ONCAP Management Partners L.P. (“ONCAP”) and its affiliates are committed to respecting your privacy and personal data. This Policy describes the categories of personal data we collect about you through www.oncap.com (the “Site”), how we use the information, with whom we may share it and your rights in this respect.

When you visit the Site, we automatically collect certain information that may be personally-identifiable, including your IP address, network location, browser characteristics, information on actions taken on our Site, and dates and times of website visits. This may be collected through the standard operation of ONCAP’ internet servers or through the use of “cookies”. ONCAP or third parties authorized by ONCAP may use this information to measure the use of our Site, monitor the Site’s performance, secure our Site and for systems administration purposes. Most browsers permit the user to disable the cookie feature. However, users are advised that cookies may be required for the use of certain features on the Site. You are not required to provide any personal data to access public areas of our Site.

We may also collect and process information that you voluntarily provide to us. This information may include your name, your contact information, information about your relationship with ONCAP and about your professional role, which we will collect and store for the purposes of maintaining a directory of contacts. If we receive personal data from you, we will use it in compliance with applicable laws, in ways consistent with our legitimate business interests and the purpose for which the personal data was collected. If you exchange emails with ONCAP personnel, our systems will retain a record of all email communications. When your information is provided to us by third parties (when you permit a recruitment agent or another third party to send a CV to us, for example), such third parties are responsible for obtaining the relevant consents from you and we have the right to assume, without further inquiry, that all such consents have been obtained.

We do not disclose personal data we obtain about you except as described in this Policy. We may share that personal data with ONCAP-affiliated entities and third parties who perform services on our behalf under express conditions of confidentiality and security. We also may disclose information about you if we are required to do so by law or legal process, to law enforcement or other government authorities, when we believe disclosure is necessary or appropriate to prevent harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity.

To the extent provided by law, you may request access to the personal data we maintain about you, request that we correct, amend, delete or block the information, withdraw any consent you previously provided to us or object at any time on legitimate grounds to the processing of your personal data. You may also file a complaint about our processing of your personal data with the relevant regulatory body in your country.

If you are dealing with us within the European Economic Area (“EEA”) or the UK, please note that any personal data that we hold may be transferred to, and stored at, a country outside of the EEA or the UK. Where we transfer data to our affiliates or service providers in countries outside the EEA or the UK, we will take reasonable steps to seek to ensure that those transfers take place in accordance with applicable data protection laws including, where appropriate, under an agreement on terms approved for this purpose by the European Commission. ONCAP may also disclose your personal data to other parties with your express consent to fulfill your instructions or other requirements.

While ONCAP will take all reasonable steps to protect your personal data, ONCAP does not guarantee that personal data transmitted via the Internet or stored in our systems will be absolutely safe from unauthorized use or intrusion from third parties. You accept the inherent security risks of providing information over the Internet and any transmission is at your own risk.

We will retain your information in line with our retention policies. The period for which ONCAP will retain personal data will vary depending on the purposes it was collected as well as the requirements of any applicable law or regulation.

We reserve the right to update this Policy at any time. If you have any questions about this Policy, including any requests to exercise your legal rights, please contact the Chief Compliance Officer at privacy@onex.com.