Privacy Policy

Huck Capital Management, LLC and its affiliates (collectively, “Huck Capital,” “we,” or “us”) want you to be familiar with how we collect, use and disclose information. In addition to the privacy notice(s) in any fund subscription materials that we may send to you (the terms of which take precedence in the event of any contradictions with this Privacy Policy), this Privacy Policy describes our practices in connection with information that we collect through:

• Websites operated by us that link to this Privacy Policy (the “Sites”);
• Our social media pages located here (collectively, our “Social Media Pages”);
• HTML-formatted email messages that we send to you that link to this Privacy Policy or other communications with you; and
• Offline business interactions you have with us.

Collectively, we refer to the Sites, Social Media Pages, emails, and offline business interactions as the “Offerings."

Personal Information

“Personal Information” is information that identifies you as an individual or relates to an identifiable individual. The Offerings collect Personal Information, including:

• Name
• Address
• Date of birth
• Telephone number
• Email address
• IP address (we may also derive your approximate location from your IP address)
• Employer and employment-related information
• Government-issued identification or similar proof of identity
• Financial information, including information regarding one or more of your bank accounts
• Tax information, including taxpayer identification number and jurisdiction of tax residence
• Investment-related information

Collection of Personal Information

We and our service providers collect Personal Information in a variety of ways, including:

• Through the Offerings.
  We collect Personal Information through the Offerings, for example, when you submit documents for purposes of subscribing to our fund(s), register an account to access the Offerings, or contact us (including offline, e.g., when you visit our offices, over the phone).
• From Other Sources.
  We receive your Personal Information from other sources, for example:
  - publicly available databases;
  - joint marketing partners, when they share the information with us.

We need to collect Personal Information in order to provide the requested Offerings to you. If you do not provide the information requested, we may not be able to provide the Offerings. If you disclose any Personal Information relating to other people to us or to our service providers in connection with the Offerings, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

Use of Personal Information

We and our service providers use Personal Information for the following purposes:‍

• ‍Providing the functionality of the Offerings and fulfilling your requests.
  - To complete your transactions (including subscribing to our fund(s)), verify your information, and provide you with related customer service.
  - To respond to your inquiries and fulfill your requests, for example, when you send us questions, suggestions, compliments or complaints, or when you request information about our Offerings.
  - To send administrative information to you, such as changes to our terms, conditions, and policies.
  - To provide the Sites’ functionality to you, such as arranging access to your registered account and providing you with related customer service.

We will engage in these activities to manage our contractual relationship with you and/or to comply with a legal obligation.

• ‍Providing you with our newsletter and/or other marketing materials.
  - To send you marketing-related emails, with information about our services, new products and other news about our company.

We will engage in this activity with your consent or where we have a legitimate interest.

• Aggregating and/or anonymizing Personal Information.
  - We may aggregate and/or anonymize Personal Information so that it will no longer be considered Personal Information. We do so to generate other data for our use, which we may use and disclose for any purpose, as it no longer identifies you or any other individual.

• Accomplishing our business purposes.
  - For data analysis, for example, to improve the efficiency of our Offerings;
  - For audits, to verify that our internal processes function as intended and to address legal, regulatory, or contractual requirements;
  - For fraud and security monitoring purposes, for example, to detect and prevent cyberattacks or attempts to commit identity theft;
  - For developing new products and services;
  - For enhancing, improving, or modifying our current products and services, as well as undertaking quality and safety assurance measures;
  - For identifying usage trends, for example, understanding which parts of our Sites are of most interest to users;
  - For determining the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users; and
  - For operating and expanding our business activities, for example, understanding which parts of our Offerings are of most interest to our users so we can focus our energies on meeting our users’ interests.

We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or based on our legitimate interest

Disclosure of Personal Information

We disclose Personal Information:

• To our affiliates for the purposes described in this Privacy Policy.
• To our third party service providers, to facilitate services they provide to us.
  - These can include providers of services such as website hosting, data analysis, information technology and related infrastructure provision, customer service, email delivery, auditing, marketing, and other services.

