Arctos Partners, LP (“Arctos”) is an investment adviser registered with the United States Securities and Exchange Commission (“SEC”) under the Investment Advisers Act of 1940, as amended. Registration of an investment adviser with the SEC does not imply a certain level of skill or training.

All information contained on this website is for informational purposes only. Nothing on this website is to be construed as a solicitation to offer investment advice or services. Information about investing in Arctos funds is only available in the form of private placement memoranda and other offering documents. These documents contain information to help investors evaluate Arctos funds’ investment objectives, risks, fees and expenses, among other factors, before considering an investment. Further information about Arctos is also available in Arctos’ Form ADV Part 2, filed with the SEC.

Past performance is not necessarily indicative, nor a guarantee, of future results and no representation is made that any fund will or is likely to achieve results that are similar to those of Arctos’ or its principals’ current or previous funds. Investors may lose part of all of their investment capital.

Certain links are provided on this website. These links are provided as a convenience and do not imply Arctos’ sponsorship or approval of any of these websites or their content. Arctos has no control over or responsibility for other websites that may be accessible from this website, the contents thereof, their security or privacy policies, or any products/services that may be offered by them. If you access any third-party website through this website or because it is referred to in this website, you do so at your own risk.

PRIVACY NOTICE

Arctos Partners, LP and our affiliates (together, “Arctos”, “we”, “our”) collects and processes Personal Data (which we define below) about you from your use of this website and through other means, such as by contacting us directly by phone or email or more generally in the course of operating our business. This Privacy Notice explains how we collect Personal Data, how we use your Personal Data and how you can assert your rights in accordance with applicable data protection laws. This Privacy Notice does not address our privacy practices with respect to any Personal Data we may collect from an investor in the funds that we sponsor or manage. We address these practices in separate notices to investors as required by law.

1. What is Personal Data and what Personal Data do we collect?

“Personal Data” is any information relating to you or that we can otherwise link to you or your household.

The Personal Data we collect on this website may include your name, email address, residential address, IP address, investor portal login information and other contact information. Some of this information we will only have access to if you provide it to us. When you visit our website, we may collect information about you when you enter and browse our website through the use of “cookies,” web server logs and other electronic tools. This information may include, without limitation, the number and frequency of your visits to our website, the websites accessed before and after you visit our website, the internet browser used by you and your IP address.

In addition to Personal Data collected from your use of our website, we may also collect Personal Data regarding our business contacts, partners, current and prospective investors, vendors and other contacts. We will collect some of this Personal Data if you contact our office or employees directly.

2. How do we collect Personal Data?

We collect Personal Data that you voluntarily provide to us, such as through “contact us” forms you choose to submit on our website to obtain more information about Arctos or our funds. We may also collect Personal Data through the use of “cookies” on our website, in the ordinary course of evaluating service providers, vendors and investments, in marketing our funds or from publicly available or accessible directories, databases and agencies.

3. How do we use your Personal Data?

We use the Personal Data we collect from you on our website for communication purposes, such as, but not limited to (i) sending you information about Arctos and/or our investment funds and (ii) maintaining our list of contacts. We use the Personal Data we collect from you through other means for business purposes, such as, but not limited to (i) communicating with service providers and vendors (ii) researching investment opportunities and (iii) managing our investments.

4. Why do we process your Personal Data?

We process your Personal Data collected from your use of this website for certain business reasons, including communication and marketing purposes. We process your Personal Data collected by other means for other business reasons, including managing our business and our funds’ investments.

5. What legal basis do we use to process your Personal Data?

In accordance with the European Union’s General Data Protection Regulation (“EU GDPR”) [please include other applicable jurisdictions here (e.g., UK GDPR)], we rely on our legitimate business interests in maintaining business relationships and communicating about Arctos’ business as the basis for collecting your Personal Data.

6. Is it necessary to provide Personal Data?

You are not required to submit information to us through this website. However, we may collect “cookies”, which do not require your consent. For our service providers, vendors, investors and other contacts, it is necessary to provide some Personal Data in order for us to do business with you.

7. With whom do we share your Personal Data?

We will not share your Personal Data with third parties except in the context of those third parties acting as data processors. For example, we may use a customer relationship manager software platform to organize our business contacts, and your Personal Data may reside on that software. Where relevant, we will ensure that contractual safeguards are implemented with these third-party data processors to ensure the protection of your Personal Data.

Arctos does not sell or transfer Personal Data to affiliates or third parties for value and does not intend to do so in the future. We will amend this Privacy Notice promptly upon any changes to this policy.

