Civitas’ No. 1 priority is the health and safety of our employees. Acting on advice from health experts, Civitas begins its “social distancing program” on Monday, March 16 — the date Civitas employees will work from home until further notice. Business operations will continue as normal, with employees available via business email addresses and phone numbers. We apologize if this new protocol affects our response time. As well, Civitas is not accepting visitors to its offices until further notice. If you currently have a scheduled office appointment, please reach out to your Civitas contact. Thank you for your patience and understanding. We will continue to provide updates as warranted.

Privacy

California-Specific Privacy Policy

The California Consumer Privacy Act

California enacted the California Consumer Privacy Act, California Civil Code § 1798.100 et seq., (with any implementing regulations and as may be amended from time to time, “CCPA”), in 2018, and it is effective as of January 1, 2020. The CCPA imposes certain obligations on the Fund, the General Partner and the Investment Manager (together, “we” or “us”) and grants certain rights to California residents (“California Resident,” “you” or “your”) with regard to “personal information.” If you are a California Resident, please review the following information about your potential rights with regard to your personal information under the CCPA. The rights described herein are subject to exemptions under the CCPA and other limitations under applicable law.

Terms used herein have the meaning ascribed to them in the CCPA. The Fund, the General Partner and the Investment Manager are each a “business.” “Personal information” under the CCPA means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a consumer or a household.

The CCPA does not restrict our ability to do certain things like comply with other laws or comply with regulatory investigations. In addition, the CCPA does not apply to certain information like personal information collected, processed, sold or disclosed pursuant to the federal Gramm-Leach-Bliley Act and its implementing regulations.

Business or Commercial Purpose for Collecting Personal Information

In the preceding 12 months, we may have collected or disclosed for a business purpose your personal information for the following business or commercial purposes. We may collect or disclose for a business purpose personal information for all or just a few of these purposes with regard to a particular California Resident.

  • Performing services on behalf of a fund or investment vehicle, including, for example, maintaining or servicing accounts, providing customer service, processing transactions, verifying information, processing payments, or providing similar services on behalf of a fund or investment vehicle.
  • Performing our contractual obligations to a California Resident as a subscriber to a fund or investment vehicle, including, processing initial subscriptions and providing updates on a fund’s or investment vehicle’s performance and other operational matters.
  • Detecting security incidents and protecting against malicious, deceptive, fraudulent, or illegal activity, including preventing fraud and conducting “Know Your Client,” anti-money laundering, terrorist financing, and conflict checks.
  • Enabling or effecting commercial transactions, including, using your bank account details to remit funds and process distributions.

Categories of Personal Information We Collect or Disclose for a Business Purpose

In the preceding 12 months, we may have collected or disclosed for a business purpose the following categories of personal information from or about you to our service providers or other entities that have agreed to limitations on use of your personal information. We may collect or disclose for a business purpose all or just a few of these categories with regard to a particular California Resident.

  • Identifiers such as, your name, address, date of birth, email address, social security number, driver’s license number, passport number, or other similar identifiers.
  • Personal information protected under California Civil Code Section 1798.80(e), including, for example, your signature or bank account or other financial information.
  • Characteristics of protected classifications under California or federal law, including, your sex or gender, national origin, or marital status.
  • Commercial information, including records of products or services purchased, obtained, or considered, or other purchasing histories or tendencies. For example, funds invested in the prior year, investments considered, or sources of wealth.
  • Internet or other electronic network activity information, including, for example, information regarding your interaction with our website or use of certain online tools.
  • Professional or employment-related information, including your current or former employer or your current professional title.
  • Inferences drawn from any of the information identified above to create a profile reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. For example, information on your potential interest in investing in new funds or investment vehicles based on various information.

Personal information under the CCPA does not include deidentified information, aggregate consumer information or publicly available information that is lawfully made available from government records.

Categories of Sources from Which Personal Information is Collected

In the preceding 12 months, we may have collected personal information about you from the following categories of sources. We may collect personal information from all or just a few of these categories of sources with regard to a particular California Resident.

  • Directly from you or your representatives, including through forms or related documentation you complete when subscribing for shares or interests, in correspondence and conversations (including by email), through transactions with regard to funds, and when you provide remittance instructions.
  • From our service providers.
  • From government records and other publicly accessible directories and sources, including, criminal background records, bankruptcy registers, tax authorities, governmental agencies and departments, and regulatory authorities.
  • From credit reporting agencies, sanctions screening databases, and fraud prevention and detection agencies and organizations.

Categories of Personal Information We Have Disclosed for a Business Purpose

In the preceding 12 months, we may have disclosed for a business purpose personal information about you to our service providers or other entities that have agreed to limitations on use of your personal information. We may disclose all or just a few of these categories with regard to a particular California Resident.

  • Identifiers such as your name, address, date of birth, email address, social security number, driver’s license number, passport number, or other similar identifiers.
  • Personal information protected under California Civil Code Section 1798.80(e), including, for example, your signature or bank account or other financial information.
  • Characteristics of protected classifications under California or federal law, including your sex or gender, national origin, or marital status.

Categories of Third Parties with Which We Share Personal Information

In the preceding 12 months, we may have shared your personal information with the following categories of third parties. We may share personal information with none, all, or just a few of these third parties with regard to a particular California Resident. We do not sell your personal information except as permitted by the CCPA or other laws.

