Global Privacy Notice of Millburn Ridgefield Corporation and Affiliated Entities

Millburn Ridgefield Corporation and its affiliates (“Millburn,” the “Company,” or “we,” “us,” or “our”) care about your privacy and recognize the importance of protecting your personal information. Furthermore, we are required by applicable law to make certain disclosures to you about our data privacy practices. Accordingly, below is our privacy notice (the “Notice”) describing the kind of personal information we may collect during your visit to our website (the “Site”) or through your other interactions with us.

For purposes of this Notice, “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. It does not include de-identified or aggregate information, or public information lawfully available from governmental records. Depending on who you are and the nature of your interaction with Millburn, some of the Personal Information we collect may be nonpublic personal information. For purposes of this Notice, “affiliated entities” are companies related by common ownership or control, which may include financial and nonfinancial companies.

By accessing the Site, you agree to our collection and use of Personal Information as described in this Notice and in accordance with our Terms of Use.

This Notice applies to Millburn Ridgefield Corporation, its affiliates, Millburn International (Europe) LLP, and to each investment vehicle sponsored by Millburn Ridgefield Corporation and to which Millburn Ridgefield Corporation serves as the general partner, investment manager, investment adviser, or in a similar capacity. Additional information applicable specifically to Millburn International (Europe) LLP is discussed below.

This notice was last updated January 2023.

Millburn Ridgefield Corporation and Affiliated Entities Privacy Notice Summary

Financial institutions like Millburn are required to provide privacy notices to their clients and federal law also requires us to tell you how we collect, share, and protect your personal information. We believe that protecting the privacy of your Personal Information is of the utmost importance, and we are committed to maintaining the privacy of your Personal Information in our possession. As required by applicable rules, we are providing you with the following information. Please read this privacy notice carefully to understand what we do.

What Personal Information Does Millburn Collect and What Personal Information has Millburn Collected in the Past 12 Months?

We collect Personal Information about you, which may include nonpublic personal information, in the following ways:

(i) Information we receive from you on managed account agreements, fund subscription documents, and related forms (for example, name, address, Social Security number, birth date, bank or broker account information, assets, income, and investment experience);

(ii) Information collected during your transactions with us (for example, account activity and balances, and information regarding the account from which you make an investment or to which redemption or withdrawal proceeds are paid);

(iii) We may also collect Personal Information from you automatically, when you visit our Site. This information may include your IP address, your device and browser type, and information about your interaction with our Site and advertisements; and

(iv) We may also collect your Personal Information from publicly available sources.

The categories of Personal Information we may have collected from these sources during the 12 months preceding the date of this Notice, and will continue to collect, include the following:

(i) Personal identifiers: Name, contact information, address, email address, telephone numbers, Social Security number, username and password, and other similar information.

(ii) Financial information: Bank account and investment information.

(iii) Protected class information: Age and birth date.

(iv) Internet or other electronic activity information: Device and browser type, your browsing and search history on our Sites, and information regarding your interaction with our Sites and our advertisements.

(v) Inferences drawn from the Personal Information identified above.

What Does Millburn Do With Your Personal Information?

We use your Personal Information to provide our services to you – for example, to service your account and process your transactions. We may also use Personal Information to contact you from time to time to provide you with customer support, advertisements and marketing promotions, and offers about products or services we think may be of interest to you. Millburn does not disclose nonpublic personal information about our current and former clients and investors to third parties other than as described below. We do not sell nonpublic personal information about clients or investors to anyone, nor do we share your information with non-affiliated third parties for them to market to you. We also do not share information about your creditworthiness with our affiliates for their everyday business purposes or for them to market to you.

We may also use Personal Information about your use of our Site to monitor and improve our Site; for internal business analysis; to prevent fraud, activities that violate our Terms of Use or that are illegal; and to protect our rights and the rights and safety of our users or others.

How Do We Share and Have We Shared Your Personal Information for Business Purposes in the Past 12 Months?

Financial companies like Millburn choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. The following chart describes the categories of Personal Information that we disclosed to third parties for a business purpose in the 12 months prior to the date of this Notice:

Additional Information About How We May Share Personal Information

We do not disclose any Personal Information about our customers or former customers to anyone other than in connection with providing our services; providing customer support, advertisements and marketing promotions; for the administration, processing, and servicing of customer accounts or investment funds as described above or to our accountants, tax preparers, attorneys and auditors; or as otherwise permitted or required by law.  We do not sell your Personal Information and we do not discriminate in terms of fees or services among different categories of individual investors based upon their exercise of any rights relating to their Personal Information.  To be clear, this means we do not share any non-public information with other entities for their own marketing purposes.

