PRIVACY POLICY

Quassar Capital, L.P. (“Quassar Capital,” “Quassar,” “we,” “us,” or “our”) respects the privacy of individuals whose personal information we collect, receive, maintain or process in connection with our business.

This Privacy Policy describes how we collect, use, disclose, retain and protect personal information in connection with our website, communications, investor and prospective-investor relationships, business relationships, social-media and professional-networking interactions and other activities to which this Policy applies.

This Privacy Policy should be read together with our Cookie Policy.

1. Scope

This Privacy Policy may apply to personal information collected through or in connection with:

the Quassar Capital website;
inquiries, correspondence and other communications with us;
investor and prospective-investor interactions;
business and professional relationships;
website forms;
email and customer-relationship-management systems;
Quassar Capital accounts or interactions on third-party social-media and professional-networking platforms;
integrated third-party services; and
other interactions in which this Privacy Policy is made available or otherwise applies.

Separate systems, including an Investor Portal, may be subject to additional privacy notices, contractual provisions or terms.

2. Personal Information We Collect

The personal information we collect depends upon the nature of your interaction with Quassar Capital and may include:

name and contact information;
professional, employment and business information;
social-media or professional-networking identifiers and publicly available profile information;
information submitted through forms, correspondence or other communications;
identification and verification information;
financial and investment-related information;
beneficial-ownership information;
information relevant to investor eligibility;
information required for know-your-customer, anti-money-laundering, sanctions and related compliance procedures;
source-of-funds and source-of-wealth information, where applicable;
tax and jurisdictional information, where relevant;
technical, browser and device information;
Internet Protocol addresses;
website usage and navigation information;
cookie identifiers and information collected through similar technologies;
publicly available information; and
information lawfully received from affiliated entities, service providers, professional advisers, financial institutions, regulatory sources, social-media or professional-networking platforms, or other authorized third parties.

We do not necessarily collect every category of information listed above from every individual.

3. Sources of Personal Information

We may collect personal information:

directly from you;
automatically when you use our website;
through communications or interactions with Quassar Capital;
from affiliated entities;
from administrators, custodians, brokers and other financial institutions;
from legal, compliance, accounting and other professional advisers;
from technology and other service providers;
from regulatory and compliance databases;
from publicly available sources;
from social-media and professional-networking platforms, including Instagram, X, Threads, LinkedIn and Facebook, where applicable and permitted; and
from other persons authorized or legally permitted to provide information to us.

Where appropriate and lawful, we may combine information obtained from different sources.

4. Investor Onboarding and Compliance Information

Investor and prospective-investor relationships may require information beyond that ordinarily collected from website visitors.

Depending upon the circumstances, Quassar Capital may request information concerning identity, beneficial ownership, source of funds, source of wealth, jurisdiction, tax status, business activities, investor eligibility and other matters reasonably necessary to perform applicable legal, compliance and risk reviews.

Investor relationships may be subject to identity verification, beneficial-ownership verification, KYC review, AML and sanctions screening, source-of-funds and source-of-wealth review, jurisdictional analysis, investor eligibility review and enhanced due diligence where appropriate.

Certain reviews may be conducted in coordination with authorized affiliated entities or service providers.

5. How We Use Personal Information

Subject to applicable law, we may use personal information to:

operate, maintain, secure and improve our website and information systems;
respond to inquiries and communications;
establish and administer business and professional relationships;
manage investor and prospective-investor interactions;
conduct investor onboarding and compliance reviews;
verify identity, beneficial ownership and eligibility;
perform KYC, AML, sanctions and related compliance procedures;
administer access to appropriate investor-related resources;
manage communications through email and CRM systems;
administer and understand interactions with our official social-media and professional-networking presence;
understand website usage and performance;
protect against fraud, impersonation, misuse, cybersecurity threats and unauthorized activity;
protect Quassar Capital’s rights, identity and intellectual property;
maintain business and compliance records;
establish, exercise or defend legal rights;
perform contractual obligations;
comply with applicable laws, regulations, legal process and regulatory requirements; and
support legitimate business, operational, legal, compliance and risk-management purposes consistent with the circumstances in which the information was collected.

6. Social Media and Professional-Networking Platforms

Quassar Capital may maintain accounts, pages, profiles or channels on third-party platforms, including Instagram, X, Threads, LinkedIn and Facebook.

When you interact with Quassar Capital through such a platform, we may receive information that you provide directly, information associated with your interaction, and information that the platform makes available to us in accordance with its terms, your settings and applicable law.

