Privacy Notice

1. Introduction

Kerberos Capital Management LLC and its affiliates (collectively, "Kerberos" or "we" or "us") respect your privacy and are committed to protecting it through our compliance with this privacy notice.

This Privacy Notice (our "Privacy Notice") describes the types of information we may collect, use, maintain, protect, disclose, or otherwise process about you when you visit the website Home | Kerberos Capital Management ("Website"). It also outlines our practices for collecting, using, maintaining, protecting, disclosing, or otherwise processing that information.

This policy applies to information we collect on our Website;

It does not apply to information collected by:

Please read this Privacy Notice carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using our Website, you agree to this Privacy Notice. This Privacy Notice may change from time to time.

Your continued use of a Website after we make changes is deemed to be acceptance of those changes, so please check this Privacy Notice periodically for updates.

This Privacy Notice does not apply to Personal Data that we may collect or otherwise receive related to your investment, or application to invest, in one of our funds. Please see our Investor Privacy Notice, made available to you in the investor portal for more information on how we collect and use such Personal Data.

This Privacy Notice also does not apply to employment-related Personal Data that we may collect or otherwise receive about you related to your relationship with us as an employee, job applicant, contractor, or other similar relationship. Please contact Kerberos' Operations department for more information on how we collect and use such Personal Data.

2. Children Under the Age of 18

Our Website is not intended for children under 18 years of age. No one under age 18 may provide any information to or on a Website. We do not knowingly collect Personal Data from children under 18. If you are under 18, do not use or provide any information on our Website, including your name, address, telephone number, email address, or any screen name or username you may use. If we learn we have collected or received Personal Data from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information directly from a child under 18, please contact us at info@kerberoscm.com.

3. Information We Collect About You and How We Collect It

Throughout this Privacy Notice, the term "Personal Data" means any information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or device. However, Personal Data does not include any deidentified or aggregated information.

Generally

We collect Personal Data from various sources, including:

Information You Provide to Us

We may collect the following types of Personal Data directly from you when you access or use our Website or otherwise contact us via email or phone: real name, alias, postal address, email address, and telephone number.

The Personal Data that you directly provide us is collected through:

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain Personal Data about your interaction with our Website, including information about your equipment, browsing actions, and patterns. This includes:

The information we collect automatically may include Personal Data. It helps us to improve our Website and to deliver a better and more personalized service by enabling us to:

The technologies we use for this automatic data collection may include one or more of the following:

Cookies (or browser cookies)

A cookie is a small file placed on the hard drive of your computer. We only place non-essential cookies on your device with your consent. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. However, if you do not consent to our use of cookies or select this setting you may be unable to access certain parts of our Website. Our Website may use both session cookies (which expire once you close your browser) and persistent cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Website. You can find more information about cookies at http://www.allaboutcookies.org. More information about our use of specific cookies and how long they remain on your device can be found below. By continuing to allow cookies, you hereby consent to our recording of use of the Website or other communications you may have with our Website.

Session Cookies

Each time you access the Website, a session cookie containing an encrypted, unique identifier is placed on your device. These session cookies allow us to uniquely identify you when you use the Website and allow us to maintain your login session. Session cookies are required to use the Website and are removed when you log out or close your browser window to the Website.

Persistent Cookies

Persistent cookies that may contain a unique identifier are placed on your device when you access the Website. These cookies are used to track aggregate and statistical information about user activity, maintain your preferences, and provide you with targeted or behavioral advertising based on your activities on the Website. The amount of time these cookies remain on your device may vary, depending on the cookie.

Web Beacons

Pages of our Website may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit Kerberos, for example, to count users who have visited those pages and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

Cookies Used on our Website

Google Analytics Cookies: Google Analytics is a web analytics service provided by Google, Inc. ("Google") to collect and record certain information relating to your use of the Website (including your IP address and what pages on our Website you visit). This information is collected through the use of cookies that remain valid for a period of up to 24 months. The information collected through these cookies will be transmitted to and may be stored by Google on servers throughout the world, including the United States. Google will use this information for the purpose of evaluating your use of the Website and compiling reports related to the activity on our Website for Kerberos. We use this information to further understand the use of our Website and our content. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. You may refuse the use of cookies by selecting the appropriate settings on your browser, however, please note that if you do this you may not be able to use the full functionality of our Website. By using our Website, you consent to the collection and recording of data about your activities on our Website by Google in the manner and for the purposes set out above. For more information regarding Google Analytics please visit Google's website, and pages that describe Google Analytics, such as www.google.com/analytics/learn/privacy.html.

