Client Login Romark FIRM TEAM STRATEGIES RESPONSIBLE INVESTING KNOWLEDGE CENTER CONTACT US PRIVACY NOTICE SEPTEMBER 2021 Introduction As a valued partner of the Shenkman Group, your privacy is very important to us. This notice (this “Privacy Notice”) is provided by Shenkman Group of Companies, and their affiliates (collectively the “Shenkman Group”), as well as mutual funds, private funds (single investor or commingled), Collateralized Loan Obligations (“CLOs”), and UCITS funds managed by the Shenkman Group (each, a “Sponsored Fund” and, collectively “Sponsored Funds”). This Privacy Notice sets forth our policies for the collection, use, storage, sharing, disclosure (collectively, “processing”) and protection of personal data relating to current, prospective and former clients and investors in Sponsored Funds, as applicable. References to “you”, “your”, “investor”, or “client” in this Privacy Notice mean any investor in a Sponsored Fund or any client of the Shenkman Group, as applicable. References to, “we”, “us”, or “our” in this Privacy Notice mean a Sponsored Fund or the Shenkman Group, as applicable. The Shenkman Group includes Shenkman Capital Management, Inc., Shenkman Capital Management Ltd, Romark Credit Advisors LP, Romark CLO Advisors LLC, and their affiliates. Capitalized terms used but not defined herein have the meanings assigned to them in the Form ADV Part 2A of Shenkman Capital Management, Inc., or of Romark Credit Advisors LP, as applicable, each of which may be supplemented, updated or modified from time-to-time. Who to Contact About This Privacy Notice This Privacy Notice is being provided in accordance with the applicable requirements under the privacy and data protection laws that apply in the jurisdictions where we operate (collectively, the “Data Protection Laws”). Certain Shenkman Group entities and Sponsored Funds are considered to be data controllers in respect of any personal data we hold about you for the purposes of certain Data Protection Laws, please see the last section of this Privacy Notice for a comprehensive list. This means that each of the Sponsored Funds and the Shenkman Group (alone or jointly, as applicable) determines the purposes and the means of the processing of your personal data. Please contact our Chief Compliance Officer at DataProtection@shenkmancapital.com, at (212) 867-9090, or by writing to the following address, Shenkman Capital Management, Inc., 461 Fifth Avenue, New York, NY 10017 with any questions about this Privacy Notice or requests with regards to the personal data we hold. Please note that certain service providers (collectively, the “Service Providers”) of the Shenkman Group and/or Sponsored Fund including, without limitation, administrators, transfer agents, legal advisers, depositaries, distributors, prime brokers, and custodians work under a range of professional and legal obligations that require them to process personal data (e.g., anti-money laundering legislation). In order to meet the requirements of such obligations, such Service Providers, from time-to-time, would not be acting on our instructions but instead in accordance with their own respective professional or legal obligations and, therefore, would be acting as data controllers in their own right with respect to such processing. For more specific information or requests in relation to the processing of personal data by such service providers, you may also contact the relevant Service Provider directly, and we can provide relevant contact information upon request. With respect to Sponsored Funds, Service Provider contact information may be found in the prospectus or confidential private placement memorandum of the applicable Sponsored Fund. The Types of Personal Data We May Hold The categories of personal data we may collect include, but are not limited to: names; residential or business addresses, or other contact details; signature; nationality; tax identification, passport, or social security number or similar identification number; date of birth; place of birth; country of incorporation or domicile; jurisdiction of tax residence(s) photographs; copies of identification documents; bank account details; information about assets or net worth; credit history; information on investment activities; financial information, for example, interest, dividends, income from certain insurance contracts or products and other income generated with respect to assets held in the account or payments made with respect to the account; account balances; proceeds from the sale or redemption of property paid or credited to the account; or other personal data, such as certain special categories of personal data (including, where relevant, information on political affiliations, ethnic origin, or criminal convictions), as specified under the applicable Data Protection Laws, that may be contained in the relevant materials, documents, or obtained through background searches, together with any other information required by applicable law or regulation. How We Collect Personal Data We may collect personal data about you through: (i) information provided directly to us by you, or another person on your behalf; (ii) information that we obtain in relation to any transactions between you and us; and (iii) recording and monitoring of