Privacy Policy

1. Introduction

Morningside Capital Inc. ("MCI", "we", "us") is committed to protecting the privacy of personal information we collect through our website and password-protected investor portal (together, the "Site"). This Privacy Policy explains what information we collect through the Site, how we use and share it, and the choices available to you. This Policy does not replace any separate privacy notice provided to you in connection with your investment or fund relationship with MCI.

2. Information We Collect

We may collect the following categories of information through the Site:

• Contact information you provide through forms on our public website, such as your name, email address, and phone number.
• Investor and account information submitted through the Portal, which may include identity verification (KYC) details, subscription documents, financial information, and communications related to your investment.
• Technical and usage information collected automatically, as described in Section 3 below.

3. Technical Information, Cookies, and Analytics

When you visit the Site, we and our service providers may automatically collect technical information, including:

• Log files: your operating system, browser type, IP address, and the date, time, and pages accessed during your visit.
• Device identifiers: information such as your IP address, which may be used to detect repeat visits and to help prevent fraudulent activity.
• Cookies: small text files stored on your device that allow the Site to recognize your browser. You can manage cookie preferences, or disable cookies, through your browser settings, though this may affect Site functionality.
• Analytics: aggregated, statistical information about how visitors use the Site, used to help us understand and improve the Site experience.

This technical information is generally not used to identify you personally, but where it is capable of identifying an individual, we treat it as personal information in accordance with this Policy.

4. How We Use Your Information

We use the information we collect to:

• Operate, maintain, and secure the Site and the Portal;
• Verify investor identity and satisfy know-your-client (KYC) and anti-money laundering (AML) obligations;
• Provide fund reporting, statements, and respond to investor inquiries;
• Comply with applicable securities, tax, and other regulatory requirements;
• Improve the Site through aggregated analytics; and
• Communicate with you, including by email or phone, where you have provided consent or where permitted by law.

5. Legal Basis for Processing

Where Canadian privacy law applies, we collect, use, and disclose personal information only with your consent (express or implied, as appropriate) or as otherwise permitted or required under applicable law, including the Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial privacy legislation.

Where the Site is accessed by individuals located in the United States, we take reasonable steps to align our practices with applicable US state privacy laws that may apply based on where you reside.

6. How We Share Your Information

We do not sell personal information. We may share personal information collected through the Site with:

• Service providers who support our business, including fund administrators, auditors, and technology providers, under confidentiality obligations;
• Our outsourced IT managed service provider, which administers our Microsoft 365 environment (including SharePoint and OneDrive) and endpoint security tools used to store and protect Site-related data;
• Regulators and governmental authorities, where required by applicable securities or other law;
• Professional advisors, such as accountants or lawyers, as needed; and
• Another party in connection with a corporate transaction (such as a merger or reorganization), subject to appropriate confidentiality protections.

7. Storage and Cross-Border Transfers

Personal information collected through the Site is primarily stored on Microsoft 365 (including SharePoint and OneDrive), administered on our behalf by our outsourced IT managed service provider. Personal information may be stored or processed in Canada, the United States, or other jurisdictions where our service providers operate. Where information is transferred outside of Canada, it may be subject to the laws of the jurisdiction in which it is held, including potential access by government authorities under local law.

8. Data Security

We use administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, disclosure, alteration, or destruction, including restricting access to authorized personnel and endpoint protection on Firm devices. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

9. Data Retention

We retain personal information collected through the Site for as long as necessary to fulfill the purposes described in this Policy, including to satisfy legal, regulatory, tax, accounting, or reporting obligations, after which it is securely deleted or anonymized.

10. Links to Other Websites

The Site may contain links to third-party websites. This Policy applies only to information collected through the Site, and we are not responsible for the privacy practices of any linked third-party site. We encourage you to review the privacy policy of any third-party site before providing your information.

11. Your Rights and Choices

Depending on your location, you may have rights to access, correct, or request deletion of your personal information, or to withdraw consent where processing is based on consent. To exercise these rights, contact us using the information in Section 13 below. We will respond to requests in accordance with applicable law.

12. Changes to This Policy

We may update this Privacy Policy from time to time. The updated version will be indicated by a revised “Updated on” date.

13. Contact Us

If you have questions about this Privacy Policy or wish to exercise your privacy rights, please contact us at info@morningsidemgmt.com.