Privacy Policy

Table of Contents

1. General Privacy Notice
2. Privacy Notice for EEA/UK Residents
3. Privacy Policy for California Consumers
4. DIFC Privacy Notice

Privacy Notice

Commitment to Privacy

Baron Capital Group, Inc. and its affiliates, and their respective successors and assigns (collectively, “Baron Capital,” “Baron,” “we,” “us” or “our”) are committed to responsibly handling personal information that we collect, use or otherwise process regarding our investors (including, for the purposes hereof, a potential investor, former investor or any individual who is a legal person connected with an investor) and individuals who visit our website (the “Website”) or otherwise communicate or engage with us (“you” or “your”).

Our intention with this privacy notice (this “Privacy Notice”) is to provide you with clear, transparent and easily understandable information about how Baron collects, uses and otherwise processes your personal information and certain rights you may have relating to such collection, use and other processing. Your access to the Website and use of the services provided by Baron are subject to this Privacy Notice. By visiting the Website, completing any of our online forms or otherwise submitting personal information to us, you agree to the terms of this Privacy Notice, and you hereby consent to our collection, use, disclosure and other processing of your personal information in accordance with this Privacy Notice. If you do not agree with this Privacy Notice, please do not use the services provided by Baron, access the Website or otherwise submit personal information to us.

Collection of Personal Information

The types of personal information collected by or on behalf of Baron about you varies based on Baron’s interactions with you (for example, whether you are an investor or an individual visiting the Website).

Personal information collected by or on behalf of Baron about individuals visiting the Website is obtained directly from you or certain third parties. For purposes of this Privacy Notice, “personal information” has the meaning given to such term (or to terms of similar intent, such as “personal data”) under applicable law, as and to the extent applicable to your rights and our obligations with respect to such information, including (as and to the extent applicable): (i) “personal information” as defined under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively, the “CCPA”), (ii) “non-public personal information” as defined under the Gramm-Leach-Bliley Act (Public Law 106-102) (the “Gramm-Leach-Bliley Act”), and/or (iii) “personal data” as defined under the General Data Protection Regulation (EU) 2016/679 (the “GDPR”) or the UK General Data Protection Regulation (i.e., the GDPR as implemented into the laws of the United Kingdom (the “UK”), the “UK GDPR”). The personal information we collect about you in the course of your interaction and correspondence with us via the Website includes, for example, the following:

• any personal information that you submit when you contact us using our contact details on the Website, such as your name or email address;
• your IP address and other online identifiers/web beacons;
• details of your online browsing activities on the Website, including, for example, the full Uniform Resource Locators (URL), clickstream to, through and from the Website (including, for example, date and time), services you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page;
• your browser type, language and version, relevant plug-ins, operating system and platform;
• your location information;
• your time zone settings; and/or
• in relation to any personal account you create on the Website:
  • usernames, passwords and other log-in information;
  • your account settings, including, for example, any default preferences;
  • a log of your browsing activities during your visit to the Website; and
  • any preferences we have observed, such as the types of products that interest you, or the areas of the Website that you visit.

If you are an investor, additional personal information collected by or on behalf of Baron about you is obtained directly from you, your professional advisors or other third parties, through the Website or from sources such as (i) information you provide to us when you interact with us before becoming a client, including, for example, when you contact us to request information about our services, (ii) subscription agreements, investor/purchaser applications or other forms and other required forms, documents and agreements or (iii) interactions with us during your time as our client, including, for example, when you meet with us or when we exchange formal correspondence and other communications with you (including, for example, written, telephone, videoconference or electronic contacts) regarding your accounts or transactions with us, our affiliates, or others. The personal information we collect about you as an investor in the course of your interaction and correspondence with Baron and its representatives includes, for example, the following:

• biographical and contact information such as name, title, address, business and/or personal telephone number, business and/or personal email addresses, and any other contact details you may supply;
• verification and due diligence information such as passport, driving license, social security number, utility bill, credit or bank card statement, and country of residence, country of origin/nationality, country of domicile/tax residency, tax reference number, date of birth, and occupation;
• details of your company’s directors, shareholders, secretaries, authorized signatories and other comparable officers and/or beneficiaries, and identification documents;
• financial and business-related information such as bank account details and information relating to your financial situation such as your assets, net worth, income, source of wealth and investment objectives. This may also include, for example, the amount invested and details of the investment made, and the name of the organization you work for and/or are a controlling person for;
• personal characteristics, including, for example, voice print, your signature and physical characteristics or description;
• details of any criminal convictions, regulatory or court orders, or suspensions or expulsions from membership in, or association with a member of, a self-regulatory association to which you are subject, or any investigation or proceeding associated with the foregoing;
• details of business advisers you may employ, including, for example, wealth managers and independent financial advisers;
• records of all communications, including, for example, recordings of your attendance (or your representative’s attendance) at certain meetings/phone calls, and electronic communications with Baron’s staff and meeting notes; and/or
• personal information about transactions with us, our affiliates or others, such as ownership of certain types of accounts, account numbers, PIN numbers, passwords or other account data or identifiers.

If you are an investor, Baron also may collect or receive personal information about you from third parties such as service providers to Baron’s sponsored funds, third-party introducers or intermediaries, your agents and representatives, where they are interacting with us on your behalf (including, for example, brokers, custodians or your assets or tax advisors), investor advisors (including, for example, independent financial advisors), vendors, tax authorities, governmental agencies and publicly available sources such as company websites. We may collect or receive any of the personal information noted above from such third parties, and in addition, we may collect or receive the following:

• details of any complaints made by you with respect to your dealings with the relevant service provider to the fund;
• data received from due diligence checks on you before we can accept you as a client (such as due diligence relating to anti-money laundering, politically exposed persons and sanctions checks); and/or
• fraud inquiries (including, for example, information from police reports).

In addition, if you are an investor, Baron obtains personal information about your interests in the funds (such as capital account balances and percentage interests) from the funds themselves and their other non-affiliated service providers.

