INTRODUCTION

This Privacy Policy describes the information that we gather on, or through, in respect of Investment Management and Advisory services (the “Services”) and how we use and process such information. For each processing purpose we will articulate the reason for requiring the data, what data we will process, the legal basis for processing the data and how long we will keep the data.

Where the legal basis of consent is to be used, this will be gathered freely, and we will use clear, plain language that is easy to understand, and you will be able to remove your consent at any point.

References to “BCI” or “us” or “we” or “our” are references to BCI Capital Limited, 58 Wood Lane, London, W12 7RZ. References to “you” are references to you as the user of our Investment Management and Advisory services (our “Services”).

BCI respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data and tell you about your privacy rights.

Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.

CONTENTS:

1. IMPORTANT INFORMATION AND WHO WE ARE

2. THE DATA WE COLLECT ABOUT YOU

3. HOW IS YOUR PERSONAL DATA COLLECTED

4. HOW WE USE YOUR PERSONAL DATA

5. DISCLOSURES OF YOUR PERSONAL DATA

6. INTERNATIONAL TRANSFERS

7. DATA SECURITY

8. DATA RETENTION

9. YOUR LEGAL RIGHTS

10. GLOSSARY

1. IMPORTANT INFORMATION AND WHO WE ARE

PURPOSE OF THIS PRIVACY POLICY

This privacy policy aims to give you information on how BCI collects and processes your personal data, including any data you may provide when you sign up to our distribution lists, register to use our products and services, complete any investment subscription or application forms, or respond to request for due diligence.

The Product is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy notice or fair processing notice.  We may provide these on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements the other notices and is not intended to override them.

CONTROLLER

BCI will collect personal data, primarily for the purpose of providing Services to the BCI Credit Opportunities Fund, or other investment vehicles (the “Investment Vehicles”). BCI as the controller is responsible for your personal data.  The Investment Vehicles are also considered Data Controllers in respect of the personal data that they hold or which is held on their behalf.

This policy shall apply to personal information collected in relation to Services provided to the Investment Vehicles, including personal information collected from:

• Investors and prospective investors in the Investment Vehicles;

• Counterparties and service providers of BCI, its affiliates, and the Investment Vehicles;

• Prospective investment counterparties, including lenders and borrowers, and other financing parties;

• Other persons who may from time to time be asked provide personal data, in relation and legitimate business relationship;

• Affiliates of any of the above.

This notice is intended to cover all of the Funds or entities to which BCI Capital Limited is or will become the Manager. This includes but is not limited to the BCI Credit Opportunities Fund.

CONTACT DETAILS

Full name of legal entity: BCI Capital Limited

Email address: dp@www.bci-capital.com

Postal address: Scale Space, 58 Wood Lane, London, W12 7RZ

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

This version was last updated in July 2024 and historic versions can be obtained by contacting us.

We may change or update this Privacy Policy at any point so that it accurately reflects our Services, if we believe it does not fundamentally change your data privacy rights. If we believe your rights have been affected we will contact Users 30 days before we implement the change. If you continue to use the Service once the Privacy Policy has been updated or amended, you will be bound by the updated Privacy Policy. If you do not want to agree to any updated or amended Privacy Policy, you can submit a deletion request.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us including but not limited to, name , address , contract details.

THIRD-PARTY LINKS

The Service may include links to third-party websites. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

2. THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, place of birth, passport of other ID number, nationality, residency and gender.

• Contact Data includes billing address, delivery address, email address and telephone numbers.

• Qualifications and financial standing data includes qualifications, details of current and historical employment, source of wealth and source of investment funds, details of other investments made.

• Financial Data includes bank account details.

• Transaction Data includes details about payments to and from you and other details of products and services you have engaged with us.

• Technical Data includes your login data and other technology on the devices you use to access this website.

• Profile Data includes your username and password, investments or subscriptions made by you, your interests, preferences, feedback and survey responses.

• Usage Data includes information about how you use our website, products and services.

• Marketing and Communications Data includes your preferences in receiving communications from us and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences unless this is in respect of Anti Money Laundering.

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

3. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

• Direct interactions: You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

• Complete and submit subscription or investment applications

• Complete of respond to due-diligence requests from either BCI or service providers of the Investment Entity

• Create an account on our Product;

• Subscribe to our service or investor updates;

• Request communication and performance updates to be sent to you;

• Discuss BCI’s products with a representative of BCI

• Give us some feedback.

Automated technologies or interactions: As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, SDKs and other similar technologies.

Third-parties or publicly available sources: When you choose to log in with a third-party provider, we will receive your email , name and other personal data submitted from such third-party in order to create your account with us.

4. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.

• Where it is necessary for our legitimate interests (or those of a third-party), and your interests and fundamental rights do not override those interests.

• Where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third- party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table overleaf.

MARKETING

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

PROMOTIONAL OFFERS FROM US

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you – this constitutes marketing.

You will receive marketing communications from us if you have requested information from us or have consented to at registration and, in each case, you have not opted out of receiving that marketing. Marketing from ourselves will only be directed to those individuals whom we believe are appropriate to receive such information.

THIRD-PARTY MARKETING

We will request your opt-in consent before we share your personal data for marketing purposes with any company outside of BCI Capital Limited for marketing purposes.

OPTING OUT

You can ask us or third parties to stop sending you marketing messages at any time by Contacting us.

Where you opt out of receiving marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

COOKIES

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

1. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below for the purposes set out in Table 1 above. Parties include:

• Internal Third Parties as set out in the Glossary.

• External Third Parties as set out in the Glossary.

• Financial Regulators, including the UK Financial Conduct Authority (“FCA”).The FCA may, from time to time, request information on our investors in order to review and test Anti-Money Laundering and Financial Crime controls and procedures. Both the FCA and Cayman Islands Monetary Authority (CIMA) have strong data protection policies and procedures and we are confident that your data would be safely and securely protected. As part of our regulatory requirements, we may be required to send your data to a regulatory body not listed above; in this case we will endeavour to inform you of this however due to the nature of the request this may not always be possible.

• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets, including the BCI Credit Opportunities Fund and any other vehicles under our control. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

2. INTERNATIONAL TRANSFERS

If you are a service user in the UK or the European Economic Area (EEA), the information you provide may be transferred to countries outside the UK or EEA that do not have similar protections in place regarding your data and restrictions on its use as set out in this policy. However, we will take steps to ensure adequate protections are in place to ensure the security of your information. The EEA comprises the EU member states plus Norway, Iceland and Liechtenstein. By submitting your information, you consent to these transfers for the purposes specified above.

We may transfer your personal information to our service providers located outside of the UK or EEA as specified in the list of Third Parties which can be found at the end of this Privacy Policy.

All of our International service providers have each provided the information to demonstrate they have appropriate technical