8. How long do we retain your Personal Data?

Your Personal Data will be retained for as long as you are one of our business contacts, or longer as required by applicable law. Your Personal Data may be deleted when it is no longer relevant or when you withdraw consent (see directly below), again within the parameters of applicable law. If we send you emails and/or market to you, you may unsubscribe at any time from communications from us, and we will cease sending you further communications.

9. What are my rights with respect to my Personal Data?

Your rights described in this Privacy Notice are applicable only if you reside in a jurisdiction where the provision of such rights is required by the data protection and privacy laws of the governing regulatory authority, as outlined further below. These rights may be limited and subject to further legal requirements.

California Consumer Privacy Act, 2020

• The right to be informed about what Personal Data is being processed and the rationale for the processing;
• The right to know whether and to whom your Personal Data is sold or disclosed and to opt out of the sale, if applicable;
• The right to access (i.e. view or request copies of) your Personal Data that is being processed;
• The right to request that we delete your Personal Data under certain circumstances; and
• The right to not be discriminated against for exercising your rights under the California Consumer Privacy Act.

EU GDPR, 2018

• The right to be informed about what Personal Data is being processed and the rationale for the processing;
• The right to access (i.e. view or request copies of) your Personal Data that is being processed;
• The right to request that we rectify Personal Data if it is inaccurate or out of date;
• The right to request that we delete your Personal Data (the right to be “forgotten”) under certain circumstances;
• The right to restrict processing your Personal Data if you contest its accuracy, the lawfulness of its processing or if we no longer need it;
• The right to object to the processing of your Personal Data if processing is based on our legitimate interests or for direct marketing purposes;
• The right to be informed about and object to the existence of automated decision making, including profiling, and about its significance and consequences on you; and
• The right to request a transfer of your Personal Data to a third party in certain circumstances

[UK GDPR, 2021]

[Cayman Islands Data Protection Law, 2017 (“DPL”)]

10. What security do we have in place over your Personal Data?

Arctos has implemented appropriate procedural and technical security measures to help protect your Personal Data against loss and to safeguard your Personal Data against access by unauthorized persons. We consider the protection of sensitive information to be a sound business practice and a top priority, and to that end we employ physical, electronic and procedural safeguards to protect your Personal Data. If you would like to request more information regarding the procedural and technical safeguards we have in place, please contact us at the email address below.

11. What are our procedures in the event of a breach to your Personal Data?

Depending on the applicable law, Arctos may be required to notify you or the appropriate authority in the event of a breach. States that have enacted data protection laws may require different procedures in the event of a breach of your Personal Data, including with regard to notification to certain regulators or agencies and the data subject; in each case and in the event of such a breach to your Personal Data, we will follow the laws of the applicable jurisdiction.

12. Updates to this Privacy Notice

This Privacy Notice was updated in [September 2024]. We may amend this Privacy Notice from time to time to reflect changes in our practices with respect to the processing of Personal Data or changes in applicable law.

13. Contact information

If you have any questions about how we process your Personal Data, please contact us at (972) 918-3800 or info@arctospartners.com

SFDR Disclosure under EU Regulation 2019/2088 (as of October 2022)

Transparency of Sustainability Risk Policies

Arctos Partners, LP (“Arctos”) seeks to integrate material environmental, social and governance (“ESG”) risks into its investment process where such risks could cause an actual or a potential material negative impact on the value of the investment and as appropriate in the relevant context. When evaluating investment opportunities, Arctos seeks to consider ESG risks associated with such opportunities, as well as whether there are material ESG or reputational concerns with regard to prospective portfolio companies. Arctos generally evaluates material ESG risks, mitigating factors and opportunities applicable for the asset type as a part of its broader ESG Policy (the “ESG Policy”), which guides Arctos’ consideration of material ESG risks throughout the investment process. Arctos’ ESG Policy is available to its investors upon request.

No Consideration of Adverse Impacts of Investment Decisions on Sustainability Factors

Arctos does not consider the adverse impacts of investment decisions on sustainability factors in the manner prescribed by Article 4(1)(a) of the EU Sustainable Finance Disclosure Regulation (“SFDR”). Arctos has chosen not to do so for the present time as it considers that its existing ESG policies and procedures are appropriate, proportional and tailored to the investment strategies of the funds managed by Arctos and because non-financial data is still not available in satisfactory quality and quantity to allow Arctos to adequately assess the potential adverse impact of its investment decisions on sustainability factors. Arctos continues to closely monitor regulatory developments with respect to the SFDR and other applicable ESG-focused laws and regulations, including the implementation of related and secondary legislation and regulatory guidance, and will, where required or otherwise appropriate, make changes to its existing policies and procedures.

Arctos Europe LLP is an appointed representative of Langham Hall Fund Management LLP, which is authorised and regulated by the Financial Conduct Authority of the UK.

Last Updated September 2024