Of the above categories of personal information that we may collect about you, the following may be considered “sensitive” categories under certain applicable laws: social security number, passport number, driver’s license, state identification card, and financial account information. This Privacy Notice, and the practices described herein, applies equally to our collection, use, disclosure and other processing of such “sensitive” personal information.

As described further below, the categories of personal information listed above are collected, used, retained, and shared by us and designated third parties only as necessary and proportionate to achieve the purposes disclosed to you in this Privacy Notice or as otherwise disclosed at or before the time of collection or based upon your subsequent consent.

We automatically collect basic technical information from all visitors to the Website. We collect this technical information during your visit to the Website through our automatic data collection tools, which may include cookies and other commonly used technologies (e.g., web beacons). Please see the section entitled “Cookies” below for a discussion of our use of cookies on the Website.

The Website is not intended for children and we do not knowingly collect data relating to children (including any minors under the age of 16). Children under 16 are prohibited by this Privacy Notice from providing personal information to us without parental consent. If you have reason to believe that a child has provided personal information to us without parental consent, please contact us using the details set forth at the end of this Privacy Notice.

Use of Personal Information Collected

Baron uses your personal information for the following business purposes:

• to provide you with services that you have requested, administer the relationship between you and us (including, for example, subscription acceptance, communications, record-keeping, reporting or monitoring of activities, and investor relations activities) and to fulfill Baron’s contractual obligations, including, for example, any contractual obligations as the general partner(s), the manager(s) and/or the investment advisor to a fund in which you have subscribed (including, for the avoidance of doubt, the preparation of Schedules K-1 and other tax forms or other filings);
• to operate the Website and our other IT systems, and safeguard their security;
• to understand the demographics, interests and behavior of users of the Website in order to personalize your visit to the Website;
• to monitor and evaluate the performance and effectiveness of our services;
• to tailor our advice and services to clients, principals, beneficial owners, beneficiaries and investors;
• to send you information about products of ours that we believe may be of interest to you and inform you of our upcoming investors’ conference;
• to fulfill our contractual obligations to other third parties to whom you have provided your information;
• for Baron’s internal business administration, record keeping and security purposes;
• to administer employee compensation, benefits and welfare programs, and to evaluate employees and prospective employees;
• for legal and regulatory compliance purposes, including, for example, as necessary for anti-money laundering, fraud prevention, tax reporting or sanctions reporting, where necessary for the establishment, exercise or defense of legal claims or to respond to governmental, regulatory or law enforcement agency requests;
• where required or considered appropriate, including, for example, prior to admitting you to a fund, prior to accepting capital contributions or making a capital distribution, carrying out “know-your-client” (KYC) checks as deemed appropriate and other procedures that Baron undertakes in the course of Baron’s ongoing business relationship with you;
• to provide information to future or potential purchasers or merger partners of all or a portion of Baron or any of its funds, or to provide information as may be necessary in connection with other corporate transactions, such as financings or restructurings;
• where necessary for reasons of substantial public interest; and/or
• for purposes otherwise set out in this Privacy Notice.

From time to time, Baron will provide you with information on Baron-sponsored funds that we may be raising and our investors’ conferences. You have the right to ask us not to send you marketing messages by post, telephone or e-mail or any combination of these at any time; however, you acknowledge that such information may be included in general update letters and while you may choose not to receive such updates, we are under no obligation to provide redacted versions of such letters or otherwise create separate reports on your behalf excluding such marketing information. You can also let us know at any time that you wish to change your mind and to start receiving such messages. You can do this by replying directly to the marketing message or at any time by contacting us.

We do not use or otherwise process your personal information, including “sensitive” personal information, for purposes of automated decision-making, including profiling.

We do not use or otherwise process your “sensitive” personal information other than as described herein. To the extent we collect any sensitive categories of personal information about you, including, for example, certain financial, health, and/or geolocation information, we will limit use of such information to that which is necessary to perform services or provide goods reasonably expected. To the extent you have any questions or concerns regarding our collection and use of sensitive categories of personal information, please contact us by using the information found at the end of this Privacy Notice.

We may aggregate, anonymize, or otherwise de-identify your personal information and use it for any purpose permitted by applicable law, and we may use information that does not personally identify you for any purpose, except where we are required to do otherwise under applicable laws. We also may use your personal information for any other purposes disclosed to you at the time of collection, that you have previously authorized, or with respect to which you subsequently provide your consent.

Do Not Track

Your browser and other mechanisms may permit you to send do-not-track signals or other similar signals via your browser settings to express your preferences regarding online tracking. Due to the lack of any standard for how do-not-track should work on commercial websites, we do not currently respond to such signals.

Consequences of Failing to Provide Personal Information

If you do not agree with our processing of your personal information as set forth in this Privacy Notice, you should not submit your personal information to us. However, where personal information is required to satisfy a statutory obligation (including, for example, compliance with applicable laws) or a contractual requirement, failure to provide such personal information may result in any of your subscriptions in our funds being rejected or your interest in such funds becoming subject to compulsory redemption or withdrawal, as applicable. Where there is suspicion of unlawful activity, failure to provide personal information may result in, to the extent permitted under applicable laws, the submission of a report to the relevant law enforcement agency or supervisory authority. Further, if you exercise your rights in such a manner to prevent us from processing your personal information, please note that we may not be able to do business with you or otherwise perform some of the tasks we need in order to provide certain products or services to you.

