Privacy Policy 

BCM Global Privacy Policy 

Effective Date: February 21, 2020 

Last Updated: May 2026 

At BCM Capital Management and its affiliated entities (collectively referred to as “BCM”), we value and respect your privacy. This Global Privacy Policy explains the kinds of personal information we collect, how that information is used, who it may be shared with, and the choices available to you regarding the use of your information. It also outlines the steps we take to safeguard your data and how you can reach us with any questions regarding our privacy practices.

For the purposes of data protection laws within the European Union (“EU”), the United Kingdom (“UK”), and Switzerland, BCM serves as the data controller of your personal information.

This Global Privacy Policy applies to BCM’s handling of personal information both online and offline. It covers information collected through BCM’s websites listed in Appendix A of this Privacy Policy or through (collectively referred to as the “Sites”), as well as our general offline privacy practices, unless a separate privacy policy specifically applies.

Because BCM operates across multiple countries and jurisdictions, our privacy practices may differ where necessary to comply with local laws, regulations, and customary practices.

Information We Collect

We may collect personal information about you through different channels, including our Sites, subscription forms, application documents, and other records submitted by you or on your behalf.

The types of personal information we may gather include:

. Identification details and contact information, such as your full name, mailing address, email address, phone number, Social Security number, tax identification number, government-issued identification details, as well as your date and place of birth;

. Professional and employment-related information, including your company or institution, occupation, job title, or professional role;

. Internet activity and electronic network information, along with details used to create and manage your online account, such as usernames and passwords;

. Commercial records and transaction-related information involving BCM, our funds, affiliated entities, or other related parties; and

. Any additional personal information you voluntarily provide through meetings, phone discussions, emails, submitted forms, documents, or through interactions on our Sites.

Information Collected Through Automated Technologies

When you access our Sites, open emails from BCM, or interact with BCM-related tools, plug-ins, or widgets, we may automatically collect certain information through technologies such as cookies, web server logs, web beacons, and JavaScript.

A cookie is a small text file sent by a website to your computer or internet-connected device to help recognize your browser or store certain settings and preferences. A web beacon—sometimes referred to as an internet tag, pixel tag, or clear GIF—is a technology that connects web pages or applications to web servers and may be used to send information back to the server.

The information collected through these automated methods may include:

. IP addresses

. Unique device identifiers

. Browser type and operating system details

. Device specifications and characteristics

. Language preferences

. Clickstream and browsing behavior data

. Referring and exit URLs

. User actions taken on the Sites

. Dates and times of activity

. Other technical and usage-related information

We use these technologies to help us:

. Save your preferences so you do not need to re-enter information repeatedly;

. Monitor and better understand how users interact with our products, services, and Sites;

. Personalize our products, services, and website experience based on your preferences;

. Evaluate the performance and usability of our Sites and the effectiveness of our communications;

. Deliver advertising and content that is more relevant to your interests; and

. Improve, manage, and enhance our products, services, and overall digital experience.

How We Use the Information We Collect

We may use and process the personal information we collect in order to fulfill our contractual obligations with you or to take necessary steps before entering into a contract with you. This may include:

. Providing, operating, and managing our products, services, and Sites;

. Creating, maintaining, and administering accounts you hold with BCM or with one of our funds.

We may also process your personal information where necessary to support our legitimate business interests, including managing client relationships, maintaining the security of our Sites, and operating our business and recruitment processes efficiently.

Examples of how we use your personal information include:

. Communicating with you and responding to your questions or requests;

. Managing and maintaining your accounts and relationship with BCM;

. Reviewing, handling, and resolving complaints or concerns;

. Sending newsletters, promotional content, marketing materials, and other business communications;

. Managing career opportunities and recruitment processes, including reviewing job applications, conducting background checks where permitted by law, employee onboarding, and other human resources functions;

. Carrying out data analysis, including customer insights and market research;

. Developing, improving, and managing our business operations, products, services, and Sites, such as enhancing user experience, launching new services, evaluating marketing performance, handling communications, and conducting accounting, billing, auditing, and reconciliation activities;

. Detecting, preventing, and addressing fraud, unauthorized access, copyright violations, misuse of protected content, and other unlawful activities, claims, or liabilities;

. Responding to legal, compliance, and regulatory obligations or official requests; and

. Fulfilling any other purposes required, permitted, or authorized by applicable law, including legitimate business interests pursued by BCM. 

Information We Share

We do not sell your personal information, and we only disclose personal information as outlined in this Privacy Policy.

Your personal information may be shared with our affiliated companies for the purposes described in this Global Privacy Policy. We may also share your information with trusted service providers, subcontractors, and agents who perform services on our behalf and under our instructions. These parties are not permitted to use or disclose your information for any purpose other than providing services to BCM or meeting legal and regulatory obligations.

