, such as device type, browser type, Internet protocol address, pages visited, and average time spent on our digital offerings. We use this information for a variety of purposes, such as maintaining the security of your session, facilitating site navigation, improving the design and functionality of our digital offerings and electronic communications, and personalizing your experience. Additionally, the following policies and practices apply when you are online.

Cookies and similar technologies

PolychainCapital and our third-party service providers may use cookies and similar technologies ("cookies") to support the operation of and maintain our digital offerings. Cookies are small amounts of data that a website or online service exchanges with a web browser or application on a visitor's device (for example, computer, tablet, or mobile phone). Cookies help us to collect information about users of our digital offerings, including date and time of visits, pages viewed, amount of time spent using our digital offerings, or general information about the device used to access our digital offerings. PolychainCapital cookies are also used for security purposes and to personalize your experience, such as customizing your screen layout.

Both PolychainCapital and third-party service providers we hire may use cookies and other technologies, such as web beacons, pixel tags, or mobile device ID, in online advertising as described below. Most browsers and mobile devices offer their own settings to manage cookies. If you use those settings to refuse or delete cookies it may negatively impact your experience using our digital offerings, as some features and services on our digital offerings may not work properly. For example, you may not be able to sign in and access your account, or we may not be able to recognize you, your device, or your online preferences. Depending on your device and operating system, you may not be able to delete or block all cookies.

We may collect analytics data or use third-party analytics tools such as Google Analytics to help us measure traffic and usage trends for our digital offerings and to understand more about the demographics of our users. You can learn more about Google's practices with Google Analytics by visiting Google's privacy policy. You can also view Google's currently available opt-out options.

Advertising on PolychainCapital Digital Offerings

PolychainCapital advertises on its own digital offerings (including our mobile applications), and when we do, we may use information about your relationship with us, such as the types of accounts you have, to tailor advertisements and communications about PolychainCapital and third-party products and services that may be of interest to you.

We may also use third-party service providers to help us determine which PolychainCapital products and services may be of interest to you. These service providers may use cookies and other technologies to collect for us information about your activity on PolychainCapital digital offerings. We and our service providers use such information to analyze the effectiveness of our advertising and the usage of our digital offerings. For example, we may analyze the browsing patterns while visiting a PolychainCapital website and responses to advertisements and promotions shown on our digital offerings. Such service providers may only collect and use such information for purposes specified by PolychainCapital and not for their own purposes.

Advertising on Non-PolychainCapital Digital Offerings

PolychainCapital also advertises our products and services on digital offerings not affiliated with PolychainCapital and we contract with third-party advertising companies to display these ads. These third-party advertising companies may use cookies and similar technologies to collect technical and web navigational information, such as device type, browser type, Internet protocol address, and pages visited.

PolychainCapital and these third-party online advertising companies may use the data collected, along with other information we have about you and your PolychainCapital relationships, to serve relevant ads to you. The advertisements may be relevant to your interests, as determined by your activity on PolychainCapital and non-PolychainCapital websites. These advertisements are known as "interest-based advertisements".

You may opt-out of receiving interest-based advertisements from online advertising companies, including those used by PolychainCapital, by clicking on the AdChoices icon and following the opt-out instructions.

Connecting with PolychainCapital on social media platforms

PolychainCapital provides experiences on social media platforms that enable online sharing and collaboration among users who have registered to use them. We may collect information you provide by interacting with us via social media, such as photographs, opinions, or social media account ID. Any content you post, such as pictures, information, opinions, or any personal information that you make available to other participants on these social platforms, is also subject to the terms of use and privacy policies of those platforms. Please refer to them to better understand your rights and obligations with regard to such content.

Third Party websites, online service, and content

Our digital offerings may contain links to third party websites and online services (for example, social media platforms) and may include embedded content that is hosted by third parties. This policy does not address the privacy, security, cookie policy and settings, or other practices of the third parties that provide such websites, online services, or content, and we are not responsible for the privacy practices or the content of these other websites, online services, or content providers. If you use a link to another website or online service or view third party content (for example, an embedded video), please consult the privacy policy for that website/or online service for additional information on their privacy practices and advertising opt-out instructions.

Children's privacy

In general, PolychainCapital's digital offerings are not directed to individuals under the age of thirteen (13). PolychainCapital does not intentionally collect information on PolychainCapital websites from those we know are under 13, and we request that these individuals do not provide personal information through our digital offerings. If we do provide a digital offering that is intended to be used by individuals under the age of thirteen, it will have a separate privacy policy.

Additional information

If you are a former customer, these policies also apply to you; we treat your information with the same care as we do information about current customers.

PolychainCapital offers several options for accessing and, if necessary, correcting your account information. You can review your information using your statements, or through our automated telephone or our digital offerings. You may also write or call us with your request for information. If you transact business through PolychainCapital's life insurance companies, you are entitled to receive, upon written request, a record of any disclosures of your medical record information. If we serve you through an investment professional, please contact them directly. Specific Internet addresses, mailing addresses and telephone numbers are listed on your statements and other correspondence.

PolychainCapital Funds Privacy Policy

Protecting your personal information is an important priority for the PolychainCapital Funds. The Funds' privacy policy is designed to support this objective. The Funds collect non-public personal information concerning you in the following ways:

• Information provided by you or your representative on applications or other forms furnished to the Funds or through other interactions that you or your representative have with the Funds
• Information arising from your investments in or accounts with the Funds
• Information the Funds receive from a consumer reporting agency

The Funds do not disclose any non-public personal information about you, except as permitted by law. For example, the Funds have entered into a number of arrangements with Polychain Capital Group to provide for investment management, distribution and servicing of the Funds.

If you decide to close your account, the Funds will continue to adhere to the privacy policies and practices as described in this policy.

Please read the PolychainCapital Funds Privacy Policy in conjunction with the Privacy Policy for the Polychain Capital Group companies of which you are also a customer.

The Funds employ physical, electronic, and procedural controls to safeguard your information. For example, the Funds authorize access to your personal and account information only for personnel who need that information in order to provide products or services to you.

The PolychainCapital Funds Privacy Policy is provided on behalf of the Polychain Capital Group family of mutual funds, including those advised by Strategic Advisers LLC.