Sharing Personal Information

We do not disclose any personal information about you to anyone, except as detailed in this Privacy Notice or otherwise permitted by law. We disclose your personal information to the following categories of recipients:

• our employees and affiliates, for purposes of operating our business and for administrative purposes;
• companies that work for us to provide you services, as reasonably necessary or appropriate in connection with the management of our funds or the Website, including, for example, a transfer agent or mailing house, processors who perform services for us, legal advisors, accountants, fund administrators, companies engaged to dispose of or store data including personal information, audit firms, banks, tax consultants/preparers, placement agents, financial advisors, broker-dealers, custodians, investor-portal service providers, persons or entities that are assessing our compliance with industry standards and vendors supporting the Website or our other IT systems. We endeavor to ensure that all such companies act on our behalf, are contractually obligated to keep the information that we provide to them confidential and use the information only to provide the services that we have asked them to perform for you and us;
• adverse parties who have a legal right to receive such information and their counsel and experts and legal advisors;
• third-party financial companies, and their affiliates, as general partners and/or managers of funds that we and such other third-party financial companies sponsor together, for purposes of providing services related to, or marketing, such funds;
• marketing companies engaged to contact you about a Baron offer in support of your business needs or to conduct online surveys to understand better our customers’ needs;
• law enforcement agencies and regulators, government agencies or departments or competent authorities of the U.S. (including, for example, the U.S. Securities and Exchange Commission) or of other countries with whom a fund (or a fund’s portfolio company) transacts who request or require such information in order to issue business or regulatory licenses or permits;
• any person or entity, including, for example, any governmental agency, regulatory authority or self-regulatory organization having jurisdiction over us or our affiliates, if (i) we determine in our discretion that such disclosure is necessary or advisable pursuant to or in connection with any United States federal, state or local, or non U.S., law, rule, regulation, executive order or policy, including, for example, any anti-money laundering law, the USA PATRIOT Act of 2001 or any subpoena, court order or judicial process, and (ii) such disclosure is not otherwise prohibited by applicable law, rule regulation, executive order or policy; and
• third parties with whom a fund (or a fund’s portfolio company or a business that issues a fund’s investment) transacts who require information to comply with local anti-money laundering laws, including, for example, banks and other financing counterparties.

In addition, we may disclose personal information as follows:

• as required by law or any applicable regulatory authority, where we are under a duty to disclose or share your personal information in order to comply with any legal or regulatory obligations, or if we reasonably consider that such disclosure is necessary or advisable to protect the rights, property, or safety of our company or its clients or others. Such disclosure (including, for example, tax status, identity or residency or other personal or payment information, documents or self-certifications) may be made directly to such regulators or competent authorities or made indirectly to our advisers or service providers who may make such filings or disclosures on our behalf;
• if we are under a duty to disclose or share your personal information with tax authorities, such information requested by such tax authorities, who may transfer such information to the government or the tax authorities in another country where you may be subject to tax. Such disclosure may be made directly to such regulators or competent authorities or made indirectly to our advisers or service providers who may make such filings or disclosures on our behalf;
• subject to any contractual confidentiality obligations, we may disclose investor names, investors’ participation on any investor advisory committee, and investors’ respective jurisdictions and/or commitment sizes, in each case, to other investors or prospective investors of a Baron-sponsored fund;
• if you use a financial or other adviser (as indicated on your subscription agreement or subsequently communicated to us), the details of your investments and valuations may also be provided to such adviser(s);
• to future or potential purchasers or merger partners (i) for due diligence purposes on a need to know basis, (ii) as necessary for pre-closing integration planning, or (iii) in connection with the consummation of a sale or merger transaction; and/or
• on a need to know basis to current, future or potential lenders or other relevant persons as necessary in connection with other corporate transactions, such as financings or restructurings.

We also may disclose your information to any other third party where you have provided consent to such disclosure. We do not sell or offer to sell any personal information about you to third parties or share your personal information with third parties for purposes of cross-context behavioral advertising.

Retention of Personal Information

We will endeavor not to keep personal information in a form that allows you to be identified for any longer than is reasonably necessary for achieving the permitted purposes for which it was collected and otherwise in order to meet our statutory, regulatory, or other obligations under applicable law. We will endeavor to ensure that personal information will be destroyed or erased from our systems or anonymized when it has reached the end of the applicable retention period. When determining the relevant retention periods, we take into account factors, including, for example, the following:

• our contractual and business relationships with you;
• legal obligations under applicable law to retain personal information for a certain period of time;
• the amount, nature and sensitivity of your personal information;
• the potential risk of harm from unauthorized use or disclosure of your personal information;
• statutes of limitation under applicable law;
• (potential) disputes; and
• guidelines issued by relevant supervisory authorities.

Data Security

We acknowledge that the personal information you provide may be confidential, and we maintain policies and procedures designed to maintain the confidentiality of and protect your personal information in accordance with our normal procedures and applicable law. We maintain physical, electronic and procedural safeguards designed to protect your personal information, to prevent unlawful or unauthorized processing of personal information, and to prevent unauthorized disclosure of, or accidental loss of, or damage to, such information. For example, we endeavor to restrict access to personal information about clients, principals, beneficial owners, beneficiaries or investors to those employees who need to know that information to provide products or services to you, and to ensure that all such staff are subject to reasonably appropriate confidentiality and security obligations. Further, we endeavor to ensure that we only transfer personal information to third-party service providers if they agree to comply with our procedures and policies, or if they put in place adequate measures themselves.

Unfortunately, the storage and transmission of electronic information is not completely secure. We may also process personal information in and transfer personal information to countries that may not guarantee the same level of protection for personal information as the country in which you reside. Although we strive to protect your personal information, we cannot guarantee the security of information stored on our or our vendors’ servers or transmitted via email or through the Website; you transmit personal information to us at your own risk. In addition, links on the Website may take you to third-party websites over which we have no control. While such links are provided for your convenience, you should be aware that the information handling practices of the linked websites might not be the same as ours and other parties may collect your personal information about your online activities over time and across different websites when you visit the Website. You should review any privacy policies or cookie policies on those linked websites. We are not responsible for any linked websites.

Further, you may have created or may in the future create an account with our third-party fund administrator(s) (including through its vendor(s)). We are not responsible for the websites of our third-party fund administrator(s) or its vendor(s), and you should review any separate privacy policies or cookie policies that they provide to you or that they post on their websites.

If you create an account on the Website, you are responsible for all actions taken with your username and password. Therefore, we recommend that you do not disclose your password to anyone. You may not allow others to use your username or password to access or use any part of our Website. If your password has been compromised for any reason, you should contact us immediately for a new password.

Cookies

Two types of cookies may be used on the Website – “session cookies” and “persistent cookies.” Session cookies are temporary cookies that remain on your device until you leave the Website. A persistent cookie remains on your device for much longer or until you manually delete it (how long the cookie remains on your device will depend on the duration or “lifetime” of the specific cookie and your browser settings).