Federal law gives consumers the right to limit some, but not all, sharing. As disclosed above, the types of Personal Information we collect and share depend on which of our products or services you use, as well as what information you choose to share with us.  All financial companies need to share customers’ Personal Information to run their everyday business.

We currently do not engage in any of these activities, and only share non-public information with nonaffiliated third parties that are service providers; however, please note that federal law gives you the right to limit only: (1) sharing for affiliates’ everyday business purposes; (2) information about your creditworthiness; (3) affiliates from using your information to market to you; and (4) sharing for non-affiliates to market to you. 

When Millburn shares your information with third-party service providers, it requires them to protect the confidentiality of your information and to use the information only for the purposes for which it was disclosed. Millburn does not otherwise provide nonpublic personal information about you to outside firms, organizations or individuals, except as required by law, as requested by any regulatory or taxing authority with appropriate jurisdiction, at your request or with your consent.

Millburn restricts access to nonpublic personal information about you to its employees who need to know that information to provide products or services to you. Millburn maintains physical, electronic and procedural safeguards that comply with federal standards to guard your personal information.

BY DISCLOSING YOUR NONPUBLIC PERSONAL INFORMATION TO MILLBURN, YOU CONSENT TO THE COLLECTION, STORAGE AND PROCESSING OF YOUR PERSONAL INFORMATION BY MILLBURN IN A MANNER CONSISTENT WITH THIS PRIVACY NOTICE.

How Do I Limit Sharing?

Please call us at +1 855 802 8241 or visit us online at www.millburn.com. Please note, if you are a new customer, we can begin sharing your information 30 days from the date we sent this Notice. When you are no longer our customer, we continue to share your information as described in this Notice. However, you can contact us at any time to limit our sharing.

What Other Rights Do You Have?

Your Right To Request Disclosure of Information We Collect and Share About You

We are committed to ensuring that you know what Personal Information we collect. To that end, you can ask us for any or all of the following regarding the Personal Information we have collected about you in the 12 months prior to our receipt of your request:

• Specific pieces of Personal Information we have collected about you;
• Categories of Personal Information we have collected about you;
• Categories of sources from which such Personal Information was collected;
• Categories of Personal Information that the business sold or disclosed for a business purpose about you;
• Categories of third parties to whom the Personal Information was sold or disclosed for a business purpose; and
• The business or commercial purpose for collecting or selling your Personal Information.

Your Right To Request Deletion of Personal Information We Have Collected About You 

Upon your request, we will delete the Personal Information we have collected about you, except for situations where the law authorizes us to retain specific information, including when it is necessary for us to provide you with a good or service that you requested; perform a contract we entered into with you; maintain the functionality or security of our systems; or comply with or exercise rights provided by the law.  The law also permits us to retain specific information for our exclusively internal use, but only in ways that are compatible with the context in which you provided the information to us or that are reasonably aligned with your expectations based on your relationship with us.  We will act on your deletion request within the timeframes set forth below.

Exercising Your Rights and How We Will Respond

To exercise any of the rights above, or to ask a question, contact us at +1 855 802 8241, submit a request to investor.relations@millburn.com, or use the contact details set out at the end of this Notice.

For requests for access or deletion, we will first acknowledge our receipt of your request within 10 business days.  We will provide a substantive response to your request as soon as we can, generally within 45 days from when we receive your request, although we may be allowed to take longer to process your request under certain circumstances. 

If we expect your request is going to take us longer than normal to fulfill, we will let you know.

We usually act on requests and provide information free of charge, but we may charge a reasonable fee to cover our administrative costs in providing the information in certain situations.  In some cases, the law may allow us to refuse to act on certain requests.  When this is the case, we will endeavor to provide you with an explanation. 

Our Commitment to Allowing You to Exercise Your Rights – Non-Discrimination

If you exercise any of the rights explained in this Notice, we will continue to treat you fairly.  If you exercise your rights under this Notice, you will not be denied or charged different prices or rates for goods or services, or provided a different level or quality of goods or services than others.

Verification of Identity – Access or Deletion Requests

We will ask you for identifying information and attempt to match it to information that we maintain about you. 