4. How We Use Your Information

We use information that we collect about you or that you provide to us, including any Personal Data:

We may also use your Personal Data to provide you with investor relation alerts that you request. If you have subscribed to such alerts but subsequently wish to change your choice, you may do so by sending us an email stating your request to info@kerberoscm.com. For more information, see Choices About How We Use and Disclose Your Information.

5. Disclosure of Your Personal Data

We do not share, sell, or otherwise disclose your Personal Data for purposes other than those outlined in this Privacy Notice. However, we may disclose aggregated information about our users without restriction.

We may disclose Personal Data that we collect, or you provide, as described in this Privacy Notice:

We may also disclose your Personal Data:

6. Choices About How We Use and Disclose Your Information

We do not control the collection and use of your information collected by third parties described above in Disclosure of Your Information. When possible, these organizations are under contractual obligations to use this data only for providing the services to us and to maintain this information strictly confidential. These third parties may, however, aggregate the information they collect with information from their other clients for their own purposes.

In addition, we strive to provide you with choices regarding the Personal Data we have collected about you. We have created mechanisms to provide you with control over your Personal Data:

7. Accessing, Correcting, and Deleting Your Personal Data

You may contact us at the contact information below to request access to, correct or delete any Personal Data that we have collected about you. We may not accommodate a request to change or delete your Personal Data if we believe the change or deletion would violate any law or legal requirement or cause the information to be incorrect.

The jurisdiction in which you are a resident or are located may provide you with additional rights and choices regarding your Personal Data. Please see Jurisdiction-Specific Privacy Rights for more information.

8. Jurisdiction-Specific Privacy Rights

The law in some jurisdictions may provide you with additional rights regarding our use of Personal Data. To learn more about any additional rights that may be applicable to you as a resident of one of these jurisdictions, please see the privacy addendum for your jurisdiction that is attached to this Privacy Notice.

Your California Privacy Rights

If you are a resident of California, you have the additional rights described in our California Privacy Addendum.

Your GDPR Privacy Rights

If you are a resident of the European Economic Area, Switzerland, or the United Kingdom, you have the additional rights described in our GDPR Privacy Notice.

9. Do Not Track Signals and Global Privacy Control Signals

We do not track you over time and across third-party websites or other online services for any purpose.

Some web browsers permit you to broadcast a signal to websites and online services indicating a preference that they "do not track" your online activities. Our Website incorporates third-party technology designed to honor such signals and some similar mechanisms that may be sent by your browser or device and we may limit the Personal Data or other information we collect and/or how we use your Personal Data or other information based upon whether such a signal is transmitted by your browser or device and received by us.

10. Data Security

We have implemented measures designed to secure your Personal Data from accidental loss and from unauthorized access, use, alteration, and disclosure.

Unfortunately, the transmission of information via the internet is not completely secure. Although we have implemented measures to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted to our Website. Any transmission of Personal Data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures deployed on the Website.

11. Consent to Processing of Personal Data in the United States

In order to provide our Website to you or by otherwise contacting us, your Personal Data may be transmitted to or otherwise stored outside of the country where you reside or are located, including to countries that may not or do not provide an equivalent level of protection for your Personal Data. Your Personal Data may be processed and stored in the United States and federal, state, and local governments, courts, or law enforcement or regulatory agencies in the United States may be able to obtain disclosure of your information through the laws of the United States. By using our Website or otherwise contacting us via email or telephone, you represent that you have read and understood the above and hereby consent to the storage and processing of Personal Data outside the country where you reside or are located, including in the United States.

Your Personal Data is transferred by Kerberos from your country to another country only if it is required or permitted under applicable data protection law and provided that there are appropriate safeguards in place to protect your Personal Data. To ensure your Personal Data is treated in accordance with this Privacy Notice when we transfer it to a third party, Kerberos uses Data Protection Agreements between the Kerberos and all other recipients of your Personal Data.

12. Changes to Our Privacy Notice

We may change this Privacy Notice at any time. It is our policy to post any changes we make to our Privacy Notice on this page. If we make material changes to how we treat our users' Personal Data, we will notify you through a notice on the Website's home page. The date this Privacy Notice was last revised is identified at the bottom of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this Privacy Notice to check for any changes.

Your continued use of our Website following the posting of changes constitutes your acceptance to such changes.

13. Contact Information

If you have any questions, concerns, complaints, or suggestions regarding our Privacy Notice or the ways in which we collect and use your Personal Data described in this Privacy Notice, have any requests related to your Personal Data pursuant to applicable laws, or otherwise need to contact us, you may contact us at the contact information below.

Kerberos Capital Management LLC
17 N. State St., Suite 1600
Chicago, Illinois 60602
(312) 854-8787
info@kerberoscm.com

Last updated: March 2025