To find out more about our use of cookies, please visit www.baroncapitalgroup.com/cookies.

Social Media

We may utilize social media platforms such as LinkedIn®, YouTube, X and others. Note that any content you make available through those platforms (such as name, pictures, opinions or any other personal information) is subject to the terms of use and privacy policies of those platforms. To better understand your rights and obligations, please review the terms of use and privacy policies of the specific website or platform you are using.

We may allow social share buttons on the Website that enable users to easily share information on social media platforms. If you click on these social share buttons, the nonaffiliated third parties that own these widgets may have access to information about your browsing on pages of the Website where these widgets are placed.

Rights in Relation to Personal Information

If you are a resident of the European Economic Area (“EEA”) or the UK (an “EEA/UK Resident”), please refer to the “Privacy Notice for European and UK Residents” with respect to your rights in relation to personal information.

If you are a resident of the state of California (a “California Consumer”), please refer to the “Privacy Policy for California Consumers” with respect to your rights in relation to personal information.

To the extent that data privacy laws other than the GDPR, UK GDPR or the CCPA apply to our collection, use, disclosure or other processing of your personal information, you may have certain rights in relation to your personal information (including, depending on the jurisdiction, rights that may be comparable to those of EEA/UK Residents and/or of California Consumers, such as the right to request access to the personal information we hold about you, the right to have inaccurate personal information amended or updated, the right to object to processing of personal information, the right to have personal information erased or to restrict processing in certain limited situations, the right to request porting of personal information to another organization, and the right to object to automated decision making). In such case, we will follow such other applicable data privacy laws with respect to your rights, and the description herein of the rights of EEA/UK Residents and/or California Consumers, in each case as and to the extent applicable, shall be considered notice of your rights to the extent that we are required to provide you with such notice under such applicable data privacy laws. You should use the contact information below to get more information and/or to make a formal request to exercise any of the foregoing rights.

Changes to this Privacy Notice

We reserve the right to modify this Privacy Notice at any time and without prior notice. All updates are effective immediately when we provide them to you and they apply on a go-forward basis. For this reason, we encourage you to review this Privacy Notice whenever you visit the Website so you are aware of any updates, as they will be applicable to you and your personal information.

Questions

If you have any questions in relation to this Privacy Notice, please contact clientservice@baroncapitalgroup.com.

We may verify communications by matching information provided in or in connection with your communication to information contained in our records. Depending on the sensitivity of the communication and the varying levels of risk in responding to such communications (for example, the risk of responding to fraudulent or malicious communications), we may request further information in order to verify your communication. If we request you verify your communication and we do not receive your response, we will pause processing your communication until such verification is received. You should be prepared to provide us with, for example, your name, organization, contact details (including physical address, telephone number and email address) and details regarding your interest in one or more of our funds.

Privacy Notice for EEA/UK Residents

This privacy notice (this “EEA/UK Privacy Notice”) explains how Baron Capital collects, uses, shares and otherwise processes the personal information¹ of EEA/UK Residents, including our clients, principals, beneficial owners, beneficiaries and investors based in the EEA or the UK. Please read the following carefully to understand our views and practices regarding your personal information and how we will treat it. Please note that this EEA/UK Privacy Notice supplements the Privacy Notice and does not apply to individuals other than EEA/UK Residents. Capitalized terms used but not defined herein have their respective meanings as set forth in the Privacy Notice.

Baron Capital has a company registered in England and Wales with company number 12160343 and having its registered office address at Suite 1, 7th Floor, 50 Broadway, London, United Kingdom, SW1H 0BL (Baron Capital Management UK Limited). This company will usually be the principal ‘data controller’ of your personal information, as Baron Capital’s main establishment in the EEA and UK, and is subject to the GDPR and UK GDPR. Baron Capital is a ‘data controller’ subject to the GDPR and UK GDPR only insofar as we are offering goods or services to individuals in the EEA or the UK.

This EEA/UK Privacy Notice supersedes any previous notice or similar terms provided to EEA/UK Residents by, or on behalf of, Baron Capital in connection with the services we provide to you. If you are an EEA/UK Resident and do not agree with Baron’s use of your personal information as set forth in this EEA/UK Privacy Notice, you should not submit your personal information to Baron. However, if you do not submit certain personal information to Baron, or if you exercise your rights to prevent Baron from using such personal information, you should be aware that Baron may not be able to do business with you.

How We Collect Your Personal Information

We collect personal information from EEA/UK Residents, including Europe-based clients, principals, beneficial owners, beneficiaries and investors, in various ways, principally:

• from information you provide to us when you interact with us before becoming a client, including, for example when you contact us to request information about our services;
• when you ask us to provide services to you and provide us with your personal information in subscription agreements, investor/purchaser applications or other forms and other required forms, documents and agreements (and in accompanying identification documents);
• from third parties and publicly available sources, including, for example when we carry out due diligence checks on you before we can accept you as a client (such as due diligence relating to anti-money laundering, politically exposed persons and sanctions checks);
• from third party introducers or intermediaries, and from your agents and representatives, where they are interacting with us on your behalf (including, for example, brokers, custodians or your assets or tax advisors);
• in other ways as you interact with us during your time as our client, including, for example when you meet with us or when we exchange formal correspondence and other communications with you; and/or
• as otherwise described in the Privacy Notice.

Categories of Personal Information Collected

We receive personal information from EEA/UK Residents, including Europe-based clients, principals, beneficial owners, beneficiaries and investors, which includes, for example:

• Category 1 - biographical and contact information such as name, title, address, business and/or personal telephone number, business and/or personal email addresses.
• Category 2 – verification and due diligence information such as passport, driving license, utility bill, credit or bank card statement, and country of residence, country of origin/nationality, country of domicile/tax residency, tax reference number, date of birth, and occupation.
• Category 3 – financial and business-related information such as bank account details and information relating to your financial situation such as your assets, net worth, income, source of wealth and investment objectives. This may also include, for example, the amount invested and details of the investment made, the name of the organisation you work for and/or are a controlling person for.

