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PRIVACY AND SECURITY

SORIANO GLOBAL HOLDINGS L.P. PRIVACY POLICY

Your Privacy Is Important to Soriano Group

In the course of serving you as an individual client or as someone associated with a corporate or institutional client, Soriano Group may
obtain personalinformation about you. Obtaining this information is important to our ability to deliver the highest level of service to you, but we also recognize that you expect us to treat this information appropriately.

This policy describes the types of personal information we may collect about you, the purposes for which we use the information, the
circumstances in which we may share the information and the steps that we take to safeguard the information to protect your privacy. As used throughout this policy, the term “Soriano Group” refers to The Soriano Consulting Group, LLC. , and its affiliates worldwide.

The Sources of Information

The personal information we collect about you comes primarily from the account applications or other forms and materials you submit to Soriano Group during the course of your relationship with us. We may also collect information about your transactions and experiences with Soriano Group relating to the products and services Soriano Group provides. In addition, depending on the products or services you require, Soriano Group may obtain additional information about you, such as your credit history, from consumer reporting agencies.

Finally, in the provision of financial services to you and subject to strict compliance with all applicable laws and regulations, information
may be collected about you indirectly from monitoring or other means (e.g. recording of telephone calls and monitoring e-mails). In these circumstances, the information is not accessed on a continuous or routine basis, but it may be used for compliance or security purposes.

The Information We Have about You

If you deal with Soriano Group in your individual capacity (e.g. as a private client), or as a settlor/trustee/beneficiary of a trust, or as an owner or principal of a company or other investment vehicle established to invest on your behalf or on behalf of your family, etc., the typical information we collect about you would include:

  • Your name, address and other contact details;
  • Your age, occupation and marital status;
  • Extensive financial information, including source of wealth, investment experience and objectives, risk tolerance and, in certain jurisdictions, representations required under applicable law or regulation concerning your financial resources;
  • A head and shoulders photograph from, as applicable, your passport, national identity card or driver’s license, as required by
    laws and regulations addressing due diligence and related matters; and
  • A personal identifier such as, depending on your country of residence, your Social Security Number, National Insurance
    Number, Tax File Number, etc.

If you are an employee/officer/director/principal, etc. of one of our corporate or institutional clients, the typical information we collect about you personally would include:

  • Your name and contact details;
  • Your role/position/title and area of responsibility; and
  • Certain identifying information (e.g. passport photo, etc.) as required by laws and regulations addressing money laundering and related matters.

Of course, you are not required to supply any of the personal information that we may request. However, failure to do so may result in our being unable to have a relationship or to provide services to you. While we make every effort to ensure that all information we hold about
you is accurate, complete and up to date, you can help us considerably in this regard by promptly notifying us if there are any changes to your personal information

Our Use of Your Personal Information

We may use your personal information to:

  • Administer, operate, facilitate and manage your relationship and/or account with Soriano Group. This may include sharing such information internally as well as disclosing it to third parties, as described in the following two sections, respectively;
  • Contact you or, if applicable, your designated representative(s) by post, telephone, electronic mail, facsimile, etc., in connection
    with your relationship and/or account;
  • Provide you with information (such as investment research), recommendations, or advice concerning products and services
    offered by Soriano Group; and
  • Facilitate our internal business operations, including assessing and managing risk and fulfilling our legal and regulatory
    requirements.

If your relationship with Soriano Group ends, Soriano Group will continue to treat your personal information, to the extent we retain it, as described in this policy.

Disclosures of Your Personal Information within Soriano Group

In order to provide efficient and reliable services and to improve product and service options available to you, more than one entity within Soriano Group may be given, or given access to, your personal information. For example, one Soriano Group entity might share your information with another in order to facilitate settlement of your transactions or the maintenance of your accounts, or as part of its arranging for the performance of specialized services such as US and international brokerage, asset management and advisory and trust services. When so sharing your personal information, we adhere to applicable legal and industry standards regarding the protection of personal information. Additional information on how your personal information is protected while within Soriano Group is provided below, under Information Security: How We Protect Your Privacy.

Disclosures of Your Personal Information to Third Parties

Soriano Group does not disclose your personal information to third parties, except as described in this policy. Third party disclosures may include sharing such information with non-affiliated companies that perform support services for your account or facilitate your transactions with Soriano Group, including those that provide professional, legal or accounting advice to Soriano Group. Non-affiliated companies that assist Soriano Group in providing services to you are required to maintain the confidentiality of such information to the extent they receive it and to use your personal information only in the course of providing such services and only for the purposes that Soriano Group dictates.

We may also disclose your personal information to fulfill your instructions, to protect our rights and interests and those of our business partners or pursuant to your express consent. Finally, under limited circumstances, your personal information may be disclosed to third parties as permitted by, or to comply with, applicable laws and regulations; for instance, when responding to a subpoena or similar legal process, to protect against fraud and to otherwise cooperat with law enforcement or regulatory authorities or with organizations such as exchanges and clearinghouses.

