Privacy Shield Policy

Hudson Advisors L.P. and its subsidiaries organized in the United States (“Hudson”) have certified to the EU-U.S. Privacy Shield (“Privacy Shield”) Principles for the processing of personal information related to natural persons from the European Union (“Data Subjects”). For more information about the Privacy Shield, and to view Hudson’s certification, please visit https://www.privacyshield.gov.

In the course of running our business and performing services for our clients, Hudson obtains and processes certain personal information about Data Subjects, including without limitation, names, addresses, assets, liabilities, income, employers, bank account information, family member information, net worth, date of birth, and other information as required to comply with applicable laws or regulations. Hudson uses this personal information to conduct due diligence, administer investments made by our clients, and comply with legal and regulatory obligations. Hudson may share this information with third parties, including our clients; service providers, including but not limited to legal advisors, auditors, and accountants; financial institutions; insurance companies; and judicial, regulatory or governmental authorities, for the purposes indicated in this Policy. By using the email address below, Data Subjects may opt out of disclosures of their information by Hudson either (i) to third parties or (ii) if the information is used for purposes which are materially different from the purposes for which it was originally collected or subsequently authorized by the Data Subject. With respect to sensitive information, Data Subjects may opt-in to disclosures either (i) to third parties or (ii) if the information is used for purposes which are different from the purposes for which it was originally collected or subsequently authorized by the Data Subject. If Hudson shares personal information with certain third parties, Hudson may be liable if those parties process that information in a manner that is inconsistent with the Privacy Shield Principles. Hudson may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Data Subjects may contact us regarding the Privacy Shield, including requests to access their personal information that is retained by Hudson, at privacyshield@hudson-advisors.com. Hudson has designated JAMS to address Privacy Shield complaints and provide appropriate recourse free of charge to the Data Subject. Data Subjects may contact JAMS at https://www.jamsadr.com/eu-us-privacy-shield. In certain circumstances, Data Subjects may be able to invoke binding arbitration with respect to adherence to the Privacy Shield. Hudson is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.