Privacy Notice

U.S. Privacy Notice¹

EU Privacy Notice

By means of this privacy notice, Volt Investment Holdings LLC and Volt Investment Holdings B.V. (together, "Volt", "we" or "us") informs its EU and US clients and investors about the processing of their personal data. Volt respects the privacy of its customers and processes their personal data in accordance with the applicable data protection legislation.

We use the word 'you' to refer to anyone within the scope of this privacy notice.

What Do We Do With Your Personal Data?

The applicable data protection legislation, including federal law, requires us to tell you how we collect, share, and protect your personal data. Please read this notice carefully to understand what we do.

We do not disclose nonpublic personal information about our (former) clients or investors to third parties other than as described below.

Personal data we collect

We collect personal data about you in connection with providing our advisory services to you or in connection with your investment in one or more funds or accounts managed or advised by us. This data may include your social security number where such processing is allowed by applicable law and may include other data such as your:

Contact details (including home address, telephone number and email);
Gender, age and nationality;
Identification documents and photos;
Investment experience and risk tolerance;
Transaction activity and history;
Assets and income information;
Source of funds;
Tax information;
Information to allow Know Your Customer (KYC) and Anti Money Laundering (AML) requirements to be fulfilled; and
Bank account details.

As part of our compliance with legal obligations such as AML/KYC, we may be required to process special categories of personal data, as well as criminal convictions and offences.

How we collect this information

We collect this information through various means, including directly from you. For example, when you give us your contact information, complete subscription documents, tax forms and other related documentation that you complete when you subscribe for an investment in a fund, tell us where to send money, or make a wire transfer. We also may collect your personal information from other sources, such as our affiliates or other non-affiliated companies and publicly available sources.

How we use this information

All financial companies need to share customers’ personal information to run their everyday business, and we use the personal information we collect from you for our everyday business purposes. These purposes may include for example:

To provide advisory services to you.
To establish and administer an account for you.
To process a transaction for your account.
To market products and services to you.
To respond to court orders and legal investigations.
To comply with our legal and regulatory obligations.

Disclosure to others

We may provide your personal data to:

our affiliates and to firms that assist us in servicing your account and have a need for such information, such as fund administrators, financial institutions, attorneys, auditors, accountants, professional advisors and Know Your Client (KYC) and Anti-Money Laundering (AML) administrators;
service providers and financial institutions with whom we have joint marketing arrangements (i.e., a formal agreement between non-affiliated financial companies that together market financial products or services to you, such as placement agents). We require third-party service providers and financial institutions with which we have joint marketing arrangements to protect the confidentiality of your information and to use the information only for the purposes for which we disclose the information to them;
Tax authorities, to comply with applicable law and regulation; and
Regulators, supervisory authorities or other bodies, to comply with legal obligations.

How we protect your personal information

To protect your personal information from unauthorized access and use, we use security measures that comply with Federal and EU data protection law. These measures include computer safeguards and secured files and buildings.

Who to contact with questions

If you have any questions about this Privacy Notice, please contact the Firm’s Chief Compliance Officer at compliance@voltinvestmentholdings.com or +1 (917) 983-0505.

Changes

We reserve the right to unilaterally change or update this Privacy Notice. To the extent required by applicable law, we will inform you of such changes or updates.

Information for US clients or investors

Financial companies choose how they share your personal information. Federal law gives our clients and investors the right to limit some but not all sharing.

Our sharing practices as referred to in the section 'disclosure to others' are consistent with Federal privacy and related laws, and in general, you may not limit our use of your personal information for these purposes under such laws. We note that the Federal privacy laws only give you the right to limit the certain types of information sharing that we do not engage in (e.g., sharing with our affiliates certain information relating to your transaction history or creditworthiness for their use in marketing to you, or sharing any personal information with non-affiliates for them to market to you).

Information for EU clients or investors

Purposes and legal grounds

We rely on the following legal grounds for processing when processing your personal data: the performance of a contract with you, a legal obligation, your consent and our legitimate interests. Our legitimate interests include marketing, advertising, research and optimizing our services. Please find an overview of the purposes for which we process your personal data, including the legal ground relied upon, below:

Purpose	Legal Ground
To provide our services to you, including advisory services, establishing and administering fund investments, processing a transaction for you, and meeting our contractual obligations to fund investors	The performance of a contract with you
For legitimate interests to: provide our investment products and services to you; manage and administer your account(s); share information, notices or correspond with you in connection with investment(s); seek professional or legal advice; facilitate transactions involving a fund; address or investigate claims, disputes, complaints or proceedings; keep records, manage risk, enable operations, governance and compliance with internal policies and procedures; protect against theft, fraud, reputational damage and financial crime; and monitor communications and protect the security of our IT systems	Our legitimate interests, or those of a third party, to process your personal data
To undertake investor due diligence, KYC and AML screening, verify the identity of our investors (and beneficial owners, as required), verify compliance with sanctions and laws, and comply with obligations such as CRS and FATCA	To comply with applicable legal and regulatory obligations
Marketing and advertising our products and services, including investor letters and presentations	Our legitimate interests and where necessary your consent
To comply with laws and regulations, respond to court orders and comply with legal, regulatory or tax authority investigations	To comply with a legal obligation and our legitimate interest

