PRIVACY POLICY/NOTICE

Updated September 2019

Introduction

This notice sets forth the privacy policy and practices of Taconic Capital Advisors L.P. and its affiliates and the Cayman Islands investment funds they manage (“Taconic”, “we”, “us” and “our”) with respect to the personal data of investors (each, an “Investor”) in the funds for which Taconic serves as investment adviser or general partner or in some similar capacity. In particular, this notice describes (i) the types of personal data about Investors that Taconic may collect and (ii) the conditions under which Taconic may disclose such data to its affiliates and to nonaffiliated third parties. If you are a corporate investor (including, for these purposes, legal arrangements such as trusts or exempted limited partnerships) that provides us with personal data on individuals connected to you for any reason in relation to your investment with us, this will be relevant for those individuals and you should transmit this document to such individuals or otherwise advise them of its content.

Data That May Be Collected

Taconic may collect certain personal data with respect to Investors, including, without limitation, (a) information received from an Investor, such as social security number, tax identification number, account information and wire transfer instructions and (b) information about an Investor’s transactions with any affiliates of Taconic or nonaffiliated third parties, such as account balances, account numbers and account activity.

Taconic may obtain such personal data when the Investor makes an investment in a Taconic fund, provides information on the Investor’s subscription booklet and related forms, gives contact information, makes a wire transfer, provides government-issued ID, makes an additional contribution to a Taconic fund or requests a redemption.

Use of Investor Personal Data

Taconic will use Investors’ personal data in the course of business for tasks such as processing transactions, maintaining investor accounts, verifying investors’ identity, fulfilling legal and regulatory obligations and responding to court orders and legal investigations. Taconic may also use Investors’ personal data to communicate with Investors and offer products and services to Investors.

Data That May Be Disclosed to Affiliates

Taconic does not disclose personal data concerning Investors or former Investors to its affiliates, including, without limitation, affiliated investment advisers, except as permitted by law.

Disclosure to Certain Nonaffiliated Third Parties

Taconic does not disclose personal data that it has collected about an Investor or former Investor to nonaffiliated third parties except as permitted by law. In the normal course of its activities, Taconic may disclose certain personal data: (i) to nonaffiliated service providers, such as transfer agents, fund administrators, custodians, broker-dealers, accountants and lawyers; (ii) to fraud prevention agencies and law enforcement agencies; (iii) to courts, governmental and non-governmental regulators and ombudsmen; and (iv) where Taconic has the Investor’s consent or as required or permitted by law, including but not limited to comply with a subpoena or similar legal process or government request, or when Taconic believes in good faith that disclosure is legally required or Taconic has a legitimate interest in making a disclosure, such as where necessary to protect Taconic’s rights and property. Any such disclosure will be in compliance with applicable law.

Transfer of Personal Data Outside the EEA of Investors Located in the EEA

For those Investors who are located in the European Economic Area (“EEA”), Taconic may disclose such Investors’ personal data to recipients (including affiliates) located in countries outside of the EEA, including in the U.S., which may not have data privacy laws equivalent to those in the EEA. In such a case, Taconic will take all necessary steps to ensure the safety of your personal information in accordance with applicable data protection laws. By signing the relevant Taconic Subscription Booklet, each such Investor consents to the transfer of their personal data to Taconic and the other recipients described in this notice that may be located in countries outside of the EEA.

Rights of Investors Located in the EEA and Investors in Cayman Islands Investment Funds

Under applicable EU data protection laws and regulations, Investors who are located in the EEA may have a right to: (i) request access to and rectification or erasure of your personal information; (ii) obtain restriction of processing or to object to processing of your personal information; and (iii) data portability. If you wish to exercise any of these rights you should contact the Taconic Legal and Compliance Department at legal&compliance@taconiccap.com. You also have the right to lodge a complaint about the processing of your personal information with your local data protection authority. Investors in Cayman Islands investment funds have broadly analogous rights under the Data Protection Law, 2017 of the Cayman Islands (“DPL”). Investors in Cayman Islands investment funds also have the right to lodge a complaint under the DPL with the Office of the Ombudsman in the Cayman Islands.

Policies and Practices Regarding the Confidentiality and Security of Such Personal Data

Only Taconic employees who need to know such information are authorized to access an Investor’s (or former Investor’s) personal data, and Taconic also requires its affiliates and service providers to limit employee access to the data. In addition, Taconic has implemented security policies and procedures designed to safeguard Investors’ personal data against loss or theft, and against unauthorized access, disclosure, copying, use or modification. Taconic retains the personal data of investors for at least the length of time required by applicable laws, provided that Taconic ensures the confidentiality of such personal data and such personal data is only processed as necessary for the purpose(s) specified in the applicable law requiring its storage or as otherwise permitted.

Cayman Islands Data Protection Measures

Any transfer of personal data by us or our duly authorised affiliates and/or delegates outside of the Cayman Islands shall be in accordance with the requirements of the DPL.

We and our duly authorised affiliates and/or delegates shall apply appropriate technical and organisational information security measures designed to protect against unauthorised or unlawful processing of personal data, and against accidental loss or destruction of, or damage to, personal data.

We shall notify you of any personal data breach that is reasonably likely to result in a risk to the interests, fundamental rights or freedoms of either you or those data subjects to whom the relevant personal data relates.

Getting In Touch

If you have any questions or comments about this notice, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your privacy rights under European or Cayman law, please do not hesitate to contact us at:

Phone: 212-209-3100
Email: legal&compliance@taconiccap.com
Attention: Flaurine St Louis (Chief Compliance Officer)