Other Uses and Disclosures

We also use and disclose your Personal Information as necessary or appropriate, in particular when we have a legal obligation or legitimate interest to do so:

• To comply with applicable law and regulations.
  - This may include laws outside your country of residence.
• To cooperate with public and government authorities.
  - To respond to a request or to provide information we believe is necessary or appropriate.
  - These can include authorities outside your country of residence.
• To cooperate with law enforcement.
  - For example, when we respond to law enforcement requests and orders or provide information we believe is important.
• For other legal reasons.
  - To enforce our terms and conditions; and
  - To protect our rights, privacy, safety or property, and/or that of our affiliates, you or others.
• In connection with a sale or business transaction.
  - We have a legitimate interest in disclosing or transferring your Personal Information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).

Other Information

“Other Information” is any information that does not reveal your specific identity or does not directly relate to an identifiable individual. The Offerings collect Other Information such as:

• Browser and device information
• Information collected through cookies, pixel tags and other technologies
• Demographic information and other information provided by you that does not reveal your specific identity
• Information that has been aggregated in a manner such that it no longer reveals your specific identity

Collection of Other Information

We and our service providers may collect Other Information in a variety of ways, including:‍

• ‍Your browser or device.
  - Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version and the name and version of the Sites you are using. We use this information to ensure that the Sites function properly.

• ‍Cookies.
  - Cookies are pieces of information stored directly on the computer that you are using. Cookies allow us to collect information such as browser type, time spent on the Sites, pages visited, language preferences, and other traffic data. We and our service providers use the information for security purposes, to facilitate navigation, to display information more effectively, and to personalize your experience. We also gather statistical information about use of the Sites in order to continually improve their design and functionality, understand how they are used, and assist us with resolving questions regarding them. We do not currently respond to browser do-not-track signals. If you do not want information collected through the use of cookies, most browsers allow you to automatically decline cookies or be given the choice of declining or accepting a particular cookie (or cookies) from a particular website. You may also wish to refer this website for more information. If, however, you do not accept cookies, you may experience some inconvenience in your use of the Sites.
• ‍Pixel tags and other similar technologies.
  - Pixel tags. Pixel tags (also known as web beacons and clear GIFs) may be used to, among other things, track the actions of users of the Sites (including email recipients), measure the success of our marketing campaigns, and compile statistics about usage of the Sites and response rates.
  - Analytics. We use Google Analytics, which uses cookies and similar technologies to collect and analyze information about use of the Sites and report on activities and trends. This service may also collect information regarding the use of other websites, apps and online resources. You can learn about Google’s practices by going here, and exercise the opt-out provided by Google by downloading the Google Analytics opt-out browser add-on, available here.

Uses and Disclosures of Other Information

We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as Personal Information under applicable law, we may use and disclose it for the purposes for which we use and disclose Personal Information as detailed in this Privacy Policy. In some instances, we may combine Other Information with Personal Information. If we do, we will treat the combined information as Personal Information as long as it is combined.

Security

We seek to use reasonable organizational, technical and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contacting Us” section below.

Choices and Access

Your choices regarding our use and disclosure of your Personal Information

We give you choices regarding our use and disclosure of your Personal Information for marketing purposes. You may opt out from:

1. Receiving marketing-related emails from us. If you no longer want to receive marketing related emails from us on a going-forward basis, you may opt out by: clicking on unsubscribe on the bottom of the email.

We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt out of receiving marketing related emails from us, we may still send you important administrative messages, from which you cannot opt out.

How you can access, change, or delete your Personal Information

If you would like to request to access, correct, update, suppress, restrict, or delete Personal Information, object to or opt out of the processing of Personal Information, or if you would like to request to receive a copy of your Personal Information for purposes of transmitting it to another company (to the extent these rights are provided to you by applicable law), you may contact us in accordance with the “Contacting Us” section below. We will respond to your request consistent with applicable law. If you are a California resident, please refer to the “Additional Information Regarding California” section at the end of this Policy for more information about the requests you may make under the California Consumer Privacy Act.

In your request, please make clear what Personal Information you would like to have changed or whether you would like to have your Personal Information suppressed from our database. For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.

Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion (e.g., when you initiate a transaction with us, such as subscribing to one of our funds, you may not be able to change or delete the Personal Information provided until after the completion of such transaction).

Retention Period

We retain Personal Information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law.

