Privacy and Disclaimer

Last Updated: March 2, 2026

We at Blue Wolf Capital Partners LLC and our subsidiaries (collectively “Blue Wolf,” “we,” “us,” or “our”) would like to thank you for your interest and welcome you to our websites. We are committed to protecting your privacy. This Privacy Policy (“Policy”) helps you understand how we collect, use, secure, and disclose your personal information collected by us. This Policy applies when you (“Visitor”) visit our website located at https://www.bluewolfcapital.com/; when you (“Investor”) use our investor portal located at https://bluewolfcapital.investorflow.com/, or any other websites, pages, or features we own or operate (collectively, the “Site(s)”). To the extent that you are an Investor and have obtained financial products or services from us, please refer to the notice we provided to you via our investor portal about how we collect, use and disclose personal information of current, former and prospective investors. If you provide personal information to us through another means (e.g., as an employee or seeking employment) you will receive a separate privacy notice and that notice will govern our use of that personal information. For the purposes of this Policy, we refer to “personal data”, “personal information” and “personally identifiable information” interchangeably to mean any information which, directly or indirectly, identifies or is capable of identifying any natural person.

Please read this Policy carefully. In particular, please note that this Policy is supplemented by the Additional Notice to Individuals in the European Economic Area, the United Kingdom and Switzerland (the “EEA-UK-Swiss Privacy Notice”) and the California Website Privacy Policy (the “California Website Privacy Policy”) (each, a “Jurisdiction-Specific Notice”) if andto the extent that European Data Protection Legislation or CCPA (each as defined in the relevant Jurisdiction-Specific Notice below) apply to our processing of your personal information.

By using our Sites, to the extent permitted by laws in your country or state of residence, you agree to the collection, use, and disclosure of your personal information as described in this Policy (or, for a Visitor from the European Economic Area, the United Kingdom or Switzerland, you acknowledge that you have read and understood this Policy), and you agree to the Terms and Conditions (“Terms”), which governs all use of our Sites, and, together with the Policy, constitute your agreement with us. If you do not agree with or are not comfortable with any part of this Policy, please immediately discontinue accessing or using our Sites.

We may change this Policy from time to time (which includes the EEA-UK-Swiss Privacy Notice and the California Website Privacy Policy) for any reason, in our sole discretion, and we will notify you by revising the “Last Updated” date at the top of this Policy and posting an updated draft of this Policy to our Sites. All changes to this Policy (which includes the EEA-UK-Swiss Privacy Notice and the California Website Privacy Policy) are effective upon posting. Accordingly, Visitors are strongly encouraged to review this Policy regularly. If we change this Policy in a way that we believe materially affects how we process your personal information, we will provide you with advance notice such as via email or by posting a notice on our Sites. We will use your personal information only in accordance with the Policy under which the information was collected. Unless otherwise required by laws in your country or state of residence, your continued access or use of our services after receiving the notice of changes constitutes your acknowledgment that you accept the updated Policy.

If you have any questions about this Policy, or have a privacy-related complaint, please contact us by email at info@bluewolfcapital.com, by phone at (212) 488-1340 or by writing us at 3 World Trade Center, 175 Greenwich Street, 65th Floor, New York, NY 10007.

1. Personal Information We Collect

We may collect the following categories of personal information that you voluntarily provide while using our Sites:

Account Information. When you use our investor portal, we may collect your account information, such as your account’s username and password.

Transaction Information. When you carry out transactions through our Sites, we may collect transactional information such as financial account number.

Client Support Information. When you choose to get in touch with us via email or phone, we may collect your first and last name, email address, copies of your correspondence, and additional information you choose to disclose to us.

Other Information. We may collect any other information that you voluntarily send to us.

To the extent permitted under applicable law, and to improve the performance of our Sites, we may collect the following types of personal information automatically from you:

Log Data and Usage Information. When you browse our Sites, we may collect personal information about you through automated technology such as your web request, information about your computer / device and Internet Protocol (“IP”) address, browser type, domain names, referring and exit pages and URLs, pages viewed and the order of these page views, the date and time you access our servers, and other diagnostic data (please see Section 2 below for information about how we use such technologies).