The relevant platform operator may independently collect and process personal information in accordance with its own privacy practices. Quassar Capital does not control processing undertaken independently by unaffiliated platform operators.

An interaction with an official Quassar Capital social-media account does not establish an investor, advisory, fiduciary or other contractual relationship with Quassar Capital.

Sensitive, confidential, investor-specific or account-related information should not be submitted through public social-media functions.

7. Cookies and Similar Technologies

We use cookies and similar technologies in connection with our website for purposes that may include security, functionality, analytics, measurement and website improvement.

Additional information concerning these technologies and available preference controls is provided in our Cookie Policy.

8. Disclosure of Personal Information

Subject to applicable law, we may disclose personal information where reasonably necessary or appropriate to:

affiliated entities;
administrators and custodians;
brokers and other financial institutions;
technology, hosting, analytics, communications, email, CRM and other service providers;
legal, compliance, accounting, tax and other professional advisers;
investor-related service providers;
regulators and supervisory authorities;
governmental, judicial and law-enforcement authorities;
counterparties or other persons where necessary to establish, exercise or defend legal rights;
parties involved in an actual or proposed corporate transaction, restructuring, financing or similar event, subject to appropriate protections where applicable; and
other persons with your authorization or as otherwise permitted or required by law.

Quassar Capital does not sell personal information collected through its website.

9. Third-Party Services

Our website may link to or integrate with third-party services, including social-media and professional-networking platforms and services supporting investor communications or other website functionality.

Those third parties may process information independently in accordance with their own terms and privacy practices. Quassar Capital does not control the privacy practices of unaffiliated third parties acting independently of us.

10. Investor Portal

Quassar Capital may provide eligible and authorized users access to a separate Investor Portal.

Information submitted to or made available through an Investor Portal may be processed by Quassar Capital and authorized service providers in connection with investor administration, communications, documentation, reporting, compliance and related purposes.

An Investor Portal may be subject to additional privacy notices, contractual arrangements, authentication requirements and terms that supplement this Privacy Policy.

11. International Processing

Quassar Capital is headquartered in New York, United States, and conducts activities involving global financial markets.

Personal information may therefore be processed in the United States or other jurisdictions in connection with our business and the activities of authorized service providers.

Privacy and data-protection requirements vary among jurisdictions. Where applicable law imposes requirements concerning international transfers or processing, Quassar Capital will address those requirements as applicable to the relevant processing activity.

12. Information Security

Quassar Capital maintains administrative, technical and organizational safeguards designed to protect personal information against unauthorized access, loss, misuse, alteration or disclosure.

No electronic transmission, information system or storage environment can be guaranteed to be completely secure.

Users are responsible for maintaining the confidentiality of credentials associated with restricted systems or Investor Portal access and should promptly report suspected unauthorized access.

13. Retention

We retain personal information for as long as reasonably necessary for the purposes for which it was collected and for legitimate business, legal, regulatory, compliance, accounting, recordkeeping and dispute-resolution purposes.

Retention periods may vary depending upon the nature of the information and relationship, applicable legal or regulatory obligations, contractual requirements, internal recordkeeping requirements and the need to establish, exercise or defend legal rights.

14. Privacy Rights

Depending upon your jurisdiction and the circumstances in which your personal information is processed, applicable law may provide rights concerning your personal information, including rights to request access, correction, deletion, restriction, objection or other action.

Such rights are not absolute and may be subject to applicable legal, regulatory, contractual, recordkeeping and other permitted limitations.

Quassar Capital does not represent through this Policy that any particular jurisdiction-specific privacy law applies to every individual who accesses the website or otherwise interacts with the Firm.

Requests will be evaluated under the law applicable to the relevant individual and processing activity.

We may request information reasonably necessary to verify identity and authority before acting upon a privacy request.

15. Children

The website and Quassar Capital’s institutional digital communications are intended for institutional, professional and business audiences and are not directed to children.

Quassar Capital does not knowingly use the website to solicit personal information from children. If we become aware that personal information concerning a child has been collected in circumstances inconsistent with applicable law, we will take appropriate action.

16. Changes to This Privacy Policy

We may amend this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements or other circumstances.

The current version will be published on the website.

17. Contact and Privacy Requests

Questions concerning this Privacy Policy, our privacy practices or requests concerning personal information may be directed to:

Nicole Dooley Horn

Chief Legal Officer

Quassar Capital, L.P.

55 Water Street, 15th Floor

New York, NY 10041

United States

nicoledooley@quassarcapital.com

General inquiries unrelated to privacy may be directed to:

contactcenter@quassarcapital.com