Your privacy is very important to us. This notice (this “Privacy Notice”) is provided by Glazer Capital, LLC (“Glazer Capital” or the “Investment Manager”) on behalf of each investment account or pooled investment vehicle advised or managed by the Investment Manager (each a “Fund”, and together with the Investment Manager, “we” or “us”), and sets forth the policies of the Investment Manager and the Funds for the collection, use, storage, sharing and disclosure (collectively, “processing”) and the protection of personal information, including, but not limited to, personal information collected through glazercapital.com (the “Site”). This Privacy Notice is being provided in accordance with the requirements of data privacy laws applicable to the Investment Manager and the Funds (“Data Protection Law”).

If you are a California resident, please review our California Privacy Notice.

1. The Types of Personal Information We May Collect and Use

The categories of personal information we collect from you may include names, residential or business addresses or other contact details, signature, nationality, tax identification or passport number, date of birth, place of birth, photographs, copies of identification documents, bank account details, information about assets or net worth, credit history, source of funds details or other sensitive information, such as certain special categories of personal information (including, where relevant, information on political affiliations, ethnic origin, or criminal convictions), as specified under the applicable Data Protection Law.

2. How We Collect Personal Information

We may collect your personal information through: (i) information provided directly to us by you via your communications with us, or another person on your behalf; (ii) information that we obtain in relation to any transactions between you and us by observing your actions on our Site; and (iii) recording and monitoring of telephone conversations and electronic communications with you as described below.

We also may receive personal information about you from third parties or other sources, such as our affiliates, the administrator of our Funds, banks, brokers, auditors, law firms, consultants, employment agencies, publicly accessible databases or registers, tax authorities, governmental agencies and supervisory authorities, credit agencies, fraud prevention and detection agencies, or other publicly accessible sources, such as the Internet.

3. How We Use Your Personal Information

We may process your personal information for the purposes of administering the relationship between you and us (including communications and reporting), direct marketing of our products and services, and for business purposes, including: performing services (for us or our service provider or contractor) such as account servicing, processing orders and payments, and analytics; auditing related to our interactions with you; monitoring and analyzing our activities; internal operations; monitoring and improving the Site; providing account maintenance, and complying with applicable legal or regulatory requirements (including anti-money laundering, fraud prevention and investigation; tax reporting; sanctions compliance; preventing, investigating and detecting security incidents; responding to requests for information from law enforcement agencies or supervisory authorities); and short-term, transient use, such that the personal information is not disclosed to another third party and is not used to build a profile about you. Where applicable, certain of these processing activities may be carried out using artificial intelligence (AI) systems and tools as described in Section 4 below.

Your personal information will be processed in accordance with Data Protection Law and may be processed with your consent, upon your instruction, or for any of the purposes set out herein, including where we or a third-party consider there to be any other lawful purpose to do so.

Where there is suspicion of unlawful activity, failure to provide personal information may result in the submission of a report to the relevant law enforcement agency or supervisory authority.

4. How We Use Artificial Intelligence

We use AI systems and tools to support and improve certain aspects of our business. While most of our AI use does not involve processing personal information, we may do so for certain purposes, subject to applicable law, including:

• analysis of information collected as described in this Privacy Notice, including information collected automatically through use of the Site;
• supporting our recruitment and/or business processes; and
• administration, such as transcribing or summarizing audio from meetings and conference calls.

Such information may only be processed by AI tools under enterprise-level agreements that include appropriate data protection commitments, including restrictions on the use of the information to train AI models. We do not use AI for automated decision-making that produces legal or similarly significant effects.  We maintain an internal approval process for the implementation of AI systems and have policies governing employee use of AI tools.

5. How We May Share Your Personal Information

We may disclose personal information to our affiliates, service providers or other third parties, including but not limited to, administrators, banks, brokers, auditors, law firms, consultants, credit agencies, business partners, for our everyday business purposes, such as administration of our business, record-keeping, maintaining security of our information technology systems, reporting and monitoring of our activities, investor or law enforcement authorities to comply with applicable legal or regulatory requirements, respond to court orders, or in the context of regulatory requests for information, administrative proceedings, or investigations. Where personal information is shared with third-party AI service providers, such providers are contractually required to use that information solely for the purposes for which it was shared and are prohibited from using it for their own purposes, including AI model training. We will also release personal information about you if you, or your agents, authorize us to do so in connection with services we provide to you. We may share your personal information with our affiliates for direct marketing purposes, such as offers of products and services to you by us or our affiliates. You may prevent this type of sharing by contacting us at compliance@glazercapital.com. When you are no longer our customer or otherwise a user of our services, we may continue to share your personal information with our affiliates for such purposes. We may also disclose information about your experiences with us to our affiliates for their everyday business purposes. We do not permit non-affiliates with whom we share personal information to market their own services to you.