telephone conversations with you. We also may receive your personal data from third parties or other sources, such as, but not limited to, our affiliates, the Service Providers, publicly accessible databases or registers, tax authorities, governmental and non-governmental agencies and supervisory authorities, credit agencies, fraud prevention and detection agencies, or other publicly accessible sources, such as the internet. How We May Use Personal Data We may process your personal data in the course of our business tasks, including, without limitation, inconnection with: (i) entering into an advisory agreement or accepting subscription documentation; (ii) administering the relationship between you and us; (iii) processing subscriptions and redemptions; (iv) executing discretionary transactions; (v) providing communications and reporting; (vi) maintaining the registers of investors of Sponsored Funds; (vii) marketing of our products and services; (viii) monitoring and analyzing our activities; (ix) processing investments and withdrawals of and payments of dividends to investors; (x) maintaining global client and investor records and providing centralized administrative, marketing and client services; (xi) investigating and resolving complaints and recording calls and managing litigation monitoring electronic communications for fraud or crime detection or for regulatory reasons; and (xii) complying with applicable legal or regulatory requirements (including anti-money laundering, fraud prevention, tax reporting, sanctions compliance, or responding to requests for information from supervisory authorities or law enforcement agencies). We will use one of the permitted grounds under the applicable Data Protection Laws to process your personal data. Such grounds include, for example, circumstances where: (i) processing is necessary to perform our obligations under applicable advisory agreements or Sponsored Fund governing documents; (ii) we are required to comply with a legal or regulatory obligation applicable to us; or (iii) we, or a third party on our behalf, have determined that it is necessary for our legitimate interests to collect and use your personal data, such as if we believe that you have a reasonable expectation for us or a third party to collect or use your personal data for such purpose. What Are The Consequences Of Failing To Provide Personal Data Where personal data is required to satisfy a statutory or regulatory obligation (including compliance with applicable anti-money laundering or sanctions requirements) or a contractual requirement, failure to provide such information may result in our advisory agreement with you, or, as applicable, your subscription in the applicable Sponsored Fund being rejected or terminated, and/or your interests in a Sponsored Fund becoming subject to compulsory redemption or withdrawal, as applicable. Where there is suspicion of unlawful activity, failure to provide personal data may result in the submission of a report to the relevant law enforcement agency or supervisory authority. How We May Share Personal Data We may disclose certain personal data about you to our affiliates, Service Providers or other third parties to onboard you as an advisory client, or in the case of Sponsored Fund investors, to accept your subscription, administer and maintain your account(s), or otherwise perform our contractual obligations. We may disclose certain personal data about you to our affiliates, Service Providers or other third parties to onboard you as an advisory client, or in the case of Sponsored Fund investors, to accept your subscription, administer and maintain your account(s), or otherwise perform our contractual obligations. We may also need to share your personal data: (i) with courts, ombudsmen, regulatory, tax, law enforcement, or other non-governmental regulators and/or authorities to comply with applicable legal or regulatory requirements; (ii) to respond to court orders, or in the context of regulatory requests for information, administrative proceedings, or investigations; or (iii) when we believe in good faith that disclosure is legally required or we or a Sponsored Fund have a legitimate interest in making a disclosure, such as where necessary to protect our or a Sponsored Fund’s rights and property. We will also release information about you if you direct us to do so. It may also be necessary, under anti-money laundering and similar laws, to disclose personal data about you to facilitate the establishment of trading relationships for your accounts, or in the case of Sponsored Fund investors, accounts of the Sponsored Funds, with prime brokers, custodians, executing brokers or other trading counterparties. We may also disclose personal data about you, or your transactions and experiences with us, to our affiliates or Service Providers for our everyday business purposes, such as administration of our business, recordkeeping, maintaining security of our information technology systems, reporting and monitoring of our activities, investor relations activities, and compliance with applicable legal and regulatory requirements.1 We may also disclose personal data about you to any third party that acquires, or is interested in acquiring, all or part of our assets or ownership interests, or