Privacy Notice

LAZARD FRÈRES & CO. LLC
LAZARD ASSET MANAGEMENT LLC
LAZARD ALTERNATIVES, LLC

30 Rockefeller Plaza
New York, New York 10112-6300

PRIVACY NOTICE REGARDING CUSTOMER FINANCIAL INFORMATION

Lazard Frères & Co. LLC, Lazard Asset Management LLC and Lazard Alternatives, LLC ("Lazard"), on their own behalf and on behalf of the funds managed by Lazard and its affiliates, recognize and appreciate the importance of respecting the privacy of our customers. Our customers' trust is our most important asset, and we are committed to safeguarding against the unauthorized use of, and access to, customer information. This Privacy Notice explains our current policies and practices with respect to non-public personal information of our current and former customers.

In order to adequately service our customers, Lazard regularly collects certain non-public personal information about our customers. We limit the collection of information to the minimum amount required to deliver useful products and superior service to our customers, to comply with legal requirements and to support our business needs. We may collect personal non-public information about you from the following sources:

• Information we receive from you on applications, questionnaires, subscription agreements or other forms, including, but not limited to, your name, address, social security or other tax identification number, age, employment information, assets owned and income.
• Information about your transactions with us, our affiliates or others, such as your account balance and holdings, payment history and transaction information.
• Information we may receive from our due diligence, such as your creditworthiness and your credit history.
• Information obtained from our communications and correspondence with you.

Lazard does not disclose any non-public personal information about our customers or former customers to any third party, except as permitted by law. Lazard may, however, disclose such non-public personal information to its affiliates in order to provide products or services to you or to support our business needs. In order to maintain the confidentiality of such information, we restrict access to non-public information about our customers to those employees who need to know that information. We maintain physical, electronic and procedural safeguards, in accordance with strict standards, in order to guard the non-public personal information of our customers and former customers.

The policies and practices described herein are current policies, and are subject to change in the future.

Please note that Lazard will treat your information as confidential as described above. It is not necessary for you to respond to this notice or to separately request confidentiality.

For EU residents:

The following Privacy Notice is relevant to you if you reside in the EU.

In this Notice “LAZARD” (as well as the terms “we” or us”) refers to Lazard Gulf Limited of Level 2, Gate Village 01, Dubai International Financial Centre, PO Box 506644, DIFC, Dubai.

LAZARD is committed to protecting and respecting your privacy. This notice describes how we will collect and use your information both from your use of this website and through any services that we may provide to you and the rights you have in relation to your information.

We may collect information from you about your preferences through your use of this website, when you request information from us or engage with our services.

By using any of our services, including this website, and by providing us with any personal information, you are consenting to the use of your personal information as set out in this Notice. Please do not send us any personal information if you do not want that information to be used in this way.

References in this Notice to “your information” are also to personal information that you provide to us. LAZARD is the data controller of any information provided via this website and via our relationship with you.

INFORMATION WE COLLECT

LAZARD may ask for and collect from you personally identifiable and other information at certain points via this website and via your relationship and interactions with us. Depending on the information and/or services you request, you may be asked to provide your name, email address and other information including identification documents.

In addition to the information you knowingly provide, LAZARD collects the domain names and IP addresses of its website visitors, along with usage statistics (e.g., types of web browsers and operating systems used) and browsing history. This data is used to promote our services. LAZARD may combine this information with the personally identifiable and other information it collects.

HOW WE USE YOUR INFORMATION

At LAZARD we are committed to protecting and respecting your privacy and will only use your personal information:

• to provide and improve our services to you;
• to compile anonymous statistics, for example, website usage statistics;
• to market our services;
• to manage our relationship with you;
• to fulfill our legal obligations;
• to provide you with personalised content;
• to process and respond to enquiries;
• to alert you to new features, special events, and service offerings; and
• for other legitimate business purposes.

LEGAL BASIS FOR OUR USE OF YOUR INFORMATION

Our use of your information is limited to:

• Our contract with you (where relevant) whereby we must send you relevant reports and notices relating to your investments.
• Our obligation to comply with our legal requirements, in particular relating to anti-money laundering regulations regarding knowing our clients.
• Our legitimate interest to inform you about our products and services and analyse your preferences and interests so as to better understand your requirements and to adapt our offering accordingly.

HOW AND WHY WE SHARE YOUR INFORMATION

In order to achieve said purposes, your personal information may be communicated to authorised persons within LAZARD in charge of marketing, business development, client servicing, information technology, legal and compliance.

Please note that we may on occasion be required to share your information with other LAZARD group companies or branches around the world and other third parties who provide services to us or on our behalf. This may entail a transfer of your information from a location within the European Economic Area (the “EEA”) to outside the EEA, or from outside the EEA to a location within the EEA. The level of information protection in countries outside the EEA may be less than that offered within the EEA. However, we have procedures in place to ensure the protection of your information and we have taken steps to ensure that all such entities keep your personal information confidential and secure and only use it for the purposes that we have specified and have informed you of.

LAZARD may disclose your personal information to another entity (i) for purposes of outsourcing one or more of the functions described above; (ii) to confirm or update information provided by you; (iii) to inform you of events, information about our services, and other important information; or (iv) for other purposes disclosed at or before the time the information is collected. We may also share your information when legally required to do so.

YOUR RIGHTS

You have the right to apply for a copy of the information we hold about you. This is called a data subject access request and you can make a request by writing to us using the contact details below. We may require further information from you in order to verify your identity before disclosing any personal information to you.

You also have the right to have any inaccurate information about you corrected. We want to make sure that your information is accurate and up to date. You may ask us to correct or remove any information that you think is no longer up to date. Please contact us using the contact details below if you would like any corrections made to your information.

You also have the right to object to LAZARD’s processing of your personal information or request that LAZARD restricts the processing of your personal information.

To exercise the above rights, you can contact LAZARD by sending an email lam_dataprotection@lazard.com.

EMAIL MARKETING LIST AND MARKETING MESSAGES

We operate an email mailing list program, used to inform you about products, services and/or news we supply or publish. You can change your preferences for receiving group marketing emails, news/updates and other information from us at any time. You can unsubscribe at any time through an automated online service or, if this is not available, by contacting us.

Email marketing messages may contain tracking beacons / tracked clickable links or similar server technologies in order to track subscriber activity. Where used, such marketing messages may record a range of subscriber data relating to engagement, geographic, demographics and already stored subscriber data.

Please note that we may use your marketing and content preferences, and other information you provide to us in order to build a profile for you. We may supplement this profile with information about how you use our websites, review our content and interact with us. We use this profile to try and ensure that you only receive information that you are likely to find of interest.