6. Retention Periods and Security Measures

We will not retain personal information for longer than is necessary in relation to the purpose for which it is collected, subject to applicable Data Protection Law. If you are an investor in a Fund, personal information will be retained for the duration of your investment in the Fund and for a minimum period of five to seven years after a redemption or withdrawal, as applicable, of your investment or liquidation of the Fund. We may retain personal information for a longer period for the purpose of marketing our products and services or compliance with applicable law. From time to time, we will review the purpose for which personal information has been collected and decide whether to retain it or to delete if it no longer serves any purpose to us.

7. International Transfers

Due to the international nature of our business, your personal information may be transferred to countries outside the United Kingdom and the European Economic Area (“Third Countries”), such as to jurisdictions where we conduct business or have a service provider, including countries that may not have the same level of data protection as that afforded by the EU General Data Protection Regulation (Regulation (EU) 2016/679), including equivalent legislation in effect in the United Kingdom (“GDPR”) or the Data Protection (Bailwick of Guernsey) Law 2017 (“Guernsey DPL”). In such cases, we will process personal information (or procure that it be processed) in the Third Countries in accordance with the requirements of the GDPR, which may include having appropriate contractual undertakings in legal agreements with service providers who process personal information on our behalf in such Third Countries. We may also be required to transfer your personal information to our regulators or government agencies in Third Countries in cases where such transfers are necessary in the context of administrative proceedings, such as requests for information, examinations or investigations, or to other relevant parties in Third Countries where it is necessary for the purposes of establishing, bringing, or defending legal claims, or for another legitimate business purpose, such as compliance with our legal or regulatory obligations under foreign law.

8. Your Rights Under Data Protection Law

You may have certain rights under the GDPR and Guernsey DPL in relation to our processing of your personal information and any processing carried out on your behalf. These rights include: (i) the right to request access to your personal information; (ii) the right to request rectification of your personal information; (iii) the right to request erasure of your personal information (the “right to be forgotten”); (iv) the right to restrict our processing or use of your personal information; (v) the right to object to our processing or use where we have considered this to be necessary for our legitimate interests (such as in the case of our marketing activities); (vi) where relevant, the right to request the portability of the data; (vii) if your consent to processing has been obtained, the right to withdraw your consent at any time; and (viii) the right to lodge a complaint with a supervisory authority. Please note that the right to be forgotten that applies in certain circumstances under the GDPR and Guernsey DPL is not likely to be available in respect of the personal information we hold, given the purpose for which we collect such data, as described above.

You may contact us at any time to limit our sharing of your personal information. If you limit sharing for an account you hold jointly with someone else, your choices will apply to everyone on your account. U.S. state laws may give you additional rights to limit sharing.

9. Cookies

We may send text files (e.g., “cookies” or other cached files) or images to your web browser to store information on your computer. Such text files and images are used for technical convenience to store information on your computer. For instance, we may use a session cookie to store form information that you have entered so that you do not have to enter such information again. We may use information stored in such text files and this Site. You can disable cookies from your computer system by following the instructions on your browser.

This Site uses Google Analytics cookies, a web analytics service provided by Google, which sets a cookie in order to understand how you use and interact with this Site and to compile meaningful Site traffic reports. More information on how Google Analytics uses cookies can be found at https://google.com/analytics.

10. Who to Contact About This Privacy Notice

Please contact Glazer Capital by telephone at (212) 808-7304, by email at compliance@glazercapital.com  or by writing to 250 West 55th Street, Suite 30A, New York, NY 10019 for any questions about this Privacy Notice or requests with regards to our handling of personal information.

Privacy Notice For California Consumers

This notice contains disclosures required by the California Privacy Rights Act (“CPRA”). Terms defined in the CPRA have the same meaning when used in this notice. This notice is only relevant to California residents (“consumers” or “you”), who may include the following: prospective investors, representatives of entities we do business with, employees/job applicants, and users of our website. Consumers with disabilities may access this notice by contacting Glazer Capital by telephone at (212) 808-7304, by email at compliance@glazercapital.com or by writing to 250 West 55th Street, Suite 30A, New York, NY 10019 to request a copy of this notice in an alternative format, such as a .pdf version of this notice that is compatible with character recognition software.