We may also receive additional categories of personal information as described in the Privacy Notice.

Purposes and Lawful Bases for Processing Personal Information

We may use your personal information for the purposes described in the Privacy Notice on the following bases:

• to carry out our obligations necessary for the performance of a contract with you, or to take steps at your request prior to entering into such a contract. This may include, for example, obligations arising from any agreement entered into with us by or on behalf of clients, principals, beneficial owners, beneficiaries and investors, including contacting such individuals; to contact such individuals with information messages about their investments; and for administration purposes to the extent allowed by applicable law;
• to comply with our legal obligations. In this respect we may process your personal information: (i) to complete anti-money laundering checks and other checks as are required by law and (ii) to meet other compliance and regulatory obligations, including in order to comply with any requirement of any applicable statute, regulation or rule to which we are subject;
• because it is necessary for our and/or a third party’s legitimate interests. These include, for example, our commercial interests in operating our business and may include using your information (i) to monitor and evaluate the performance and effectiveness of our services or (ii) to tailor our advice and services to clients, principals, beneficial owners, beneficiaries and investors; and/or
• where it is necessary for reasons of substantial public interest; it is necessary for the establishment, exercise or defense of legal claims; or where we have your specific or, where necessary, explicit consent to do so.

If we were to process “sensitive” or “special” categories of personal information under the GDPR or UK GDPR², we would do so only where we have asked for your explicit consent, or otherwise where necessary for the establishment, exercise or defense of legal claims, or as otherwise may be permitted under applicable laws.

Provision of certain of your personal information is a legal and contractual requirement to becoming an investor in any fund or other pooled vehicle. If you choose not to provide such personal information, we may not be able to perform some of the tasks we need to in order to provide certain products or services to you. Where our processing is based on your consent, you may withdraw that consent, without affecting the lawfulness of our processing based on consent before its withdrawal.

Disclosure of Personal Information

We do not disclose any of your personal information to any third parties, except as detailed in the Privacy Notice or as otherwise required by law. We will use reasonable efforts to take steps necessary to ensure that where personal information is shared it is treated securely and in accordance with this EEA/UK Privacy Notice and applicable laws.

Transferring Your Personal Information Outside of the EEA and UK

In the course of providing services to you, we may transfer, use, store and/or otherwise process your personal information outside of the EEA and UK, principally to Baron Capital’s offices and servers in the United States. EEA/UK Residents’ personal information also may be processed by staff operating outside the EEA or UK who work for us (including, for example, staff engaged in the provision of administration and support services) or for one of our vendors (including, for example, those who supply support services to us). This means that, in such cases, your personal information will not have the automatic protection of data protection laws (including the GDPR and the UK GDPR) which apply in the EEA or UK. In circumstances where your personal information is transferred outside the EEA or UK, and your personal information will be processed in a country with laws that (i) if you are an EEA resident, may not be equivalent to, or as protective as, the laws of countries within the EEA or (ii) if you are a UK resident, establish a data protection standard that is materially lower than that established by the laws of the UK, in either case of (i) or (ii), in order to require that your personal information continues to have adequate protection, your personal information will only be transferred on one of the following grounds:

• the country or territory to which the transfer is made ensures an adequate level of protection for personal information;
• Baron Capital and the recipient of the personal information outside the EEA or UK have signed a form of model data protection clauses (standard contractual clauses) approved by the European Commission or their equivalent under the UK GDPR; or
• there exists another situation where the transfer is permitted under applicable law (including, for example, where we have your explicit consent to make the transfer).

You can obtain more details of the protection given to your personal information when it is transferred outside the EEA or UK by contacting us using the details set out below.

Storage of Personal Information

As is described in the Privacy Notice, we maintain physical, electronic and procedural safeguards designed to protect your personal information, to prevent unlawful or unauthorized processing of personal information, and to prevent unauthorized disclosure of, or accidental loss of, or damage to, such information. For example, we endeavor to restrict access to your personal information to those of our employees and agents who need to know the information to enable us to provide services.

Personal Information Retention

As is described in the Privacy Notice, we will endeavor not to keep personal information in a form that allows you to be identified for any longer than is reasonably necessary for achieving the permitted purposes. We will endeavor to ensure that personal information will be destroyed or erased from our systems or anonymized when it has reached the end of the applicable retention period.

Your Rights in Relation to Personal Information

Under certain circumstances, by law you have the following rights in relation to your personal information:

• the right to request access to, and copies of, the personal information we hold about you;
• the right to have inaccurate personal information amended or updated;
• the right to object, on grounds relating to your particular situation, to any of our particular processing activities where you feel this has a disproportionate impact on your rights;
• the right (in certain circumstances) to have personal information erased or to restrict processing in certain limited situations; and
• to receive from us the personal information we hold about you which you have provided to us, in a reasonable format specified by you, including for the purpose of you transmitting that personal information to another data controller.

Where our processing is based on your consent, you may withdraw that consent, without affecting the lawfulness of our processing based on consent before its withdrawal.

Please note that these rights are not absolute, and we may be entitled to refuse requests where exceptions apply.

You should use the contact information below to get more information and/or to make a formal request. We will respond to your request within one month of receipt of your request. In some cases, we may not be able to fulfill your request to exercise the right before this date, and may need to request more time. Where we cannot provide a full response to you for any reason, we will let you know about this in our initial reply to your request.

You will not have to pay a fee to access your personal information (or to exercise any of the other above-listed rights). In some cases, we may charge a reasonable fee if your request for access is clearly unfounded or excessive, or if you request multiple copies of the relevant information. Alternatively, we may refuse to comply with the request in such circumstances.

You should notify us if any of your personal information changes or if you become aware of any inaccuracies in the personal information we hold about you. To access your personal information (or to exercise any of the other above-listed rights), we may need to request specific information from you to help us confirm your identity and ensure your right to access the personal information (or to exercise any of your other above-listed rights). This is another appropriate security measure designed to ensure that personal information is not disclosed to any person who is not entitled to receive it.