If we are unable to verify your identity with the degree of certainty required, we will not be able to respond to your request.  We will notify you to explain the basis of the denial. 

Authorized Agents

You may designate an agent to submit requests on your behalf.  The agent must be a natural person or a business entity that is registered with the state entity identified (if any) by your state law.  

If you would like to designate an agent to act on your behalf, you and the agent will need to comply with our verification process:

Requests to Access, Know, or Delete Personal Information: If the agent submits requests to access, know, or delete your Personal Information, the agent will need to provide us with your signed permission indicating the agent has been authorized to submit the request on your behalf.  We will also require that you verify your identity directly with us or confirm with us that you provided the agent with permission to submit the request.

Please note that this subsection does not apply when an agent is authorized to act on your behalf pursuant to a valid power of attorney.  Any such requests will be processed in accordance with state law pertaining to powers of attorney.  

Requests for Household Information

There may be some types of Personal Information that can be associated with a household (a group of people living together in a single dwelling).  Requests for access or deletion of household Personal Information must be made by each member of the household.  To the extent we collect household information and requests are made pertaining specifically to such information, before responding to a request, we will verify the identity of each member of the household using the verification criteria explained above and will also verify that each household member is currently a member of the household.

Security and Retention

The Company will take reasonable steps to protect customers’ Personal Information against loss or theft, as well as from unauthorized access, disclosure, copying, use, or modification, regardless of the format in which it is held. However, no method of transmission over the internet, or method of electronic storage, is 100% secure. To the extent permitted by applicable law, the Company retains Personal Information it obtains about you as long as: (i) it is needed for the purposes for which the Company obtained it, in accordance with the provisions of this notice; or (ii) the Company has another lawful basis for retaining the data beyond the period for which it is necessary to serve the original purpose for collecting the data.

Cookies

Cookies are small pieces of text sent to a user’s web browser when visiting a website. They are used to help users navigate websites efficiently as well as to provide information to the owner of the website. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, please visit www.allaboutcookies.org.

In order to increase the effectiveness of our website and improve user experience, the Company may place a cookie or other online tracking device (e.g., web beacon) that recognizes you when you visit the Site.  These collect information about a website visitor’s computer, including IP address, the company name from which the visitor is browsing the website, the operating system, and browser type, among other information. Visitors to the Site are able to set their browser not to accept cookies, or opt out from accepting cookies, but this may limit their ability to use the website. Collecting information in this way enables Millburn to estimate audience and page usage patterns and preferences, with the overall goal of better understanding who accesses the website and how we can customize or better provide information to website visitors. You can disable cookies from your computer system by following the instructions on your browser or at www.youradchoices.com.

We also work with third-party service providers who may place third-party cookies or similar technologies on your computer when you visit our Sites to collect information about your use of our Sites for our own use. We do not, however, permit these companies to collect Personal Information about your online activities over time and across different websites when you visit our Site, nor do we allow third parties to do so. 

Lastly, we use Google Analytics to evaluate the use of our website. Google Analytics uses cookies and other identifiers to collect information, such as how often users visit the website, what pages they visit when they do so, and what other websites they visited prior to visiting our website. To learn more about how Google Analytics collects Personal Information, review Google’s Privacy Notice.

Do Not Track

We do not respond to Do Not Track (DNT) header signals at this time.

California Shine the Light

California Civil Code Section 1798.83, also known as the “Shine the Light” law, permits California residents that have an established business relationship with a business to annually request, free of charge, information about certain categories of Personal Information a business has disclosed to third parties for those parties’ direct marketing purposes in the preceding calendar year.  For information and to make a request, please contact us at +1 855 802 8241 or investor.relations@millburn.com.

Personal Information of Minors

Our products and services are not directed to minors under the age of 13 and we do not knowingly collect the Personal Information of minors under 13. 

Other Websites and Social Media Buttons

Our Site may contain links to other websites or social media buttons. We are not responsible for the privacy practices or the content of those websites or social media platforms. This Notice applies only to our business and the Personal Information we collect. 

Accessibility

We want our communications to be accessible to people with disabilities.  To make accessibility-related requests or report barriers, please contact us at investor.relations@millburn.com.