The criteria used to determine our retention periods include:

• The length of time we have an ongoing relationship with you and provide the Offerings to you (for example, for as long as you have an account with us or are an investor in one of our funds);
• A reasonable period of time after our relationship with you ends;
• Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
• Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

Third Party Services

This Privacy Policy does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third party operating any website or service to which the Offerings link. The inclusion of a link on the Offerings does not imply endorsement of the linked site or service by us or by our affiliates.

In addition, we are not responsible for the information collection, use, disclosure, or security policies or practices of other organizations, such as LinkedIn, Apple, Google or any other social media platform provider or operating system provider, including with respect to any Personal Information you disclose to other organizations through or in connection with our Social Media Pages.

Use of offerings by Minors

The Offerings are not directed to individuals under the age of eighteen (18), and we do not knowingly collect Personal Information from individuals under 18.

Jurisdiction and Cross-Border Transfer

Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Offerings you understand that your information will be transferred to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country.

ADDITIONAL INFORMATION REGARDING THE EEA: Some non-EEA countries are recognized by the European Commission as providing an adequate level of data protection according to EEA standards (the full list of these countries is available here). For transfers by Huck Capital from the EEA to countries not considered adequate by the European Commission, we have put in place adequate measures, such as standard contractual clauses adopted by the European Commission to protect your Personal Information. You may obtain a copy of these measures by contacting us in accordance with the “Contact Us” section below.

SENSITIVE INFORMATION

Unless we request it, we ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background, or trade union membership) on or through the Offerings or otherwise to us.

Updates to this privacy policy

The “LAST UPDATED” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised. Any changes will become effective when we post the revised Privacy Policy on the Offerings.

Contacting Us

Huck Capital Management, LLC, located at 500 Sansome St, San Francisco, CA 94111, is the company responsible for collection, use, and disclosure of your Personal Information under this Privacy Policy. If you have any questions about this Privacy Policy, please contact us at info@huckcapital.com or:

500 Sansome St., San Francisco, CA 94111
415-773-0388

Because email communications are not always secure, please do not include sensitive information in your emails to us.

Additional Information Regarding the EEA

You may also:

• Lodge a complaint with an EU/EEA data protection authority for your country or region where you have your habitual residence or place of work or where an alleged infringement of applicable data protection law occurs.

Additional Information Regarding California

Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), we are providing the following additional details regarding the categories of Personal Information about California residents that we have collected or disclosed within the preceding 12 months:

1. We collected the following categories of Personal Information:
   A. Identifiers, such as name, contact information, online identifiers, Social Security numbers and other government ID numbers;
   B. Personal information, as defined in the California customer records law, such as name, contact information, signature, government ID numbers, medical, health insurance and physical characteristics, insurance and financial account information, and education and employment information;
   C. Commercial information, such as transaction information and transaction history;
   D. Internet or network activity information, such as browsing history and interactions with our website;

As described above, we may use this Personal Information to operate, manage, and maintain our business, to provide our products and services, for our employment and vendor management purposes, and to accomplish our business purposes and objectives, including, for example, using Personal Information to: develop, improve, repair, and maintain our products and services; personalize, advertise, and market our products and services; conduct research, analytics, and data analysis; maintain our facilities and infrastructure; undertake quality and safety assurance measures; conduct risk and security control and monitoring; detect and prevent fraud; perform identity verification; perform accounting, audit, and other internal functions, such as internal investigations; comply with law, legal process, and internal policies; maintain records; and exercise and defend legal claims.

If you are a California resident, you may request that we:

1. Disclose to you the following information covering the 12 months preceding your request:
   - The categories of Personal Information we collected about you and the categories of sources from which we collected such Personal Information;
   - The specific pieces of Personal Information we collected about you;
   - The business or commercial purpose for collecting (if applicable) Personal Information about you; and
   - The categories of Personal Information about you that we otherwise shared or disclosed, and the categories of third parties with whom we shared or to whom we disclosed such Personal Information (if applicable).
2. Delete Personal Information we collected from you.

To make a request for the disclosures or deletion described above, please contact us in accordance with the “Contacting Us” section above. In some instances, we may decline to honor your request where an exception applies, such as where the disclosure of Personal Information would adversely affect the rights and freedoms of another California resident.

You have the right to be free from unlawful discrimination for exercising your rights under the CCPA.