Privacy Statement

This Privacy Notice is made on behalf of Pacific Road Capital Management (“Pacific Road”) and its related bodies corporate.

Pacific Road recognises an individual’s right to privacy and understands the protection and confidentiality of your personal information is important to you. By downloading, accessing or using this website (the “Site”), you acknowledge and agree to these information collection practices (the “Privacy Notice”). If you do not agree to this Privacy Notice, then you should not use the Site.

Pacific Road is bound by the Privacy Act 1988 (Cth).

Pacific Road may collect and use information relating to your use of the Site, in accordance with this Privacy Notice. The Privacy Notice concerns only the Site and not your interaction with us in any matter other than your use of the Site. This Privacy Notice does not address our privacy practices with respect to any “nonpublic personal information” or “personal data” (together, “Personal Information”) that we may collect from you as an investor in funds or accounts that we sponsor or manage or as persons with whom we otherwise conduct business. We address these practices in separate notices as required by applicable law and regulation.

Pacific Road may change this Privacy Notice from time to time, and any modifications will be effective immediately upon posting, unless indicated otherwise.

Collection of Information

The Site does not require you to provide us with Personal Information in order to access its information. However, when you use the Site, Pacific Road may collect information about your use of the Site and the devices you use to access it. This may include, but is not limited to:

• When and how often you access the Site.
• Referring sites.
• The browser and operating system you use to access the Site.
• Connection information, such as IP addresses.

Usage of “private” or “incognito” modes may not prevent your browser from sharing such information with Pacific Road. You should be aware that the Internet is not a secure environment. Whilst Pacific takes reasonable steps, we cannot guarantee the security of information you provide to us via our website or that we make accessible to you via the secure investor site. No Personal Information is stored on our public website.

Use of Personal Information

We may use the Personal Information we collect from and about you from the Site for the following business purposes and commercial (as those terms are defined in applicable law):

• To maintain, provide, operate, and improve the Sites;
• To prevent or address technical or security issues;
• To engage in internal analytics, research, auditing, and reporting;
• To comply with the law and protect the safety, rights, property, or security of the Site and the general public;

Sharing of Personal Information

We do not sell information collected on this Site to third parties. We may, however, disclose and/or share your information with:

• Affiliates and Subsidiaries.
• Service Providers. We may provide access to or share your information with select entities that use the information only to perform services on our behalf.
• Third Parties for Legal or Regulatory

We take steps to ensure that our agents and third parties keep your personal information confidential and use it only for the purposes for which they, and Pacific Road, are authorised.

Pacific Road intends to rely on applicable exemptions to the extent permitted by law. For instance, the Privacy Act exemption for disclosing personal information to our related bodies corporate.

We maintain physical, electronic and procedural safeguards to protect your personal information. The entities performing services for us are directed to protect your personal information and to only use such information in connection with the services we have contracted with them to perform. From time to time, we may review the purpose for which personal information has been collected and decide whether to retain or delete such information if we are permitted to do so under applicable law.

If you have any questions about this Privacy Notice, or wish to make a complaint about how we have handled your personal information, or wish to access or correct your personal information held by us, please contact Investor Relations:

Pacific Road Capital Management
Attn: Investor Relations
Level 2, 88 George Street
Sydney NSW 2000 Australia

Telephone: +61 2 9241 1000

Your Rights and Choices

Subject to applicable law, you may have certain rights with respect to your Personal Information, including the rights to access, review, update, delete, and correct inaccuracies in your Personal Information:

California Shine the Light Disclosure. The California “Shine the Light” law gives residents of California the right under certain circumstances to request information from us regarding the manner in which we share certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes. We do not share your personal information with third parties for their own direct marketing purposes.

California Consumer Privacy Act Rights. The California Consumer Privacy Act (“CCPA”) provides certain rights to California residents in connection with personal information that is collected and sold, as defined under the statute. For instance, if you are a California resident, you may request that we:

Provide you the categories of personal information we have collected or disclosed about you in the last twelve months; the categories of sources of such information; the business or commercial purpose for collecting or selling your personal information; and the categories of third parties with whom we shared personal information; Provide access to and/or a copy of certain information we hold about you; and, Delete certain information we have about you.

EU General Data Protection Regulation 2016/679 (“GDPR”). If you are an individual resident in the European Economic Area, your personal information will be processed as described herein by us and other parties in countries outside the EEA, including the United States, Cayman Islands and Australia, which may not offer the same level of protection of personal information as the GDPR. Please be advised that certain aspects of the GDPR may not be consistent with the laws and regulations applicable to us.

You also have the right to not be discriminated against (as provided for in applicable law) for exercising certain of your rights.

These rights are subject to certain exceptions or qualifications, including when such Personal Information we collect is subject to Gramm-Leach-Bliley, it is not covered by CCPA.

CCPA sets forth certain obligations for businesses that “sell” personal information. Based on the definition of “sell” under the CCPA and pursuant to current regulatory guidance, we do not believe we engage in such activity based on information collected via the Site and have not engaged in such activity in the past twelve months. If you have questions about our practices or want to exercise any of these rights, then please contact us.

Changes to this Privacy Notice

We encourage you to periodically review this page for the latest information on our privacy practices.