Additional Privacy Notice Applicable to European Economic Area (“EEA”) and United Kingdom Persons

This notice sets forth the additional privacy practices of Millburn International (Europe) LLP (the “Company”) with respect to the Personal Information of business contacts of the Company (each, a “Client”). This notice only applies to Clients whose Personal Information is processed by the Company. For the purposes of EEA/UK data protection laws, the Company is the controller of your Personal Information.

Data That May Be Collected

The Company may collect certain Personal Information with respect to Clients, for example, contact information (such as name, postal and email address, and telephone number) (“Contact Data”); date of birth; information about your transactions with Company, Company funds, or Company affiliates; information about your assets, net worth, source of funds, or credit history; signatures; copies of identification documents; bank account details (“Financial Data”); and other Personal Information you provide to Company, such as through emails, subscription documents or agreements and other onboarding documents (that may include Social Security numbers, tax ID numbers or other government-issued identification numbers, to the extent permitted by applicable law) (“Onboarding Data”), and other forms and documents you provide or that are provided by others on your behalf.

Purposes and Legal Bases for Processing of Personal Information

The Company also may use the Personal Information obtained in other ways for which the Company provides specific notice at the time of collection.

Please note that you have a right to object to the processing of your Personal Information where that processing is carried out for the Company’s legitimate interest or for direct marketing.

Where we require your Personal Information to comply with AML or other legal requirements, failure to provide this information means the Company may not be able to accept you as a Client and/or may not be able to process, or release your investments. This may result in the Company terminating its relationship with you.

Disclosure to Certain Third Parties

The Company does not sell or otherwise share Personal Information about you, except as described in this notice. The Company shares your Personal Information with its affiliates, including Millburn Ridgefield Corporation, for the purposes identified in this notice. The Company also shares the information with service providers who perform services on its behalf based on its instructions and record your information in one or more databases maintained by third parties in connection with the collection of data and communications and for legal or regulatory purposes, as described in this notice. The Company does not authorize these service providers to use or disclose the information except as necessary to perform services on its behalf or comply with legal requirements. Examples of these service providers include fund administrators and entities that perform anti-money laundering testing services. In addition, the Company may share your Personal Information with your authorized representatives and other third parties to address anti-money laundering and know-your-customer requirements.

The Company also may disclose information about you (1) if the Company is required to do so by law or legal process (such as a court order or subpoena); (2) to law enforcement authorities or other government entities based on a lawful disclosure request; (3) to establish, exercise, or defend the Company’s legal rights; (4) when the Company believes disclosure is necessary or appropriate to prevent harm or financial loss; (5) in connection with an investigation of suspected or actual fraudulent or illegal activity; or (6) otherwise with your consent. The Company reserves the right to transfer Personal Information it has about you in the event of a potential or actual sale or transfer of all or a portion of the Company’s business or assets (including in the event of a merger, acquisition, joint venture, reorganization, divestiture, spin-off, dissolution, or liquidation).

Transfer of Personal Information Outside the EEA/UK

The Company may disclose Client Personal Information to other recipients located in countries outside of the EEA or the UK, including affiliates located in the United States, which may not have data privacy laws equivalent to those in the EEA or the UK.  Where we transfer Personal Information outside the EEA/UK, we will enter into a data transfer agreement with the recipient, seek assurances from the recipient that they have Binding Corporate Rules in place, or rely on a derogation such as, where the transfer is necessary for performance or a contract or the establishment or defense of legal claims). More details on the transfer mechanisms can be obtained using the contact details at the end of this Notice.

EU/ UK Data Subject Rights

Under applicable EU/UK data privacy laws, Clients may have a right to: (i) request access to and rectification or erasure of their Personal Information; (ii) obtain restriction of processing or object to processing of their Personal Information; and (iii) ask for a copy of their Personal Information to be provided to them, or to a third party, in a digital form. If you wish to exercise any of these rights you should contact investor.relations@millburn.com. Clients also have the right to lodge a complaint about the processing of their Personal Information with their local data protection authority.

Updates

This notice and the policies described in this notice may be updated periodically and without prior notice to you to reflect changes in Company’s privacy practices or in applicable law, rules, or regulations. The date as of which this notice was last updated appears at the beginning of the notice.

Contact Us

If there are any questions regarding this Notice or to request a copy of this Notice in another format you may contact us using the information below.

investor.relations@millburn.com

+1 855 802 8241

Millburn Ridgefield Corporation

55 West 46th Street, 31st Floor

New York, NY  10036