Privacy Policy

California Compliant

HSR Management, Inc. & Affiliates

Effective Date: February 2025

1. Our Commitment to Your Privacy

HSR Management, Inc. and its affiliates (“HSR,” “we,” “us,” or “our”) value the relationships we have built with our investors, clients, partners and website users (“you”). We are committed to protecting your personal information and maintaining transparency in how we collect, use, and share data. This Privacy Policy complies with the California Consumer Privacy Act (CCPA/CPRA) and the Colorado Privacy Act (CPA).

2. Categories of Personal Information We Collect

We may collect the following categories of personal information:

• Identifiers (name, address, email, phone, SSN, driver’s license)

• Sensitive personal information (SSN, financial account numbers)

• Customer Records (signature, contact info, account info)

• Commercial information (transaction history, holdings, investment activity)

• Internet/network activity (IP address, browsing behavior on our website)

• Professional information

• Information from custodians, administrators, transfer agents, and similar parties

We do not knowingly collect data from minors under 16.

3. Purposes for Collecting and Using Personal Information

We use personal information to:

• Service and maintain investment accounts

• Verify your identity

• Process transactions

• Comply with securities and financial laws

• Communicate with you

• Detect and prevent fraud

• Maintain website functionality and security

4. How We Share Personal Information

We do NOT sell personal information and do NOT share it for cross-context behavioral advertising.

We may disclose personal information to:

• Affiliated entities

• Service providers and contractors (IT, custodians, broker-dealers, registered investment advisors, transfer agents and fund administrators)

• Non-affiliated financial institutions assisting with account servicing

• Legal/regulatory authorities as required

All service providers are contractually restricted from using data for any unrelated purpose.

5. Your Rights Under California & Colorado Law

Depending on your state of residence, you may have:

• Right to Know / Access

• Right to Delete

• Right to Correct

• Right to Opt Out of sale/targeted advertising (not applicable—we do not engage in these)

• Right to Limit Use of Sensitive Personal Information

• Right to Appeal (Colorado residents)

6. How to Exercise Your Rights

You may submit requests via:

Phone: (310) 914-1410

Website: https://www.hsrm.com/

Email: privacy@hsrm.com (placeholder—update as needed)

Notice: We may need to verify your identity before fulfilling a request.

7. Data Security

We maintain physical, electronic, and procedural safeguards to protect personal information.

8. Data Retention

We retain data as required under federal securities law, tax rules, and other regulatory obligations.

9. Website & Web Portal Use

By using our website or portal, you consent to the practices described in this Privacy Policy. Third-party websites linked from our website are not governed by this Policy.

10. Updates to This Policy

We may revise this Privacy Policy. Continued use of our services indicates your acceptance of any updates.

11. Contact Us

HSR Management, Inc.

(310) 914-1410

https://www.hsrm.com/

___________________________________________________________________________________________________________________

Colorado Compliant

HSR Management, Inc. & Affiliates

Effective Date: February 2025

This Colorado Privacy Supplement applies to individuals who are residents of the State of Colorado and supplements the HSR Management, Inc. Privacy Policy. It is provided in accordance with the Colorado Privacy Act (CPA) and governs personal data processed by HSR Management, Inc. and its affiliates (“HSR,” “we,” “us,” or “our”) when acting as a controller of personal data of Colorado residents.

1. Personal Data We Collect About Colorado Residents

We may collect the following categories of personal data from Colorado residents:

• Personal Data (identifiers, financial information, transaction history, online activity, professional information)

• Sensitive Data (SSN, financial account numbers—processed only as required for financial services)

2. How We Use and Process Personal Data

We use personal data for account servicing, compliance, identity verification, communication, fraud prevention, internal business operations, and website functionality.

3. How We Share Personal Data

We share personal data only with:

• Service providers (account administrators, custodians, transfer agents, IT vendors)

• Affiliates

• Legal/regulatory authorities

We do not sell personal data, share it for targeted advertising, or use it for profiling that produces legal or significant effects.

4. Your Rights Under the Colorado Privacy Act

Colorado residents have the right to:

• Access

• Correct

• Delete

• Data Portability

• Opt Out (sale, targeted advertising, profiling—none applicable)

• Appeal a denied request

5. How to Exercise Your Rights

Requests may be made via:

Phone (310) 914-1410

Website: https://www.hsrm.com/

Email: privacy@hsrm.com

6. Data Retention

We retain personal data as required by securities laws, tax rules, and regulatory requirements.

7. Updates

We may update this supplement as required by law.

8. Contact Us

HSR Management, Inc.

(310) 914-1410

https://www.hsrm.com/