Changes to this Privacy Notice

We reserve the right to modify this EEA/UK Privacy Notice at any time and without prior notice. All updates are effective immediately when we provide them to you and they apply on a go-forward basis. For this reason, we encourage you to review this EEA/UK Privacy Notice whenever you visit the Website so you are aware of any updates, as they will be applicable to you and your personal information.

Questions and Complaints

If you have any questions in relation to this Privacy Notice, please contact clientservice@baroncapitalgroup.com.

If you are not satisfied with our response to your questions or believe that how we are processing your personal information does not comply with the GDPR, UK GDPR or other applicable data privacy legislation, you can make a complaint to a data protection supervisory authority in your country, including the data protection regulator in the country where you or your organization is located. For example, in the UK you should contact the Information Commissioner’s Office (or successor thereto) at: https://ico.org.uk/global/contact-us/ or 0303 123 1113.

¹ For the purposes of this section, “personal information” has the meaning given to the term “personal data” in the GDPR or UK GDPR, as applicable.

² “Special” or “sensitive” categories of personal information include, among other things, data concerning your health, revealing your racial or ethnic origin, political opinions, religious or philosophical beliefs, or concerning your sexual orientation.

Privacy Policy for California Consumers

This privacy policy (this “California Privacy Policy”) applies to California Consumers and supplements the information contained in the Privacy Notice of Baron. Any terms defined in the CCPA or the Privacy Notice have the same meaning when used in this California Privacy Policy.

PERSONAL INFORMATION WE COLLECT

For purposes of this California Privacy Policy, “Personal Information” means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal Information does not include publicly available information from government records. Further, the rights under the CCPA do not apply to personal information collected, processed, sold or disclosed subject to the Gramm-Leach-Bliley Act, the Fair Credit Reporting Act (12 CFR 1022) and/or the California Financial Information Privacy Act.

Baron collects personal information as described in the Privacy Notice, and has collected the following categories of Personal Information from California Consumers within the last 12 months:

SOURCES OF PERSONAL INFORMATION

Baron collects the categories of Personal Information listed above from the following categories of sources:

• From use of the Website (www.baroncapitalgroup.com). For example, in the account access area of the Website, we may collect a shareholder’s account number, social security number, tax identification number, and password.
• Directly from our clients or their agents. For example, from documents that our clients provide to us in connection with our providing them a financial product or service.
• Indirectly from our clients or their agents. For example, through information we collect from our clients in connection with providing them a financial product or service.
• From third parties that interact with us in connection with financial products we provide and services we perform.
• As otherwise described in the Privacy Notice. 

USE OF PERSONAL INFORMATION

Baron may use or disclose the Personal Information we collect for one or more of the following business purposes:

• To provide the California Consumer a service. For example, we may provide Personal Information to a transfer agent or mailing house.
• To send the California Consumer information about our products that we believe may be of interest to that consumer.
• To inform the California Consumer of our upcoming investors’ conference.
• To administer employee compensation, benefits and welfare programs, and to evaluate employees and prospective employees.
• As otherwise described in the Privacy Notice.

As is described in the Privacy Notice, we endeavor to restrict access to Personal Information about the California Consumer to those employees who need to know that information to provide products or services to the California Consumer. We maintain physical, electronic, and procedural safeguards designed to guard Personal Information.

DISCLOSURE OF PERSONAL INFORMATION

We may disclose the California Consumer’s Personal Information to a third party for a business purpose. We endeavor to ensure that all third parties to which we provide Personal Information for a business purpose act on our behalf, and are contractually obligated to keep the Personal Information that we provide to them confidential, and maintain or otherwise process the Personal Information to perform only the services specified in the written contract between our organization and the service provider. We will not use your Personal Information to build consumer profiles for use in providing services to another business.

In the preceding 12 months, we have disclosed the following categories of Personal Information for a business purpose:

• Category A (Identifiers)
• Category B (Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
• Category C (Protected classification characteristics under California or federal law)
• Category E (Biometric information)
• Category F (Internet or other similar network activity)
• Category I (Professional or employment-related information)
• Category J (Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))

We disclose California Consumers’ Personal Information for a business purpose to the following categories of third parties:

• Our affiliates.
• Service providers.
• Third parties to whom California Consumers or their agents authorize us to disclose Personal Information in connection with the financial products or services we provide to them.
• As otherwise described in the Privacy Notice.

SALE OF PERSONAL INFORMATION

In the preceding 12 months, we have not sold any Personal Information. We do not intend to sell Personal Information to any party. If in the future, we anticipate selling Personal Information to any party, we will provide the California Consumer with the opt-out and opt-in rights required by the CCPA.

CALIFORNIA CONSUMER RIGHTS REGARDING PERSONAL INFORMATION

The CCPA provides California Consumers with certain rights regarding their Personal Information. This section describes CCPA rights and explains how to exercise those rights.

Access to Specific Information

California Consumers have the right to request that we disclose to them certain information about our collection and use of their Personal Information over the past 12 months. Once we receive and confirm a verifiable consumer request, we will disclose to a California Consumer:

1. The categories of Personal Information we collected about the California Consumer.
2. The categories of sources from which the Personal Information was collected.
3. The categories of third parties with which we share such Personal Information.
4. The specific pieces of Personal Information we have collected about the California Consumer. However, we will not disclose a California Consumer’s Social Security number, driver’s license number or other government-issued identification number, financial account number, any health insurance or medical identification number, an account password, security questions and answers, or unique biometric data generated from measurements or technical analysis of human characteristics. If applicable, we will inform the California Consumer with sufficient particularity that we have collected any one of the previous types of information.
5. Our business or commercial purpose for collecting or selling that Personal Information.
6. If we sold the California Consumer’s Personal Information for a business purpose, the associated sales, identifying the Personal Information categories that each category of recipient purchased.
7. If we disclosed the California Consumer’s Personal Information for a business purpose, such disclosures, identifying the Personal Information categories that each category of recipient obtained.

Deletion Request Rights

California Consumers have the right to request that we delete any of their Personal Information that we collected from them and retained, subject to certain exceptions. Once we receive and confirm a California Consumer’s verifiable consumer request, we will delete (and direct our service providers to delete) their Personal Information from our records, unless an exception applies.