that succeeds us in carrying on all or a part of our or its business, whether by merger, acquisition, reorganization or otherwise. Retention Periods and Security Measures We will take reasonable steps, in accordance with applicable Data Protection Laws, to protect your personal data against loss or theft, as well as from unauthorized access, disclosure, copying, use or modification, regardless of the format in which it is held. We will retain personal data for a minimum period of six years from the date on which you redeem all of your shares or units in the relevant Sponsored Fund(s) or you close your account with the Shenkman Group, or for as long as required for us to perform the services or comply with applicable legal or regulatory obligations. We may retain personal data for a longer period for the purpose of marketing our products and services or compliance with applicable law. From time-to-time, we will review the purpose for which personal data has been collected and decide whether to retain it or to delete if it no longer serves any purpose to us. We will notify you of any material personal data breaches affecting you in accordance with the requirements of applicable Data Protection Laws. Monitoring of Communications We may record and monitor telephone conversations and electronic communications with you for the purposes of: (i) ascertaining the details of instructions given, the terms on which any transaction was executed or any other relevant circumstances; (ii) ensuring compliance with our regulatory obligations; and/or (iii) detecting and preventing the commission of financial crime. Additional Information under the U.S. Gramm-Leach-Bliley Act 1999 (Reg S-P) and Fair Credit Reporting Act (Reg S-AM) For purposes of U.S. federal law, this Privacy Notice applies to current and former clients and investors who are individuals or Individual Retirement Accounts. We are providing this additional information under U.S. federal law. We may disclose information about our clients, investors, prospective investors or former investors to affiliates (i.e., financial and non-financial companies related by common ownership or control) or nonaffiliates (i.e., financial or non-financial companies not related by common ownership or control) for our everyday business purposes, such as to process your transactions, maintain your account(s) or respond to court orders and legal investigations. Thus, it may be necessary or appropriate, under anti-money laundering and similar laws, to disclose information about our clients or Sponsored Fund investors in order to accept subscriptions from them. We will also release information about you if you direct us to do so. We may share your information with our affiliates for direct marketing purposes, such as offers of products and services to you by us or our affiliates. You may prevent this type of sharing by contacting us at DataProtection@shenkmancapital.com. If you are a new client or investor in a Sponsored Fund, we can begin sharing your information with our affiliates for direct marketing purposes 30 days from the date we sent this Privacy Notice. When you are no longer our client or an investor in a Sponsored Fund, we may continue to share your information with our affiliates for such purposes. You may contact us at any time to limit our sharing of your personal data at DataProtection@shenkmancapital.com. If you limit sharing for an account you hold jointly with someone else, your choices will apply to everyone on your account. U.S. state laws may give you additional rights to limit sharing. We do not share your information with non-affiliates for them to market their own services to you. We may disclose information you provide to us to companies that perform marketing services on our behalf, such as any placement agent retained by a Sponsored Fund, or a client solicitor. Additional Information under the Cayman Islands Data Protection Act 2017 (“DPA”) With respect to investors in Sponsored Funds organized under the laws of the Cayman Islands, the applicable Sponsored Fund may share your personal data with its Services Providers, including the Shenkman Group, as well as the Sponsored Fund’s administrators, transfer agents, depositories, distributors, custodians, prime brokers, or others who are located outside the Cayman Islands. It may also be necessary to share your information with the Cayman Islands Monetary Authority or the Tax Information Authority, which may, in turn, exchange this information with foreign tax authorities, regulatory or law enforcement agencies. By submitting your personal data to us, you consent to the transfer of your personal data to Shenkman and the other recipients described in this notice that are located in countries outside of the Cayman Islands. Any transfer of your personal data by us, our affiliates or service providers outside the Cayman Islands will be carried out in accordance with the DPA. Investors may withdraw their consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. You may have certain rights under the DPA, including: (i) the right to be informed; (ii) the right of access; (iii) the right to rectification; (iv) the right to stop or restrict processing; (v) the right to stop direct marketing; (vi) rights in relation to automated decision