You should know that Soriano Group will not sell your personal information.

Soriano Global Holdings Limited, Malta

Information Security: How We Protect Your Privacy

Soriano Group is committed to protecting the privacy and confidentiality of your personal information. We limit access to your personal information to authorized Soriano Group employees or agents and, as described above in Disclosures of Your Personal Information to
Third Parties, our service providers are held to stringent standards of privacy. We also maintain physical, electronic and procedural
safeguards to protect the information against loss, misuse, damage or modification and unauthorized access or disclosure. Some of the
other central features of our information security program are:

  • A dedicated group – the Information Security Department – that designs, implements and provides oversight to our information
    security program;
  • The use of specialized technology such as firewalls;
  • Testing of the security and operability of products and services before they are introduced to the Internet, as well as ongoing
    scanning for publicly known vulnerabilities in the technology;
  • Internal and external reviews of our Internet sites and services;
  • Monitoring of our systems infrastructure to detect weaknesses and potential intrusions;
  • Implementing controls to identify, authenticate and authorize access to various systems or sites;
  • Protecting information during transmission through various means including, where appropriate, encryption; and
  • Providing Soriano Group personnel with relevant training and continually updating our security practices in light of new risks
    and developments in technology.

Privacy and the Internet

The following additional information will be of interest to you as a visitor to this site:
 

  • Users of private Soriano Group Web sites are required to identify and authenticate themselves prior to accessing our services.
  • Generally, identification and authentication take place through the use of your user name and a password, or with an RSA
  • SecurID* Card and a Personal Identification Number (PIN).
  • The private Soriano Group Web sites are built upon a secure infrastructure with multiple layers of protection, including
    measures ranging from proper physical security of our machines to system intrusion detection capabilities. Within such private
    sites, Soriano Group uses industry standard encryption technologies to protect your information from external compromise.
  • “Cookies” are small text files that may be placed on your Web browser when you visit our Web sites or when you view
    advertisements we have placed on other Web sites.
  • “Clickstream” data (e.g., information regarding which of our Web pages you access, the frequency of such access, and your
    product and service preferences) may be collected by Soriano Group itself, or by our service providers, using cookies, Web
    beacons, page tags, or similar tools that are set when you visit our Web site or when you view an advertisement we have
    placed on another Web site. Clickstream data and similar information may be shared internally within Soriano Group and used:
    for administrative purposes; to assess the usage, value and performance of our online products and services; to improve your experience with our Web sites; and as otherwise permitted by applicable law or regulation. If you are a Soriano Group client,
    this information helps us suggest products or service offerings that may be of interest to you. This information may be
    processed by us for the purposes described above, or on our behalf by third parties, solely in accordance with our instructions.
  • When you visit this site, your browser may be momentarily directed to the Web site of an ad server or other third party service
    provider. This re-direction process will not be apparent to you. These third party Web sites automatically receive your IP
    address when this happens, and they may also collect information from your interaction with our Web sites including computer
    and connection information, standard Web log information, and ad information. Such information does not identify you
    individually.
  • Soriano Group may make available on this Web site third party applications such as content linking or sharing facilities. Information collected by providers of such applications is governed by their privacy policies.
  • Our Web sites are not currently configured to respond to “do not track” signals or similar mechanisms.

Other Privacy Policies or Statements; Changes to Policy

This policy provides a general statement of the ways in which Soriano Group protects your personal information. You may, however, in connection with specific products or services offered by Soriano Group, be provided with privacy policies or statements that supplement this policy. This policy may be changed from time to time to reflect changes in our practices concerning the collection and use of personal information. The revised policy will be effective immediately upon posting to our Web site. This version of the Policy is effective December 13, 2017.

Additional Information: The European Economic Area – Malta (This section applies only if your information is processed by Soriano Group in a Member State of the European Economic Area (EEA).

You are entitled to access any personal data about you held by Soriano Group by sending a written request to the applicable individual identified below. You may be required to supply a valid means of identification as a security precaution to assist us in preventing the unauthorized disclosure of your personal information. We will process your request within the time provided by applicable law. You are also entitled to have Soriano Group modify or delete any information that you believe is incorrect or out of date.

Terms and Conditions of Use

Access to the Soriano Group Web site defined below, is provided by SG. For purposes of this agreement, “SG” shall mean Soriano Group, LLC and its affiliates, and their officers, directors, managing directors, partners, and employees. The “Soriano Web site” shall mean the Web site of Soriano Group, LLC available to the general public and located at www.sorianogroup.com and select other domains. Monitoring by SG: Your use of the products and services on this Web site may be monitored by SG, and that the resultant information may be used by SG for its internal business purposes or in accordance with the rules of any applicable regulatory or self-regulatory organization. Information Made Available Through this Service: You are permitted to store, display, analyse, modify, reformat, and print the information made available to you via these services only for your own use. You are not permitted to publish, transmit, or otherwise reproduce this information, in whole or in part, in any format to any third party without the express written consent of SG. In addition, you are not permittedto alter, obscure, or remove any copyright, trademark or any other notices that are provided to you in connection with the information. SG reserves the right, at any time and from time to time, in the interests of its own editorial discretion and business judgment to add, modify, or remove any of the information. These Terms and Conditions of Use are not intended to, and will not, transfer or grant any rights in or to the information other than those which are specifically described herein, and all rights not expressly granted herein are re served by SG or the third party providers from whom SG has obtained the information. You are required to read and abide by any additional terms and conditions that may be posted on this service from time to time concerning information obtained from specific third party providers. Such third party providers shall have no liability to you for monetary damages on account of the information provided to you via this service. 