Examples of these service providers include fund administrators, website hosting providers, marketing and analytics partners, and other information technology service providers. We may also disclose your information to your authorized representatives where appropriate.

For current and former investors, personal information may also be disclosed:

1. To non-affiliated third parties and BCM affiliates for standard business operations, such as processing transactions, maintaining accounts, complying with court orders, handling legal investigations, reporting to credit bureaus, and supporting other normal activities related to BCM-managed investment partnerships;

2. To transfer agents, brokerage firms, portfolio investments, and similar entities in connection with investment transactions, acquisitions, or disposals;

3. To actual or prospective portfolio companies, potential co-investors, and their respective advisors when necessary to complete, manage, or support a proposed or completed investment or disposition.

We may also share your personal information with our professional advisors, including legal counsel, accountants, and other consultants where necessary.

In addition, we may disclose your information under the following circumstances:

. When required by law, legal process, court order, or subpoena;

. In response to lawful requests from law enforcement agencies or government authorities;

. To establish, protect, or defend our legal rights;

. When disclosure is necessary to prevent fraud, financial loss, or potential harm;

. During investigations involving suspected or actual unlawful or fraudulent activities;

. With your consent where required or appropriate.

We also reserve the right to transfer your personal information in the event of a business transaction involving BCM, such as a merger, acquisition, joint venture, restructuring, sale of assets, reorganization, dissolution, or liquidation.

Where applicable law requires it, we will obtain your consent before disclosing your personal information.

Data Transfers

Your personal information may be transferred to and processed by recipients located in countries outside the country where the information was originally collected. These countries may have different data protection laws and privacy regulations than those in your home jurisdiction.

Where required by applicable law, when BCM transfers your personal information to recipients in other countries—such as the United States, the United Kingdom, Ireland, or the Cayman Islands—we take appropriate steps to ensure that your information remains protected in accordance with this Global Privacy Policy and applicable legal requirements.

Your Rights and Choices

We provide you with certain rights and options regarding the personal information we collect about you.

If you would like to update your communication preferences, request removal from our mailing lists, or submit a request relating to your personal information, you may contact us using the details provided in the How to Contact Us section of this Global Privacy Policy. You may also opt out of receiving marketing emails at any time by clicking the “Unsubscribe” link included in our email communications.

Subject to the laws applicable in your jurisdiction, you may have the right to:

1. Request access to the personal information we collect, store, and disclose about you;

2. Request that we correct, update, amend, delete, or restrict the use of your personal information;

3. Exercise your right to data portability, where applicable;

4. Withdraw your consent at any time where processing is based on consent;

5. Object to the processing of your personal information where legitimate grounds apply based on your specific circumstances.

Depending on your location, you may also have the right to submit a complaint to a government regulator, privacy commissioner, or data protection authority if you believe your privacy rights have not been handled properly or if you are dissatisfied with our response.

To protect your privacy and ensure security, we may request verification of your identity before processing certain requests related to your personal information.

Where permitted by applicable law, an administrative fee may apply before we provide you with copies of the personal information we maintain about you.

How We Protect Personal Information

We implement appropriate security measures and safeguards to help protect the personal information we collect against unauthorized access, unlawful use, disclosure, loss, alteration, destruction, or accidental damage.

Retention of Personal Information

Where permitted by applicable law, we retain personal information for as long as it is necessary to fulfill the purposes for which it was collected, in line with this Global Privacy Policy. We may also retain personal information for longer periods where we have a lawful basis to do so, even after the original purpose for collection has been satisfied.

Children’s Personal Information

Our Sites are intended for a general audience and are not directed to individuals under the age of 18, or such other minimum age as may be required by applicable law in your jurisdiction.

We do not knowingly collect or request personal information from individuals under the age of 18 (or the applicable legal age in your jurisdiction) through our Sites without appropriate parental or guardian consent.

If we become aware that we have inadvertently collected personal information from a child under the age of 18 without the required consent, we will take appropriate steps, which may include seeking verifiable parental consent or deleting the information from our records promptly.

If you believe that a child under the age of 18 may have provided us with personal information through our Sites, please contact us using the details provided in the How to Contact Us section of this Global Privacy Policy.

Updates to Our Global Privacy Policy

We may update this Global Privacy Policy from time to time without prior notice to reflect changes in our privacy practices.

Where material changes are made, we will notify you by posting an update notice on our Sites. The “Last Updated” date at the top of this Policy will also be revised to indicate when the most recent changes were made.

This Global Privacy Policy supersedes and replaces all prior versions or earlier statements of our privacy policy.