making; (vii) the right to seek compensation; and (viii) the right to complain to the supervisory authority. If you wish to exercise these rights, please contact DataProtection@shenkmancapital.com. A complaint in respect of a Sponsored Fund organized under the laws of the Cayman Islands may be lodged with the Office of the Ombudsman in the Cayman Islands, although, we ask that you contact DataProtection@shenkmancapital.com in the first instance to give us the opportunity to address any concerns you may have. Additional Information under the General Data Protection Regulation With respect to investors in Sponsored Funds organized under the laws of the Cayman Islands, the applicable Sponsored Fund may share your personal data with its Services Providers, including the Shenkman Group, as well as the Sponsored Fund’s administrators, transfer agents, depositories, distributors, custodians, prime brokers, or others who are located outside the Cayman Islands. It may also be necessary to share your information with the Cayman Islands Monetary Authority or the Tax Information Authority, which may, in turn, exchange this information with foreign tax authorities, regulatory or law enforcement agencies. By submitting your personal data to us, you consent to the transfer of your personal data to Shenkman and the other recipients described in this notice that are located in countries outside of the Cayman Islands. Any transfer of your personal data by us, our affiliates or service providers outside the Cayman Islands will be carried out in accordance with the DPA. Investors may withdraw their consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. You may have certain rights under the DPA, including: (i) the right to be informed; (ii) the right of access; (iii) the right to rectification; (iv) the right to stop or restrict processing; (v) the right to stop direct marketing; (vi) rights in relation to automated decision making; (vii) the right to seek compensation; and (viii) the right to complain to the supervisory authority. If you wish to exercise these rights, please contact DataProtection@shenkmancapital.com. A complaint in respect of a Sponsored Fund organized under the laws of the Cayman Islands may be lodged with the Office of the Ombudsman in the Cayman Islands, although, we ask that you contact DataProtection@shenkmancapital.com in the first instance to give us the opportunity to address any concerns you may have. Additional Information under the General Data Protection Regulation You may have certain rights under EU General Data Protection Regulation and equivalent legislation adopted in the United Kingdom (“GDPR”) in relation to our processing of your personal data and any processing carried out on your behalf. These rights include: (i) the right to request access to your personal data; (ii) the right to request rectification of your personal data; (iii) the right to request erasure of your personal data (the “right to be forgotten”); (iv) the right to restrict our processing or use of your personal data; (v) the right to object to our processing or use where we have considered this to be necessary for our legitimate interests (such as in the case of our marketing activities); (vi) where relevant, the right to request the portability of the data; (vii) if your consent to processing has been obtained, the right to withdraw your consent at any time; and (viii) the right to lodge a complaint with a supervisory authority. Please note that the right to be forgotten that applies in certain circumstances under GDPR is not likely to be available in respect of the personal data we hold, given the purpose for which we collect such data, as described above. Please contact DataProtection@shenkmancapital.com if you wish to exercise these rights. A complaint in respect of the Shenkman Capital Management Ltd may be lodged with the Information Commissioner’s Office in the United Kingdom, although, we ask that you contact DataProtection@shenkmancapital.com in the first instance to give us the opportunity to address any concerns you may have. Due to the international nature of our business, your personal data may be transferred to jurisdictions that do not offer equivalent protection to personal data as under the GDPR (“Third Countries”). By submitting your personal data to us, you consent to the transfer of your personal data to Shenkman and the other recipients described in this notice that are located in countries outside of the United Kingdom and EEA, as relevant. Investors may withdraw their consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. In such cases, we will process personal data (or procure that it be processed) in the Third Countries in accordance with the requirements of GDPR, which may include having appropriate contractual undertakings in legal agreements with service providers who process personal data on our behalf in such Third Countries. The Shenkman Group has entered into EU standard contractual clauses (“Model Contracts”) for intra-group transfers of personal data. Investors have a right to request copies of the Model Contracts by contacting DataProtection@shenkmancapital.com. We may also be required to transfer your personal data to our regulators or government agencies in Third Countries in cases where such transfers are