We may combine personal information that you provide to us with information that we collect from or about you from third parties and publicly available sources. This will include information collected in an online or offline context.

2. Cookies and Similar Tracking Technologies

We, and third parties on our behalf may employ various tracking technologies, such as cookies and other similar technologies (collectively, “Tracking Technologies”) to collect personal information automatically as you interact with our Sites, to help us customize your experience and better manage content on our Sites, including to:

Identify whether you already visited our Sit
Analyze our web traffic using an analytics package
Store information about your preferences
To recognize when you return to our Sites

Cookies are small text files that a website can use to recognize a repeat visitor to the Site. The following types of cookies are used on our Sites:

Strictly Necessary Cookies. These cookies are essential because they enable you to use our Sites as you reasonably expect. Without these cookies, some Site features cannot function. This category of cookies is essential for our Site to work and so they cannot be disabled.
Functional Cookies. We use functional cookies to remember your choices so that we may tailor our Sites to provide you with enhanced features and personalized content. While these cookies can be disabled, this may result in less functionality during your use of our Site.
Analytics Cookies. These cookies allow us to collect passive information about your use of our Sites, for example, count page visits and traffic sources to measure and improve our Sites’ performance.
Advertising Cookies. These cookies may be set through our website by our advertising partners. Data may be collected by these companies that enable them to serve up advertisements on other sites that are relevant to your interests.

You have the right to decide whether to accept cookies. If you do not want Blue Wolf to deploy cookies in your browser, you may exercise your preference by modifying your web browser setting to either refuse some or all cookies, or notify you and ask for your permission when a website tries to set a cookie. If you want to learn the correct way to modify your browser settings, please use the “Help,” “Tools,” or “Edit” menu in your browser or review the instructions provided by your local browse. If you choose to disable cookies in your browser, you can still use our Sites, although your ability to use some of the features may be affected.

Our Sites and our third-party technology providers use third-party analytics services (such as Google Analytics) to evaluate your use of the Sites, compile reports on activity, collect demographic data, analyze performance metrics, and collect and evaluate other information relating to the Sites and Internet usage. For more information on how to opt-out of Google Analytics’ tracking, please click here.

Subject to your consent for non-essential cookies, our Sites use the cookies listed below:

Cookie	Name	Type / Purpose	Duration
Google Analytics	_ga	Analytics cookie – This cookie is used to evaluate your use of the Sites, compile reports on activity, collect demographic data, analyze performance metrics, and collect and evaluate other information relating to the Sites and Internet usage.	We use Google Analytics, a web analytics service provided by Google, Inc. Google Analytics uses cookies to help us analyze how users use the website and enhance your experience when you use the website. For more information on how Google uses this information, click here. To opt out of being tracked by Google Analytics across all websites, visit https://tools.google.com/dlpage/gaoptout.
Google Analytics	_ga_R3H816V7B7	Analytics cookie – This cookie is used to evaluate your use of the Sites, compile reports on activity, collect demographic data, analyze performance metrics, and collect and evaluate other information relating to the Sites and Internet usage.	We use Google Analytics, a web analytics service provided by Google, Inc. Google Analytics uses cookies to help us analyze how users use the website and enhance your experience when you use the website. For more information on how Google uses this information, click here. To opt out of being tracked by Google Analytics across all websites, visit https://tools.google.com/dlpage/gaoptout.

Interest-Based Advertising. Many advertising companies that collect information for interest-based advertising are members of the Digital Advertising Alliance (“DAA”) or the Network Advertising Initiative (“NAI”), both of which maintain websites where people can opt out of interest-based advertising from their members. To opt-out of website interest-based advertising provided by each organization’s respective participating companies, visit the DAA’s opt-out portal available at https://optout.aboutads.info/, or visit the NAI’s opt-out portal available at https://thenai.org/how-to-opt-out/ If you reside in the European Economic Area, the United Kingdom, and Switzerland (collectively, the “European Countries”), you may opt out of online behavioral advertising served by the European Interactive Digital Advertising Alliance’s participating member organizations by visiting https://youronlinechoices.eu/.