We may deny a California Consumer’s deletion request if retaining the Personal Information is necessary for us or our service providers to:

1. Complete the transaction for which the Personal Information was collected; provide a good or service requested by the California Consumer or reasonably anticipated within the context of our ongoing business relationship with the California Consumer; or otherwise perform a contract between our business and the California Consumer.
2. Detect security incidents; protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity.
3. Debug to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code.
6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when deletion of the information is likely to render impossible or seriously impair the achievement of such research, if the California Consumer has provided informed consent.
7. Enable solely-internal uses that are reasonably aligned with the expectations of the California Consumer based on the California Consumer’s relationship with our business.
8. Comply with a legal obligation.
9. Otherwise use the California Consumer’s Personal Information, internally, in a lawful manner that is compatible with the context in which the California Consumer provided the information.

Correction of Personal Information

California Consumers have the right to request that we correct any inaccurate or outdated Personal Information that we have collected about them, subject to certain exceptions.

Exercising CCPA Rights

To exercise the rights described above, or if you need to access this California Privacy Policy in an alternative format, please submit a verifiable consumer request to us by either:

• Calling us at 1(800) 99-BARON
• Visiting www.baroncapitalgroup.com/contact/contact-us 

Only a California Consumer or a person registered with the California Secretary of State that the California Consumer authorizes to act on his or her behalf may make a verifiable consumer request related to his or her Personal Information. The California Consumer may also make a verifiable consumer request on behalf of his or her minor child.

In response to a verifiable consumer request, Baron is required to provide Personal Information to a California Consumer no more than twice in a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows Baron to reasonably verify the California Consumer is the person about whom Baron collected Personal Information or an authorized representative; and
• Contain reasonable detail such that Baron is able to properly understand, evaluate, and respond to it.

Baron cannot respond to a California Consumer’s request or provide a California Consumer with Personal Information if we cannot verify the requesting person’s identity or authority to make the request.

Making a verifiable consumer request does not require the California Consumer to create an account with Baron. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

Baron will respond to a verifiable consumer request within 45 days of its receipt when possible. If we require more time (up to 90 additional days), we will inform the California Consumer within 45 days of receipt of the request of the need for an extension along with the reasons for the extension.

Any disclosures Baron provides will only cover the 12-month period preceding the verifiable California Consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. Baron will deliver information by mail or electronically, and if provided electronically, the information shall be in a portable and, to the extent technically feasible, readily-useable format that allows the California Consumer to transmit the information to another entity without hindrance.

Baron does not charge a fee to respond to a California Consumer’s verifiable consumer request unless it is manifestly unfounded, excessive, or repetitive. In such a case, we may charge a reasonable fee or refuse to act on the request, but we will inform the California Consumer why we made that decision and provide the California Consumer with a cost estimate before completing the request.

Non-Discrimination

We will not discriminate against a California Consumer because the California Consumer exercised any of his or her rights under the CCPA. We will not, based on an exercise of rights under the CCPA:

• Deny goods or services to the California Consumer;
• Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
• Provide a different level or quality of goods or services to the California Consumer; or
• Suggest that the California Consumer will receive a different price or rate for goods or services or a different level or quality of goods or services.

DIFC Privacy Notice

This Privacy Notice explains how Baron Capital (“Baron Capital”, “we”, “our”, “us”) collects, uses and shares personal data of clients, principals, beneficial owners, beneficiaries, investors, prospects and any other individuals using our website for the Dubai International Financial Centre (“DIFC”) https://www.baroncapitalgroup.com/ or who contact us (“you”, “your”) in accordance with the DIFC Data Protection Law (DIFC Law No. 5 of 2020) and its associated Data Protection Regulations 2020 (“DIFC DP Law”). Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

Baron Capital has a company registered in the Dubai International Financial Centre (“DIFC”) with company number 9737 and having its registered office at Unit GV-00-10-08-OF-10, Level 8, Gate Village Building 10, DIFC, United Arab Emirates (Baron Capital Management (DIFC) Limited).

This company will usually be the principal ‘data controller’ of your personal data for the purposes of the DIFC DP Law, as it is incorporated in the DIFC. However, the DIFC DP Law (and therefore this Privacy Notice) may also apply to other Baron Capital entities to the extent that they process your personal data in the context of their activities in or from the DIFC, or where personal data is processed in the DIFC as part of stable arrangements.

This Privacy Notice was updated on January 27, 2026 and supersedes any previous notice or similar terms provided by, or on behalf of, Baron Capital in connection with the services we provide to you.

How We Collect Your Personal Data

We collect personal data from DIFC-based clients, principals, beneficial owners, beneficiaries and investors in various ways, principally:

• from information you provide to us when you interact with us before becoming a client, for example when you contact us to request information about our services;
• when you ask us to provide services to you and provide us with your personal data in application forms for investment management services (and in accompanying identification documents);
• from third parties and publicly available sources, for example when we carry out due diligence checks on you before we can accept you as a client;
• from third party introducers or intermediaries, and from your agents and representatives, where they are interacting with us on your behalf (for example, brokers, custodians or your assets or tax advisors);
• in other ways as you interact with us during your time as our clients, for example when you meet with us or when we exchange formal correspondence and other communications with you.

Categories of Personal Data Collected

We receive personal data from you which includes:

• Category 1 - biographical and contact information such as name, title, address, business and/or personal telephone number, business and/or personal email addresses.
• Category 2 – verification and due diligence information such as passport, driving license, utility bill, credit or bank card statement, and country of residence, country of origin/nationality, country of domicile/tax residency, tax reference number, date of birth, and occupation.
• Category 3 – financial and business-related information such as bank account details and information relating to your financial situation such as your assets, net worth, income, source of wealth and investment objectives. This may also include the amount invested and details of the investment made, the name of the organisation you work for and/or are a controlling person for.
• Category 4 – information collected in connection with the ongoing commercial relationship between us and you, as well as in administrating this commercial relationship. This may include recordings of our correspondence and calls, CCTV recordings of attendance at office premises where CCTV is installed, data collected for maintaining business records and related documents, data collected through our website and social media pages where this notice is applicable to website users.