Transfer of your personal data

We will only transfer your personal data to third parties mentioned in the section 'disclosures to others' for the purposes included in this privacy notice, and only to the extent that such is permitted under the applicable data protection legislation.

To be able to provide our services, it might be necessary that we transfer your personal data to other countries, including countries outside the European Economic Area such as the United States. If we do so, we take all measures necessary to safeguard your personal data and to ensure that the transfer of your personal data to such countries is permitted under the applicable data protection legislation. For more information on the safeguards we have implemented please reach out to us using the contact details included below.

How long we retain your personal information

We will not store your personal data longer than necessary to achieve the purposes stated in this privacy notice, unless we are required by law to do so.

Generally, we retain your personal data at least seven years to meet our statutory retention obligation.

Your Rights

You have the following rights:

Right of access, this means you can make a request to obtain access to the personal data concerning you;
The right to rectification or correction of your personal data;
The right to erasure of the personal data concerning you;
The right to restriction of the processing;
The right to data portability, this means that you have the right to receive your personal data in a structured, commonly used and machine-readable format, and that you have the right to transmit those data to another controller;
The right to object; and
The right to withdraw your consent.

You can exercise these rights by contacting us using the contact details included below.

In addition to the above stated rights, you also have the right to lodge a complaint with a supervisory authority. The supervisory authority for the Netherlands is the Autoriteit Persoonsgegevens.

Privacy Notice Supplement for California Residents

This notice supplements the Privacy Notice set forth above with respect to specific rights granted under the California Consumer Privacy Act of 2018, as amended (the “CCPA”) to natural person California residents and provides information regarding how such California residents can exercise their rights under the CCPA. This supplement is only relevant to you if you are a resident of California as determined in accordance with the CCPA. Information required to be disclosed to California residents under the CCPA regarding the collection of their personal information that is not set forth in this CCPA supplement is otherwise set forth above in the Privacy Notice. To the extent there is any conflict with the privacy requirements under the Gramm-Leach-Bliley Act and/or Regulation S-P (“GLB Rights”), GLB Rights shall apply.

Categories of Personal Information We Collect

We have collected some or all of the following categories of personal information from individuals within the last twelve (12) months:

Category	Examples	Collected
A. Identifiers	Name, contact details and address (including physical address, email address and Internet Protocol address), and other identification (including social security number, passport number and driver’s license or state identification card number).	YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))	Telephone number, signature, bank account number, other financial information (including accounts and transactions with other institutions and anti-money laundering information), and verification documentation and information regarding investors’ status under various laws and regulations (including social security number, tax status, income and assets).	YES
C. Protected classification characteristics under California or federal law	Date of birth, citizenship and birthplace.	YES
D. Commercial information	Account data and other information contained in any document provided by investors to authorized service providers (whether directly or indirectly), risk tolerance, transaction history, investment experience and investment activity, information regarding a potential and/or actual investment in the applicable fund(s), including ownership percentage, capital investment, income and losses, source of funds used to make the investment in the applicable fund(s).	YES
E. Biometric information	Imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns and voice recordings or keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contains identifying information.	NO
F. Internet or other similar network activity	Use of our website, fund data room and investor reporting portal (e.g., cookies, browsing history and/or search history), as well as information you provide to us when you correspond with us in relation to inquiries.	YES
G. Geolocation data	Physical location or movements.	NO
H. Sensory data	Audio, electronic, visual, thermal, olfactory, or similar information.	NO
I. Professional or employment-related information	Current or past job history or performance evaluations.	NO
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	NO
K. Inferences drawn from other personal information	Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	NO
L. Sensitive Personal Information	Social security, driver's license, state identification card, or passport numbers; account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation; racial or ethnic origin; religious or philosophical beliefs; union membership; genetic data; the contents of a consumer's mail, email, and text messages unless you are the intended recipient of the communication; biometric information for the purpose of uniquely identifying a consumer; and personal information collected and analyzed concerning a consumer's health, sex life, or sexual orientation.	YES, as to the following types of information: social security, driver’s license, state identification card, or passport numbers; account log-in, financial account in combination with any required security or access code password; or credentials allowing access to an account only.