3. How We Obtain Your Personal Information

We may collect and maintain your personal information from the following sources:

Information captured on our Sites or our other digital platforms, including registration and account information, information provided through online forms and the “Contact Us” page.
Information provided by you in person or through communications with us, such as information obtained through written correspondence, including when you provide it to us in online or offline correspondence via physical mail, email, telephone calls (which may be recorded for regulatory purposes), video communications and other verbal communications.
Information provided by third parties or publicly available sources, such as a resume or CV sent to us by a recruiting firm, background information from a background check provider, personal information we viewed on social media (e.g., LinkedIn) or information obtained from publicly available lists of individuals subject to sanctions or trade restrictions, including government registers. If you choose to register or login to our Sites using a third party single sign−in service that authenticates your identity and/or connects your social media login information (e.g., LinkedIn, Google, or Vimeo), we will collect any information or content needed for the registration or log−in that you have permitted the social media provider to disclose to us, such as your name and email address. If you represent one of our vendors, business partners or portfolio companies, we may also collect your personal information from the entity that you work for where this is necessary to receive products or services from, or otherwise conduct business with, such third party.
Information such as your IP address and other online identifiers that are collected through automated technology when you access and use our Sites, such as cookies and similar technology.
Information provided in the context of the companies we are evaluating in connection with a corporate transaction or investment (which in addition to your basic information and contact information may include information such as government-issued identification, financial information, information about your employment (including benefits information)).

4. How We Use Your Personal Information

Our primary purpose for collecting personal information is to provide you with a secure and smooth experience on our Sites. We may use your personal information in the following ways:

To Provide You With Our Sites. We may use your information to complete the transactions you request, to perform our contractual obligations with you, to provide you with requested information or materials, or to ensure that our services function properly.
To Maintain Legal and Regulatory Compliance. Our business is subject to certain laws and regulations which may require us to process your personal information. Without processing your personal information for such purposes, we cannot provide our services in accordance with our legal and regulatory requirements.
To Enforce Compliance with Our Terms, Agreements, and Policies. When you access our Sites, you are bound to our Terms. To ensure you comply with them, we may process your personal information by actively monitoring, investigating, preventing, and mitigating any alleged or actual prohibited, illicit or illegal activities on our Sites. Subject to the applicable law, we may also process your personal information to investigate, prevent or mitigate violations of our agreements and internal policies, or enforce our agreements with third parties and business partners.
To Detect and Prevent Fraud and Security Risks. We may process your personal information to help monitor, prevent and detect fraud activities in our Sites, monitor and verify your identity so that unauthorized users do not gain access to your accounts, enhance system security, and combat spam, malware, malicious activities or other security risks that might result in financial loss.
To Provide Support or Respond to You. We collect any information that you provide to us when you contact us. Without your personal information, we cannot respond to you or ensure your continued use and enjoyment of our services.
To Provide You with Service-Related Communications. We may send you administrative or account-related information to keep you updated about your account and our services. Such communications may include information about Policy updates, confirmations of your account actions or transactions, security updates, or other relevant transaction-related information. Service-related communications are not promotional in nature. You are not able to unsubscribe from such communications, otherwise, you may miss important developments relating to your account or our services.
To Research and Develop of Our Sites. We may process your personal information and derive analytical and statistical data to better understand the way you interact with our Sites to help us maintain, improve and develop our Sites. Please see our Cookies and Other Similar Tracking Technologies section for more information.
To Personalize Your Experience. We may process your information to personalize your experience. By personalization, we enable you to more easily interact with our Sites. Please see our Cookies and Other Similar Tracking Technologies section for more information.
To Facilitate Corporate Acquisitions, Mergers, and Transactions. We may process information regarding your account and your use of our Sites as is necessary in the context of corporate acquisitions, mergers, or other corporate transactions.
With Your Consent. We may process your information for any other purpose to which you consent.

Note that we may process your personal information on more than one legal basis depending on the specific purpose for which we are using your personal information.

We will only use your personal information for the purposes for which we 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 information for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so.