Purposes and Lawful Bases for Processing Personal data

We may use your personal data for the following purposes:

• to carry out our obligations necessary for the performance of a contract with you, or to take steps at your request prior to entering into such a contract. This may include obligations such as those arising from any agreement entered into with us by or on behalf of clients, principals, beneficial owners, beneficiaries and investors, including contacting such individuals;
• to contact such individuals with information messages about the investment; and for administration purposes to the extent allowed by applicable law;
• to comply with our legal obligations. In this respect we may process your personal data:
• to complete anti-money laundering checks and other checks as are required by law;
• to meet other compliance and regulatory obligations, including in order to comply with any requirement of any applicable statute, regulation or regulatory rule to which we are subject;
• to tailor our advice and services to clients, principals, beneficial owners, beneficiaries and investors.

We may also process your personal data because it is necessary for our and/or a third party’s legitimate interests. These include our commercial interests in operating our business and may include using your information to monitor and evaluate the performance and effectiveness of our services.

We may also process your personal data where it is necessary for reasons of substantial public interest; it is necessary for the establishment, exercise or defence of legal claims; or where we have your specific or, where necessary, explicit consent to do so.

If you do not provide us with certain information (for example, information that is indicated as mandatory or which is necessary to enter into a contract with us), we may not be able to manage or administer our relationship with you and provide services to you.

Any use by us of AI systems is designed to ensure ethical, fair, transparent, secure, and accountable processing of personal data and will be in accordance with DIFC DP Law,. We are committed to maintaining high standards of data protection and ensuring that any AI systems used are aligned with these principles.

Disclosure of Personal data

Other than to our affiliates for the purposes described above, we do not disclose any of your personal data to any third parties, except as reasonably necessary or appropriate in connection with the management of the funds, to processors who are only permitted to use it to perform services for us, or as required by law or any applicable regulatory authority, or to protect the rights, property, or safety of our company or its clients or others, or if we sell in part or in whole our business or assets or are acquired by a third party, in which case we may disclose your personal data to the prospective buyer for due diligence purposes. In these cases, we may share personal data with legal advisors, accountants, fund administrators, companies engaged to dispose of or store data including personal data, and adverse parties who have a legal right to receive such information and their counsel and experts and legal advisors.

We will take all steps reasonably necessary to ensure that where personal data is shared it is treated securely and in accordance with this notice and applicable laws.

Transferring your personal data outside of DIFC

In the course of providing services to you, we will transfer your personal data outside of the DIFC, principally to Baron Capital’s offices and servers in the US. In order to ensure that your personal data has adequate protection when it is transferred outside the DIFC, your personal data will only be transferred on one of the following grounds:

• the country or territory to which the transfer is made ensures an adequate level of protection for personal data;
• Baron Capital and the recipient of the personal data outside the DIFC have signed a form of model data protection clauses (standard contractual clauses) approved by DIFC Commissioner of Data Protection; or
• there exists another situation where the transfer is permitted under applicable law (for example, where we have your explicit consent to make the transfer).

You can obtain more details of the protection given to your personal data when it is transferred outside the DIFC (including a copy of the standard data protection clauses which we have entered into with recipients of your personal data) by contacting us using the details set out below.

Storage of Personal data

We restrict access to your personal data to those of our employees and agents who need to know the information to enable us to provide services.

We maintain physical, electronic and procedural safeguards designed to protect your personal data, to prevent unlawful or unauthorized processing of personal data, and to prevent unauthorized disclosure of, or accidental loss of, or damage to, such information.

We will only transfer personal data to a third-party service provider if they agree to comply with those procedures and policies, or if they put in place adequate measures themselves.

Personal data Retention

We will endeavour not to keep personal data in a form that allows you to be identified for any longer than is reasonably necessary for achieving the permitted purposes. This means that personal data will be destroyed or erased from our systems or anonymized when it has reached the applicable retention period.

Your Rights in Relation to Personal Data

You have the following rights in relation to your personal data:

• the right to request access to, and copies of, the personal data we hold about you
• the right to have inaccurate data amended or updated;
• the right to object, on grounds relating to your particular situation, to any of our particular processing activities where you feel this has a disproportionate impact on your rights. There may be circumstances where you object to, or ask us to restrict, our processing of your personal data but we are legally entitled to continue processing your personal data and / or to refuse that request;
• where you have actively provided your consent for us to process your personal data, the right to withdraw your consent to our processing of your personal data at any time. Please note, however, that we may still be entitled to process your personal data if we have another legitimate reason (other than consent) for doing so. The withdrawal of consent does not affect the lawfulness of processing of your personal data based on consent before the withdrawal;
• the right (in certain circumstances) to have personal data erased or to restrict processing in certain limited situations;
• to receive from us the personal data we hold about you which you have provided to us, in a reasonable format specified by you, including for the purpose of you transmitting that personal data to another data controller;
• the right not to be discriminated against by us or adversely treated when exercising one of your rights in relation to your personal data; and
• the right to lodge a complaint with the data protection regulator (details of which are provided below) if you think that any of your rights have been infringed by us.

Please note that these rights are not absolute, and we may be entitled to refuse requests where exceptions apply.

You should use the contact information below to get more information and/or to make a formal request.

You should notify us if any of your personal data changes or if you become aware of any inaccuracies in the personal data we hold about you.

Changes to this Privacy Notice

We reserve the right to modify this Privacy Notice at any time and without prior notice.

Questions and Complaints

If you have any questions in relation to this Privacy Notice, please contact:

Legal Office;
Baron Capital Management (DIFC) Limited,
767 Fifth Avenue,
49th Floor,
New York, NY, USA 10153,

Email: clientservice@baroncapitalgroup.com.

If you are not satisfied with how we are processing your personal data, you can make a complaint to the DIFC Commissioner of Data Protection, or by searching their website at https://www.difc.com/business/registrars-and-commissioners/commissioner-of-data-protection.