Information We Collect. Through your interaction with us, we may collect and share for a business purpose the following categories of personal information (“Personal Information”) about California consumers:

Personal Information does not include information that is publicly available, de-identified/ aggregated, or subject to HIPAA or GLBA.

We collect Personal Information from the sources provided in Section 2 of the general Privacy Notice above.

We do not knowingly collect, solicit or sell Personal Information from anyone under the age of 16 without the prior consent of a parent or guardian.

Use of Personal Information. We may use the Personal Information we collect as provided in Section 3 of the general Privacy Notice above.

Sharing Personal Information. We may disclose Personal Information as provided in Section 4 of the general Privacy Notice above.

We have not sold Personal Information to third parties, and we have shared the categories of personal information we collect only as set forth above.

Purpose of Personal Information Collection.  We use Personal Information for the business and commercial purposes disclosed under the “How We Use Your Personal Information” section of the Privacy Policy.

Retention Period and Criteria. We will keep your Personal Information for as long as necessary to comply with our regulatory obligations.

We retain personal information that we determine is necessary for: (i) providing the investment advisory services requested by clients and managing our continuing contractual rights and obligations; (ii) compliance with applicable law, rule, or regulation, including Rule 204-2 under the Investment Advisers Act of 1940, as amended; (iii) anti-money laundering, customer identification, and fraud prevention and detection purposes; (iv) the establishment, exercise, or defense of legal rights or claims; (v) responding to legal or regulatory requests or inquiries; (vi) internal business purposes, including auditing, risk management, and business continuity; and (vii) tax reporting and other financial recordkeeping obligations. We anticipate that we will need to retain personal information through the period of your relationship with us, consistent with and proportional to our business record retention requirements.

Rights of California Consumers. The CPRA provides a California consumer the following rights, subject to certain exceptions and limitations:

• The right to request: (a) the categories and specific pieces of Personal Information we collect about you; (b) the categories of sources from which we collect your Personal Information; (c) our purposes for collecting, selling or sharing your Personal Information; (d) the categories of Personal Information disclosed for a business purpose and the categories of persons to whom it was disclosed; (e) the categories of your Personal Information (if any) that we have either sold, shared, or disclosed.
• For certain categories of Personal Information, the right to request a list of what we disclosed to third parties for their own direct marketing purposes and the names and addresses of those third parties.
• The right to request that we delete your Personal Information, subject to certain exceptions.
• The right to opt out of our sale(s) or sharing (if any) of your Personal Information.
• The right to request we correct any inaccurate Personal Information maintained about you.
• The right to opt-out of certain uses or limit our use of your sensitive personal information to only use that is necessary to perform the services expected or provide the goods reasonably expected.
• The right to opt-out of sale or sharing of your personal information by us by turning on a recognized opt-out preference signal, such as Global Privacy Control, in your browser or extension. Please note that when you submit an opt-out through this method we do not know who you are within our systems, and your opt-out will apply only to information collected from tracking technologies on the specific browser from which you opt-out. If you delete or reset your cookies, or use a different browser or device, you will need to reconfigure your settings.
• The right not to receive discriminatory treatment for exercising your CPRA rights.

You may submit requests relating to your CPRA rights to us via:

phone (212) 808-7304; or email compliance@glazercapital.com with the phrase “California Consumer Rights” in the subject line.

You may only make a verifiable request for access or data portability twice within a 12-month period, for information collected on or after January 1, 2022. All verifiable requests must provide (1) enough information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative and (2) sufficient detail that allows us to properly evaluate and respond to it.

We endeavor to respond to a verifiable request within 45 days of its receipt. If we require more time, we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option.

You may designate an authorized agent to make a CPRA request on your behalf. In such case, we will ask the agent to provide proof that you have given the agent signed permission to act on your behalf. In addition, we will ask you to (1) verify your identity directly with us in the manner described above and (2) directly confirm with us that you have provided the agent permission to make the request on your behalf.

Questions

Please contact Glazer Capital by telephone at (212) 808-7304, by email at compliance@glazercapital.com or by writing to 250 West 55th Street, Suite 30A, New York, NY 10019 for any questions about this Notice or requests with regards to our handling of personal information.