  • Law enforcement as required by law.
  • Regulators and other government agencies as required or permitted by law.
  • Individuals, entities, or regulatory bodies in connection with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons.
  • Individuals, entities, or regulatory bodies to exercise or defend legal claims on behalf of you.
  • Individuals, entities, or regulatory bodies at your direction or with your consent.
  • Other individuals, entities, or regulatory bodies as otherwise required or permitted by law.

We may disclose all or just a few of the categories of personal information identified in the paragraph labeled “Categories of Personal Information We Collect or Disclose for a Business Purpose” to our service providers or other entities with which we have contracted to provide support and services and that have agreed to limitations on the use of your personal information for a business purpose or that fit within other exemptions or exceptions in the CCPA.

California Residents’ Rights under the CCPA

If your personal information is subject to the CCPA, you may have certain rights concerning your personal information, subject to applicable exemptions and limitations, including the right to: (i) be informed, at or before the point of collection, of the categories of personal information to be collected and the purposes for which the categories of personal information shall be used; (ii) not be discriminated against because you exercise any of your rights under the CCPA; (iii) request that we delete any personal information about you that we collected or maintained, subject to certain exceptions (“request to delete”); and (iv) request that we, as a business that collects personal information about you and that discloses your personal information for a business purpose, disclose to you (“request to know”): (a) the categories of personal information we have collected about you; (b) the categories of sources from which we have collected the personal information; (c) the business or commercial purpose for collecting or selling the personal information; (d) the categories of third parties with which we share personal information; (e) the specific pieces of personal information we have collected about you; and (f) the categories of personal information we have disclosed about you for a business purpose.

How to Submit a Request under the CCPA

You may submit requests to know through the following telephone number: (214) 572-2300, or through our website at the following link: https://www.civitascapital.com/contact-us/. You may submit requests to delete through the following methods: via email to ir@civitascapital.com or by mail to:

Civitas Capital Group
1722 Routh Street, Suite 800
Dallas, Texas 75201

We are required to provide certain information or to delete personal information only in response to verifiable requests made by you or your legally authorized agent. Any information gathered as part of the verification process will be used for verification purposes only.

Contact for More Information

If you have any questions or concerns about this California-specific Privacy Policy, please contact Bill Dunne (telephone: (214) 572-2300) at the office of Civitas Capital Group.


Civitas Capital Management, LLC Privacy Policy, May 2019

Civitas takes precautions to maintain the privacy of personal information concerning our current clients and prospective investors. These precautions include the adoption of certain procedures designed to maintain and secure such client’s nonpublic personal information from inappropriate disclosure to third parties. Federal regulations require Civitas to inform prospective clients of this privacy policy.

Civitas collects nonpublic personal information about its clients from the following sources:

  • Information Civitas receives from a prospective investor in this Confidential Questionnaire or other related documents or forms;
  • Information about a client’s transactions with Civitas, its affiliates, and others, including service providers that are necessary to carry on our everyday business; and
  • Information Civitas may receive from a consumer reporting agency.

Civitas does not disclose any nonpublic personal information about its prospective, existing or former Subscribers to anyone, except to service providers that have been advised as to proper handling of the information and otherwise as permitted or required by law and regulation.

Civitas restricts access to nonpublic personal information about its clients and prospective investors to those employees and agents of Civitas who have been advised as to the proper handling of such information and who need to know that information in order to provide services to its clients. Civitas may also disclose such information to its affiliates and to service providers and financial institutions that provide services to Civitas. Civitas requires such third party service providers and financial institutions to protect the confidentiality of the clients’ and prospective investors’ nonpublic personal information and to use the information only for purposes for which it is disclosed to them. Civitas may also disclose nonpublic personal information to regulatory authorities as required or permitted by applicable law. Civitas maintains physical, electronic, and procedural safeguards that comply with federal standards to safeguard the clients’ and prospective investors’ nonpublic personal information and which Civitas believes are adequate to prevent unauthorized disclosure of such information.

Civitas does not otherwise provide information about current, former and prospective individual investors to outside firms, organizations or individuals except at the Subscriber’s request or to attorneys, accountants and auditors of any current, former and prospective individual Subscriber.

Security of Customer Information

Civitas restricts access to personal information about you within Civitas to those who need to know that information in order to provide products and services to you or to comply with regulatory requirements. We maintain physical, electronic and procedural safeguards that comply with federal standards to protect such information and monitor our systems to detect weakness and potential intrusions. Civitas provide relevant training to our employees and update our securities practices in light of new

risks and developments in technology. Civitas also has the procedures to identify, authenticate and authorize access to various systems or sites.

Please know that Civitas will not sell your personal information.

“Opt Out” Provisions

The law allows you to “opt out” of certain kinds of information sharing with third parties. Civitas does not share personal information about you with any affiliated and nonaffiliated companies that trigger this opt-out right. Hence you have already “opted out.”

Important Information about Procedures for Opening a New Account

To help the government fight the funding of terrorism and money laundering activities, federal law requires financial institutions to obtain, verify and record information that identifies each person who opens an account.

Prior to acceptance and from time to time, we will request your name, address, tax identification number and other information or documents that allow us to identify you. The information gathered during this process falls under this policy.

Questions

If you have any questions concerning this privacy policy, please contact Nikki Gill, Director, Investor Relations at + 1 214 572 2300 or via email at info@civitascapital.com.