5. How We Disclose Your Personal Information

We may disclose your personal information listed above to third parties and service providers when necessary for business purposes. The categories of third parties to whom we may disclose your personal information include:

As Required by Law. We may access, preserve, and disclose information about you if we believe doing so is required or appropriate to (a) comply with law enforcement requests and legal processes, such as a court order or subpoena; (b) comply with requests from auditors, examiners or other regulators; (c) respond to your requests; or (d) protect your, our, our clients’ and investors’, or others’ rights, property or safety.
Our Affiliates and Subsidiaries. We may disclose your personal information to and among Blue Wolf subsidiaries and affiliates for management, analysis, client, and investor support.
Our Service Providers. We may disclose your personal information to service providers performing necessary business functions for us, such as secure website hosting, information technology maintenance, and analytics.
Authorized Third Parties. We may disclose your information to third parties that you authorize us to disclose personal information in connection with the services we (or they) provide you.
During Business Transactions or Other Asset Transfers. We may disclose and transfer information about you to buyers, service providers, advisors, potential transactional partners or other third parties in connection with the advisors, potential transactional partners or other third parties of a corporate transaction in which we or any of our affiliated entities are acquired by or merged with another company, or we sell, liquidate, or transfer all or a portion of our business or assets. By engaging with us or using our services, you understand and agree to our assignment or transfer of rights to your personal information. In the event of any such change in ownership or control of your personal information, we will notify you of such changes to the extent required under applicable law.
With Your Consent. We may disclose your personal information for any purpose with your consent.

We make sure anyone who provides a service to, or for us, enters into an agreement with us and meets our standards for data security.

Please also refer to EEA-UK-Swiss Privacy Notice or California Website Privacy Policy for further information about disclosure and transfers of personal data.

6. How We Protect Your Personal Information

We maintain appropriate technical and organisational measures, including physical, electronic, and procedural safeguards to guard and prevent misuse of your personal information.

We restrict access to personal information about Visitors to those employees, agents, contractors and other third parties who need to know that information to provide services in connection with the Sites. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. We cannot guarantee the security of our databases or the databases of the third parties with which we may disclose such information, nor can we guarantee that the information you supply will not be intercepted while being transmitted over the Internet. In particular, email sent to us may not be secure, and you should therefore take special care in deciding what information you send to us via email. If you have any questions about the security of your interaction with us (if, for example, you feel that the security of any account you might have with us has been compromised), please reach out immediately via the method listed in the “Contact Us” section below.

7. Retention of Your Personal Information

We will retain your personal information only for as long as is necessary for the purposes set out in this Policy, or to the extent necessary or permitted to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies. We will cease to retain your personal information or remove the means by which the data can be associated with you as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal information was collected and is no longer necessary for legal or business purposes. We will not keep more information than we need for those purposes. For further information about how long we will keep your personal information, please contact us using the contact details provided in the “Contact Us” section below.

8. Access To Other Websites From Our Sites

During your visit to our Sites, you may have the opportunity to link to other websites. Please be aware that we do not have any access, control, input, or authorization over any of the materials or content contained on these websites. Additionally, we are not liable or responsible for the privacy practices, content, or policies of any of these other websites.

9. Marketing

We may send you direct marketing communications where permitted by applicable laws, to keep you informed of our products and services in which you might be interested either where we have obtained your prior consent or based on our legitimate business interests where we have an existing relationship with you and we wish to contact you about similar products or services in which you may be interested. You may opt-in to certain kinds of marketing, and all forms of marketing at any time, by contacting us using the methods described in the “Contact Us” section below or you may unsubscribe to receiving emails by clicking on the “opt-out” or “unsubscribe” link provided in all our marketing emails.

10. How We Handle Children’s Information

Our Sites are not directed to, and we do not knowingly collect personal information from, children under the age of 18 (or other age as required by local law). If you are under 18, please do not send any personal information about yourself to us. If we become aware that a child under 18 (or other age as required by local law) has provided us with personal information contrary to our instruction, we will take steps to delete such information from our filesystems, unless we have a legal obligation to keep it.

11. International Transfers

When you access our Sites or submit information to us, your personal information may be transferred to, processed, maintained, and used on computers, servers and systems located where the data protection laws may not be as protective as those in your jurisdiction. If you are located outside the United States and choose to provide information to us, please note that we may transfer your personal information to the United States for further processing. We will take appropriate contractual or other steps to protect the relevant personal information in accordance with applicable laws.