We do not collect or use sensitive personal information other than:

To perform services, or provide goods, as would reasonably be expected by an average consumer who requests those goods or services;
As reasonably necessary and proportionate to detect security incidents that compromise the availability, authenticity, integrity, and confidentiality of stored or transmitted personal information;
As reasonably necessary and proportionate to resist malicious, deceptive, fraudulent, or illegal actions directed at us and to prosecute those responsible for such actions;
For short-term, transient use (but not in a manner that discloses such information to another third party or is used to build a profile of you or otherwise alter your experience outside of your current interaction with us);
To perform services on behalf of our business;
To verify or maintain the quality or safety of a service or to improve, upgrade, or enhance such service or device; and
To collect or process sensitive personal information where such collection or processing is not for the purpose of inferring characteristics about a consumer.

We collect personal information from the sources set forth in “Purposes for Collecting Personal Information” and “Sources of Non-Public Information,” respectively, in the Privacy Notice above. We retain the categories of personal information set forth above in the “Information We Collect” section of this Privacy Notice Supplement only as long as is reasonably necessary for those purposes set forth in “Purposes for Collecting Personal Information” in the Privacy Notice above, except as may be required under applicable law, court order or government regulations.

Disclosure of Information

We do not share for the purpose of cross-context behavioral advertising or sell (as such terms are defined in the CCPA) any of the personal information we collect about you to third parties.

Within the last twelve (12) months, we have disclosed personal information collected from you for a business purpose to the categories of third parties indicated in the chart below. We may also disclose your information to other parties as may be required by law or regulation, or in response to regulatory inquiries.

Personal Information Category	Category of Third-Party Recipients
A. Identifiers	Administrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants and placement agents.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))	Administrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants and placement agents.
C. Protected classification characteristics under California or federal law	Administrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants and placement agents.
D. Commercial information	Administrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants and placement agents.
E. Biometric information	N/A
F. Internet or other similar network activity	Administrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants and placement agents.
G. Geolocation data	N/A
H. Sensory data	N/A
I. Professional or employment-related information	N/A
J. Non-public education information	N/A
K. Inferences drawn from other personal information	N/A
L. Sensitive Personal Information	Administrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants and placement agents.

Rights under the CCPA

Deletion Rights: You have the right to request that we delete any of your personal information that we retain, subject to certain exceptions, including, but not limited to, our compliance with U.S., state, local and non-U.S. laws, rules and regulations. We will notify you in writing if we cannot comply with a specific request and provide an explanation of the reasons.
Disclosure and Access Rights: You have the right to request that we disclose to you certain information regarding our collection, use, disclosure and sale of personal information specific to you. Such information includes: the categories of personal information we collected about you; the categories of sources from which the personal information is collected; our business or commercial purpose for collecting such personal information; categories of third parties with whom we disclose the personal information; the specific pieces of personal information we have collected about you; and whether we disclosed your personal information to a third party, and if so, the categories of personal information that each recipient obtained.
Correction Right: You have the right to request that we correct any inaccuracies in the personal information that we retain, subject to certain statutory exceptions. We will notify you in writing if we cannot comply with a specific request and provide an explanation of the reasons.
No Discrimination: We will not discriminate against you for exercising your rights under the CCPA, including by denying service, suggesting that you will receive, or charging, different rates for services or providing a different level or quality of service to you.

How to Exercise Your Rights

To exercise any of your rights under the CCPA, or to access this notice in an alternative format, please submit a request on your behalf using any of the methods set forth below.

Call us at +1 (917) 983-0505 or email us at compliance@voltinvestmentholdings.com, attention of the Firm's Chief Compliance Officer.

We will contact you to confirm receipt of your request under the CCPA and request any additional information necessary to verify your request. We verify requests by matching information provided in connection with your request to information contained in our records. Depending on the sensitivity of the request and the varying levels of risk in responding to such requests (for example, the risk of responding to fraudulent or malicious requests), we may request further information or your investor portal access credentials, if applicable in order to verify your request. You may designate an authorized agent to make a request under the CCPA on your behalf, provided that you provide a signed agreement verifying such authorized agent’s authority to make requests on your behalf, and we may verify such authorized person’s identity using the procedures above. If we request you verify your request and we do not receive your response, we will pause processing your request until such verification is received.

Please contact the Firm's Chief Compliance Officer at the email address above with any questions or concerns about this Privacy Notice.

¹ This U.S. Privacy Notice is intended only for individuals and certain entities that are essentially “alter egos” of individuals (e.g., revocable grantor trusts, IRAs or certain estate planning vehicles). This U.S. Privacy Notice is also being provided to you on behalf of, and with respect to, all management companies and fund general partners affiliated with such entities.