Privacy Shield Notice

Please be advised that Cortland Capital Market Services LLC, Alter Domus (US) LLC, Alter Domus (CA) Inc., Alter Domus Products Corp., Investors’ Economic Assurance, LLC, IPS Fund Services, LLC, Strata Fund Solutions, LLC, and AD Carta, LLC, all entities within the Alter Domus Group (collectively, “Alter Domus US”), may collect and transfer certain personal data outside of the EU, United Kingdom (UK) and Switzerland to the United States for processing and storage as (1) part of its provision of services to clients of its subsidiaries located in the EU, particularly for the purpose of performing “know your customer” identity verification and “anti-money laundering” compliance reviews; and (2) for pure employment functions, such as, processing payroll and track time and attendance; managing worker’s compensation claims; administering and maintaining benefits, including group benefits, and retirement service and insurance; managing employee performance of job duties and conduct workplace investigations; and performing background checks on employees.

Alter Domus US is committed to complying with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework (the “Framework”) as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States, UK, and Switzerland. When doing so, Alter Domus processes personal data pursuant to established safeguards such as the use of EU Standard Contractual Clauses.

Alter Domus US has certified to the Department of Commerce that it adheres to the Privacy Shield Principle and the Federal Trade Commission has jurisdiction over Alter Domus’s compliance with Privacy Shield. If there is any conflict between the terms in this privacy policy regarding Privacy Shield and the Privacy Shield Principles (“Principles”), the Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

SCOPE AND LIMITS ON DISCLOSURE

In connection to the provision of services to clients, Alter Domus US may provide personal data to third parties of identity verification web-based programs. These third parties are subject to confidentiality and data security obligations in their access of said personal data. These third parties would be responsible to Alter Domus US for any misuse or unauthorized access of this personal data. Alter Domus US has in place data security and recovery systems and policies that are at or higher than industry standard for the protection of such personal data.

In connection with pure employment functions, Alter Domus may share your data with third parties where it is necessary to administer the employment function or where Alter Domus has another legitimate interest in doing so. These third parties are subject to confidentiality and data security obligations in their access of said personal data. These third parties would be responsible to Alter Domus US for any misuse or unauthorized access of this personal data. Alter Domus US has in place data security and recovery systems and policies that are at or higher than industry standard for the protection of such personal data.

"Third parties" includes:

• Public authorities, including tax authorities and regulatory authorities

• Third-party service providers (including but not limited to; software providers, IT support providers, suppliers who process data on behalf of Alter Domus, and designated agents)

• Auditors

• Alter Domus clients and their advisors (for communications purposes and where AD staff act on behalf of clients)

Your personal data may also be disclosed in response to lawful requests by public authorities or by court order, which enforcement authority has jurisdiction over Alter Domus US’s compliance with the Framework.
Alter Domus will not use or disclose personal information for purposes other than those for which it was collected, except with the consent of the individual, or as required or authorized by law. Personal information will be retained only as long as necessary for the fulfilment of those purpose

INDIVIDUAL NOTICE AND CHOICE

Alter Domus does not use any automated processes to make decisions about you without human intervention. Notice to individuals regarding the personal information collected from them and how that information is used may be provided through this Privacy Shield Notice, other Alter Domus website notices, or other direct forms of communication with appropriate parties, such as contracts or agreements. Where necessary and appropriate, consent for personal information to be collected, used, and/or transferred may also be obtained through these same means of communication (including opt-in consent for sensitive personal information). If you wish to limit the use and disclosure of personal information in accordance with the Principles, please contact the Group Data Protection Officer at dataprotection@alterdomus.com.

ONWARD TRANSFER

In cases of onward transfer to third parties of HR Data received pursuant to the Framework, Alter Domus is potentially liable. Alter Domus shall remain liable under the Principles if its agent processes such personal information in a manner inconsistent with the Principles, unless Alter Domus proves that it is not responsible for the event giving rise to the damage.

In the context of an onward transfer Alter Domus has responsibility for the processing of personal information it receives under the Privacy Shield and subsequently transfers to a third party acting as an agent on its behalf. Alter Domus shall remain liable under the Principles if its agent processes such personal information in a manner inconsistent with the Principles, unless the organization proves that it is not responsible for the event giving rise to the damage.

INDEPENDENT RECOURSE MECHANISM

In compliance with the Principles, Alter Domus US commits to resolve complaints about our collection or use of your personal information. Residents of the European Union, UK and Switzerland with inquiries or complaints regarding our Privacy Shield policy should first contact David J. Evans, Group Data Protection Officer, at dataprotection@alterdomus.com. Any EU resident has the option to invoke binding arbitration to determine whether Alter Domus or Alter Domus US has violated its obligations as to that individual and whether any such violation remains fully or partially unremedied (“residual claims”). Alter Domus US has further committed to cooperate with the panel established by the EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved Privacy Shield complaints concerning data transferred from the EU and Switzerland. If you do not receive timely acknowledgment of your complaint from us, or if we have not resolved your complaint, please contact or visit http://go.adr.org/privacyshield.html for more information or to file a complaint. There are pre-arbitration requirements you must meet. For more information, visit privacyshield.gov.