Please also refer to EEA-UK-Swiss Privacy Notice or California Website Privacy Policy for further information about international transfers of your personal information.

12. Your Privacy Rights

Depending on applicable law where you reside or are located, you may be able to assert certain rights identified below with respect to your personal information. If any of the rights listed below are not provided to you under the law that governs the processing of your personal information, we have absolute discretion in providing you with those rights. Please refer to the “What Rights Apply” section to determine the rights applicable to you.

Please note, your rights in relation to your personal information are not absolute. Depending on the applicable law, access to your rights under the applicable law may be denied: (a) where denial of access is required or authorized by law; (b) when granting access would have a negative impact on other’s privacy; (c) to protect our rights and properties; or (d) where the request is frivolous or unrealistic. If you would like to exercise your rights under applicable laws, please contact us at info@bluewolfcapital.com. In your request, please make clear which right you would like to exercise. Upon receiving your rights request. we may seek to verify your identity to ensure the security of your personal information.

Right to know/access. You may have the right to obtain a copy of the personal information that we hold about you, as well as other supplementary information, such as the purposes of processing, and the entities to whom we disclose your personal information.
Right to correct/rectification. You may have the right to correct any of your personal information in our files if it is inaccurate or needs to be updated.
Right to delete/erasure. Under certain circumstances, you may have the right to the erasure of the personal information that we hold about you. This right is not absolute, and we may refuse your right to erasure if it is reasonably necessary for us to provide a service requested by you; to perform a contract between us; to maintain functionality and ensure security of our systems; to enable solely expected internal uses of your personal information; to exercise a right provided by law; to comply with a legal obligation; or if there are compelling legitimate grounds for keeping your personal information.
Right to restrict processing. You have the right to request that we restrict our processing of your personal information in certain circumstances. For instance, this right may be available if you contest the accuracy of the personal information.
Right to object to processing. You may have the right to object to our processing of your personal information at any time and as permitted under applicable law if we process your personal information on the legal bases of consent or legitimate interests. However, we may continue to process your personal information if it is necessary for the defense of legal claims, or for any other exceptions permitted under applicable laws.
Right not to provide consent or to withdraw consent. We may seek to rely on your consent in order to process certain personal information. Where we do so, you have the right not to provide your consent or to withdraw your consent at any time. This does not affect the lawfulness of the processing based on consent before its withdrawal.
Right to portability. Under certain circumstances, you may have the right to receive personal information we hold about you in a structured, commonly used, and machine-readable format so that you can provide that personal information to another controller.
Right to object to Automated Decision-Making. We do not make any decisions based on algorithms or other automated processing that significantly affect you.
Right against discrimination. You have the right not to be discriminated against for exercising any of the rights described in this section. We will not discriminate against you for exercising your privacy rights.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information 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.

What Rights Apply

To determine which rights you have, please refer to the table below that references the rights as described above. U.S. States not listed either do not have a law providing such rights, or it does not apply to our operations.

Jurisdiction

Applicable Rights

European Economic Area, United Kingdom and Switzerland

(for individuals located in these jurisdictions when their personal information is collected)

(a) Right to know/access; (b) Right to correct/rectification; (c) Right to delete/erasure; (d) Right to restrict processing; (e) Right to object to processing; (f) Right not to provide consent or to withdraw consent; (g) Right to portability; and (h) Right to object to Automated Decision-Making.

California Residents

With respect to specific rights granted under the California Consumer Privacy Act of 2018 (as amended, the “CCPA”) to natural person California residents, please see our California Website Privacy Policy.

JURISDICTION-SPECIFIC NOTICES

The following Jurisdiction-Specific Notices supplement (and, in the case of conflict, take precedence over) the information provided in the Policy, and will apply, if and to the extent that certain regional data protection and privacy laws apply to our processing of your personal data.

13. Additional Notice to Individuals in the European Economic Area, the United Kingdom, and Switzerland

This section only applies if and to the extent that European Data Protection Legislation (as defined below) applies to our processing of personal data. Information required to be disclosed under European Data Protection Legislation regarding the collection of your personal data that is not set forth in this EEA-UK-Swiss Privacy Notice is otherwise set forth in the Policy.