No warranties made as to content; no responsibilities to update: SG makes no warranty, express or implied, concerning this service. The services provided by us and our third party providers are on an “AS IS” basis at your sole risk. SG expressly disclaims any implied warranty of merchantability or fitness for a particular purpose, including any warranty for the use or the results of the use of the services with respect to their correctness, quality, accuracy, completeness, reliability, performance, timeliness, or continued availability. 

Neither SG nor any of its third party providers shall have any responsibility to maintain the data and services made available on this Web site or to supply any corrections, updates, or releases in connection therewith. 

Availability of data and services are subject to change without notice. 

No liability for content; no liability arising from use: SG shall have no liability, contingent or otherwise, to you or to third parties, or any responsibility whatsoever, for the failure of any connection or communication service to provide or maintain your access to this service, or for any interruption or disruption of such access or any erroneous communication between SG and you, regardless of whether the connection or communication service is provided by SG or a third party service provider. SG shall have no liability, contingent or otherwise, to you or to third parties, for the correctness, quality, accuracy, timeliness, reliability, performance, continued availability, completeness or delays, omissions, or interruptions in the delivery of the data and services available on this Web site or for any other aspect of the performance of this service or for any failure or delay in the execution of any transactions through this service. In no event will SG be liable for any special, indirect, incidental, or consequential damages which may be incurred or experienced on account of you using the data or services made available on this Web site, even if SG has been advised of the possibility of such damages. SG will have no responsibility to inform you of any difficulties experienced by SG or third parties with respect to the use of the services or to take any action in connection therewith. 

No warranties made as to security: SG makes no warranty whatsoever to you, express or implied, regarding the security of the site, including with respect to the ability of unauthorized persons to intercept or access information transmitted by you through this service. 

System Outages, Slowdowns, and Capacity Limitations/Delays in Order Routing, Executions, and Trade Reports: As a result of high Internet traffic, transmission problems, systems capacity limitations, and other problems, you may, at times, experience difficulty accessing the Web site or communicating with SG through the Internet or other electronic and wireless services. Any computer system or other electronic device, whether, it is yours, an Internet service provider’s or SG’ can experience unanticipated outages or slowdowns, or have capacity limitations. 

Content not to be construed as a solicitation or recommendation: This material has been prepared for informational purposes only without regard to any particular user’s investment objectives, financial situation, or means, and SG is not soliciting any action based upon it. This material is not to be construed as a recommendation; or an offer to buy or sell; or the solicitation of an offer to buy or sell any security, financial product, or instrument; or to participate in any particular trading strategy in any jurisdiction in which such an offer or solicitation, or trading strategy would be illegal. Certain transactions, including those involving futures, options, and high-yield securities, give rise to substantial risk and are not suitable for all investors. Although this material is based upon information that SG considers reliable and endeavours to keep current, SG has not verified this information and does not represent that this material is accurate, current, or complete and it should not be relied upon as such. 

No determination of suitability has been made; not all risks are disclosed; private advisors should be consulted: The fact that SG has made the data and services provided on this Web site available to you constitutes neither a recommendation that you enter into a particular transaction nor a representation that any product described on this Web site is suitable or appropriate for you. Many of the products described on this Web site involve significant risks, and you should not enter into any transactions unless you have fully understood all such risks and has independently determined that such transactions are appropriate for you. Any discussion of the risks contained herein with respect to any product should not be considered to be a disclosure of all risks or complete discussion of the risks, which are mentioned. You should neither construe any of the material contained herein as business, financial, investment, hedging, trading, legal, regulatory, tax, or accounting advice nor make this service the primary basis for any investment decisions made by or on behalf of you, your accountants, or your managed or fiduciary accounts, and you may want to consult your business advisor, attorney, and tax and accounting advisors concerning any contemplated transactions. 

No representations made as to other sites or links: This service may provide links to certain Internet sites (the “Sites”) sponsored and maintained by third parties. SG is providing such links solely as a convenience to you. 

Accordingly, SG makes no representations concerning the content of the Sites. The fact that SG has provided a link to the Site does not constitute an endorsement, authorization, sponsorship, or affiliation by SG with respect to the Site, its owners, or its providers. SG has not tested any information, software, or products found on any of the Sites and therefore does not make any representations with respect thereto, including any representations regarding the content or sponsors of the Site, or the suitability or appropriateness of the products or transactions described therein.

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