necessary in the context of administrative proceedings, such as requests for information, examinations or investigations, or to other relevant parties in Third Countries where it is necessary for the purposes of establishing, bringing, or defending legal claims, or for another legitimate business purpose, such as compliance with our legal or regulatory obligations under foreign law. Revisions to Our Privacy Policies The Shenkman Group evaluates its privacy policies and procedures to implement improvements and refinements from time-to-time. The Shenkman Group reserves the right to amend the terms contained herein in whole or in part for any reason without notice to you. We therefore suggest that you review this Privacy Notice periodically, which is available at https://www.shenkmancapital.com/privacy_notice Data Controllers As referenced above, the Shenkman Group entities and Sponsored Funds identified in the table below may be considered to be data controllers in respect of certain personal data we hold about you for the purposes of the applicable Data Protection Laws: Adams Mill CLO LLC Adams Mill CLO Ltd. Adams Mill Issuer Subsidiary I LLC Adams Mill Issuer Subsidiary II LLC Adams Mill Issuer Subsidiary III Ltd. Adams Mill Issuer Subsidiary IV Ltd. Adams Mill Issuer Subsidiary V Ltd. Adams Mill Issuer Subsidiary VI Ltd. Brookside Mill CLO Issuer Subsidiary IV Ltd. Brookside Mill CLO Issuer Subsidiary VI Ltd. Brookside Mill CLO Ltd. Brookside Mill CLO LLC Credos Floating Rate Fund Ltd. Credos Floating Rate Fund Subsidiary I Ltd. Four Points Multi-Strategy Fund Subsidiary VII LLC Four Points Multi-Strategy Fund, Inc. Four Points Multi-Strategy Master Fund Subsidiary I, Ltd. Four Points Multi-Strategy Master Fund Subsidiary II, Ltd. Four Points Multi-Strategy Master Fund Subsidiary IV, Ltd. Four Points Multi-Strategy Master Fund, Inc. Four Points Multi-Strategy Subsidiary III, Ltd. Jackson Mill CLO Issuer Subsidiary IV Ltd. Jackson Mill CLO Issuer Subsidiary V Ltd. Jackson Mill CLO LLC Jackson Mill CLO Ltd. Jackson Mill Issuer Subsidiary III Ltd. Jefferson Mill CLO Issuer Subsidiary IV Ltd. Jefferson Mill CLO Issuer Subsidiary V Ltd. Jefferson Mill CLO Issuer Subsidiary VI Ltd. Jefferson Mill CLO LLC Jefferson Mill CLO Ltd. Jefferson Mill Issuer Subsidiary I LLC Primus High Yield Bond Fund Ltd. Primus High Yield Bond Fund, L.P. Romark CLO Advisors LLC Romark CLO I Issuer Subsidiary I Ltd. Romark CLO I Issuer Subsidiary VI Ltd. Romark CLO II Issuer Subsidiary I Ltd. Romark CLO II Issuer Subsidiary VI Ltd. Romark CLO III Issuer Subsidiary VI Ltd. Romark CLO-I LLC Romark CLO-I Ltd. Romark CLO-II LLC Romark CLO-II Ltd. Romark CLO-III LLC Romark CLO-III Ltd. Romark CLO-IV LLC Romark CLO-IV Ltd. Romark Credit Advisors LP Romark Credit Funding I, LLC Romark Credit Funding I, Ltd. Romark Credit Funding II, LLC Romark Credit Funding II, Ltd. Romark WM-R Issuer Subsidiary IV Ltd. Romark WM-R Issuer Subsidiary V Ltd. Romark WM-R Issuer Subsidiary VI Ltd. Romark WM-R LLC Romark WM-R Ltd. Shenkman Capital Management Ltd Shenkman Capital Management, Inc. Shenkman Capital Management, L.L.C. Shenkman CLO Equity Opportunity Fund I GP, LLC Shenkman CLO Equity Opportunity Fund I LP Shenkman Credit Fund plc Shenkman Funds ICAV Shenkman Global Convertible Bond Fund Shenkman High Income Fund Shenkman High Yield Bond Master Fund, Inc. Shenkman Investments, LLC Shenkman Master Funds ICAV Shenkman Multi-Asset Credit Fund Shenkman Multi-Asset Credit Fund LP Shenkman Multi-Asset Credit GP LLC Shenkman Multi-Asset Credit Master Fund Shenkman Multi-Asset Credit Select Fund LP Shenkman Multi-Asset Credit Select GP LLC Shenkman Multi-Asset Credit Select Master Fund LP Shenkman Opportunistic Credit Fund Ltd. Shenkman Opportunistic Credit Fund Subsidiary VII LLC Shenkman Opportunistic Credit Intermediate Fund LP Shenkman Opportunistic Credit Master Fund LP Shenkman Short Duration High Income Fund Shenkman Structured Credit Master Fund Ltd. Shenkman Tactical Credit Fund (Cayman) LP Shenkman Tactical Credit Fund LP Shenkman Tactical Credit GP LLC Shenkman Tactical Credit Intermediate Fund (Cayman) Ltd. Shenkman Tactical Credit Intermediate Fund E II LLC Shenkman Tactical Credit Intermediate Fund E III LLC Shenkman Tactical Credit Intermediate Fund E IV LLC Shenkman Tactical Credit Intermediate Fund E LLC Shenkman Tactical Credit Intermediate Fund E V LLC Shenkman Tactical Credit Master Fund E LP Shenkman Tactical Credit Master Fund LP Shenkman Winchester GP LLC Sudbury Mill CLO Issuer Subsidiary II Ltd. Sudbury Mill CLO Issuer Subsidiary IV Ltd. Sudbury Mill CLO LLC Sudbury Mill CLO Ltd. Sudbury Mill Issuer Subsidiary I LLC 1Please refer to the Privacy Statement of Refinitiv, a due diligence Service Provider of the Shenkman Group, located here: https://www.refinitiv.com/en/policies/privacy-statement FIRM OVERVIEW PHILOSOPHY PROCESS HISTORY FOUNDER'S LETTER TEAM EXTRAORDINARY PEOPLE LEADERSHIP STRATEGIES PRODUCT OFFERINGS MUTUAL FUNDS UCITS FUNDS RESPONSIBLE INVESTING OVERVIEW PRI ASSESSMENT ESG NEWSLETTER ESG POLICY KNOWLEDGE CENTER MARKET PERSPECTIVE UNDER THE SCOPE WHITE PAPERS PUBLICATIONS NEWS CONTACT US LOCATIONS EMAIL FORM © 2021 SHENKMAN CAPITAL MANAGEMENT, INC. ALL RIGHTS RESERVED. FORM ADV 3 DISCLOSURES PRIVACY NOTICES COOKIE PREFERENCES TERMS OF SERVICE