For the purposes of this EEA-UK-Swiss Privacy Notice, the “European Data Protection Legislation” means all applicable legislation and regulations relating to the processing or protection of personal data in force from time to time in the European Economic Area (and its member states), the United Kingdom, or Switzerland (collectively, the “European Countries”), including (without limitation) the General Data Protection Regulation (EU) 2016/679 (“EU GDPR”), the EU GDPR as it forms part of the laws of England and Wales, Scotland and Northern Ireland (“UK GDPR”), the UK Data Protection Act 2018, and the Switzerland revised Federal Act on Data Protection 2020 and the Ordinance of 31 August 2022 on Data Protection, and any national implementing or successor legislation, and any amendment or re-enactment, of any of the foregoing. References to “personal information” shall have the same meaning as “personal data”, and the terms “controller”, “processor”, “data subject”, “personal data” and “processing” in this EEA-UK-Swiss Privacy Notice shall be interpreted in accordance with the applicable European Data Protection Legislation. If you have any questions regarding our use of your personal data, or this Privacy Notice, please contact us at info@bluewolfcapital.com.

We may rely on your IP address to identify which country you are located in. If any terms in this section conflict with other terms contained in this Policy, the terms in this section shall apply to individuals whose personal information is collected while they are located in a European Country.

For the purposes of European Data Protection Legislation, Blue Wolf will be a controller of any personal information collected by us. In simple terms, this means that we: (i) “control” the personal data that we collect; and (ii) make certain decisions on how to use and protect such personal data.

Personal Information Collected by Us

We do not collect any special categories of personal information 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) or any information about criminal convictions and offences.

Legal Bases for Processing Your Personal Information

Our legal bases for processing your information under the EEA-UK Data Protection Laws will depend on the personal information at issue, the specific context in which the personal information is collected and the purposes for which it is used. Below is a list of how we use and disclose your personal information, as described above in Section 3 and Section 4, with the corresponding legal bases for processing.

Based on our legal obligations:

Section 3(b) To Maintain Legal and Regulatory Compliance.
Section 3(d) To Detect and Prevent Fraud and Security Risks.
Section 4(a) As required by Law.

Based on our contract with you or to take steps at your request prior to entering a contract:

Section 3(a) To Provide You With Our Sites.
Section 3(c) To Enforce Compliance with Our Terms, Agreements and Policies.
Section 3(e) To Provide Client Support or Respond to You.
Section 3(f) To Provide You with Service-Related Communications.
Section 4(b) Our Affiliates and Subsidiaries.
Section 4(c) Our Service Providers.
Section 4(d) Authorized Third Parties.

Based on our legitimate interest to operate our business and not overridden by your data protection interests or fundamental rights and freedom:

Section 3(c) To Enforce Compliance with Our Terms, Agreements and Policies.
Section 3(d) To Detect and Prevent Fraud and Security Risks.
Section 3(g) To Research and Develop Our Sites.
Section 3(h) To Personalize Your Experience.
Section 3(i) To Facilitate Corporate Acquisitions, Mergers and Transactions.
Section 4(e) During Business Transaction or Other Asset Transfers.

Based on your consent:

Section 3(j) With Your Consent.
Section 4(f) With Your Consent

We may also process personal data for any other purpose that has been notified to you, or that has been agreed in writing with you.

From time to time, we may need to process the personal data on other legal bases, including where it is necessary to protect the vital interests of another data subject or if it is necessary for a task carried out in the public interest.

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. A failure to provide the personal data requested to fulfil the purposes described in this EEA-UK-Swiss Privacy Notice may result in us being unable to provide services or products to you. In this case we may have to cancel a product or a service you have with us but we will notify you if this is the case at the time.

Right to Lodge a Complaint to Your Local Data Protection Authority

If you reside in certain territories (such as the European Economic Area, Switzerland, the United Kingdom), you may have the right to lodge a complaint with your national data protection authority or equivalent regulatory body. You can find details of EEA Supervisory Authorities here: https://edpb.europa.eu/about-edpb/board/members_en. The Supervisory Authority in the United Kingdom is the Information Commissioner’s Office (ICO). The Supervisory Authority in Switzerland is the Federal Data Protection and Information Commissioner (FDPIC).

International Transfer of Your Personal Information

We rely primarily on the European Commission’s Standard Contractual Clauses and the United Kingdom’s International Data Transfer Agreement to facilitate the international and onward transfer of personal information subject to European Data Protection Legislation to any other country or territory that is: (i) not a European Country; or (ii) which has not at the relevant time been determined by the relevant authorities in the applicable European Country to provide an adequate level of data protection in accordance with European Data Protection Legislation. We may also rely on an adequacy decision of the relevant regulatory body confirming an adequate level of data protection in the jurisdiction of the party receiving the information, or derogations in specific situations. For further information about such transfers, please contact us at info@bluewolfcapital.com.

California Website Privacy Policy

This California Website Privacy Policy (the “California Website Privacy Policy”) supplements the 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 California Website Privacy Policy 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 Website Privacy Policy is otherwise set forth in the 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.

Categories of Personal Information Collected

We collect limited types of personal information through our Sites (as defined in the Policy) and investor reporting portals, as well as through other electronic communications (e.g., emails or social media messaging), as applicable. The types of personal information we collect about you depends on the nature of your interaction with us. In the preceding 12 months, we have collected some or all of the following categories of personal information from individuals:

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 drivers’ license or state identification card number).	YES
B. A 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).	YES
C. Protected classification characteristics under California or federal law	Date of birth, citizenship and birthplace.	YES
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).	YES
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
H. Sensory data	Audio, electronic, visual, thermal, olfactory, or similar information.	NO
I. Professional or employment-related data	Current or past job history or performance evaluations.	NO
J. 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.	NO
K. Inferences drawn from other personal information	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	NO
L. 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: social security, driver’s license, state identification care, or passport numbers, 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;
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; and
To collect or process sensitive personal information where such collection or processing is not for the purpose of inferring characteristics about a consumer.

How We Use Your Personal Information

We collect personal information for the business or commercial purposes and from the sources set forth in “Personal Information We Collect” and “How We Obtain Your Personal Information,” respectively, in the Policy above. We retain the categories of personal information set forth above in the “Categories of Personal Information Collected” section of this California Website Privacy Policy only as long as is reasonably necessary for those business or commercial purposes set forth in “Personal Information We Collect” in the Policy above, except as may be required under applicable law, court order or government regulations. For more information about the personal information we collect and how we collect it, please refer to Section 1 above, “Personal Information We Collect.”

How We Disclose Your Personal Information

We do not share 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 our Sites for a business or commercial 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, 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 law	Administrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants and placement agents.
D. Commercial information	Administrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants and placement agents.
E. Biometric information	N/A
F. Internet or other similar network activity	Administrators, law firms, governmental agencies or pursuant to legal process, consultants and placement agents.
G. Geolocation data	N/A
H. Sensory data	N/A
I. Professional or employment-related information	N/A
J. 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/A
K. Inferences drawn from other personal information	N/A
L. Sensitive Personal Information	Administrators, law firms, governmental agencies or pursuant to legal process, consultants and placement agents.

Information Security

We consider the protection of sensitive information to be a sound business practice, and to that end we employ appropriate organizational, physical, technical and procedural safeguards, which seek to protect your personal information in our possession or under our control to the extent possible from unauthorized access and improper use.

Exercise Your Privacy 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, 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 and use of personal information specific to you over the last twelve (12) months. 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 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.

Do Not Track Signals

Some Internet browsers, such as Internet Explorer, Firefox, and Safari, include the ability to transmit “Do Not Track” or “DNT” signals. Since uniform standards for “DNT” signals have not been adopted, our Site does not currently process or respond to “DNT” signals.

Contact Us

If you have any questions about this California Website Privacy Policy, wish to exercise any of your rights under the CCPA, or have a privacy-related complaint, please contact us by email at info@bluewolfcapital.com, by phone at (212) 488-1340 or toll-free at (888) 849-1562, or by writing us at 3 World Trade Center, 175 Greenwich Street, 65th Floor, New York, NY 10007.

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.