36 South Capital Advisors LLP Privacy Notice

Introduction

This notice (the “Privacy Notice”) is provided by 36 South Capital Advisors LLP (the “Investment Manager”, “36 South”, “we”, “us” or “our”), which manages several private investment funds (the “ Funds”), including the Fund you are invested in, or are intending to invest in. This notice sets forth our policies for the collection, use, storage, sharing, disclosure (collectively, “processing”) and protection of personal data and/or customer information relating to:

• current, prospective and former investors in the Funds, as applicable (“Investors”);
• beneficial owners of shares in the Funds, or applicants for shares, personal representatives of Investors or beneficial owners, directors, officers, trustees and / or authorised signatories of Investors, and other authorised contacts of Investors ("Connected Persons"); and
• not Investors or Connected Persons, but other persons who otherwise have contact with the Investment Manager and/or the Funds for business reasons such as partners, advisors, agents and any natural persons who is employed or engaged by service providers of the Funds ("Business Contacts").

In this Privacy Notice, Investors, Connected Persons and Business Contacts are together referred as “you” or "Individuals".

If you are an institutional investor that provides us with personal data on Connected Persons or Business Contacts, this Privacy Notice will be relevant for those Individuals and you should transmit this document to such Individuals or otherwise advise them of its existence and content.

Who to Contact About This Privacy Notice

This Privacy Notice is being provided in accordance with the applicable requirements under the privacy and data protection laws that apply in the jurisdictions where we operate, including but not limited to (i) the General Data Protection Regulation (Regulation (EU) 2016/679 of the European Parliament and the Council of 27 April 2016 (the “GDPR”); (ii) the Data Protection Acts 1988 to 2018 in Ireland, as may be amended, replaced or succeeded from time to time; (iii) the GDPR as it forms part of the law of England and Wales, Scotland and Northern Ireland by virtue of section 3 of the European Union (Withdrawal) Act 2018 and as amended by the Data Protection, Privacy and Electronic Communications (Amendments etc.) (EU Exit) Regulations 2019; (iv) the U.S. Gramm-Leach-Bliley Act 1999 (Reg S-P) and Fair Credit Reporting Act (Reg S-AM); and (v) Cayman Islands Data Protection Act (2021 Revised) (“DPA”), (collectively, the “Data Protection Laws”).

Please note: “personal data” is the language used in European and UK legislation and regulations (e.g., GDPR) whereas “customer information” and "nonpublic personal information" is the language used in U.S. legislation and regulations (e.g., Regulation S-P). In practice, these terms have similar meanings, and the procedures described in this Privacy Notice relate to personal data and customer information. Throughout this document, any use of the term “personal data” can also be taken to mean “customer information” or "personal information".

The Investment Manager and the Funds are considered to be data controllers in respect of any personal data we hold about you for the purposes of certain Data Protection Laws. This means that the Investment Manager and the Funds determine the purposes and the means of the processing of your personal data.

Please contact our compliance team on [email protected] with any questions about this Privacy Notice or requests with regards to the personal data we hold.

We may need to make changes to this Privacy Notice from time to time and shall do so by amending the version of this Privacy Notice published at www.36south.com. We will notify you of any material changes via the fund administrator’s “investor portal”, by posting the updated notice on our website (link above), or by other appropriate means. We encourage you to review this Privacy Notice regularly to stay informed about how we protect your Personal Data.

SEI Investments - Global Fund Services Limited, (the "Administrator") may use your personal data where this is necessary for compliance with a legal obligation to which it is directly subject (i.e., to comply with applicable law in the area of anti-money laundering (“AML”), where required for global tax reporting purposes, or where mandated by a court order or regulatory sanction).

The Administrator, in respect of these specific uses of personal data, acts as a separate data controller. For the avoidance of doubt, the Administrator will not at any time be acting as a joint controller with us. Please contact the Administrator if you want further information on the specific legal obligations which are necessary for them to process your personal data.

A copy of the SEI's privacy notice can be found here: https://www.seic.com/en-gb/privacy-notice.

Where a third-party service provider acts as a data controller, the use by that third party of the personal data will be subject to the third party’s own privacy policies. If you have any queries regarding such processing, please contact the third-party service provider directly.

The Types of Personal Data We May Hold

"Personal Data" means any information which we have or obtain concerning an identified or identifiable Individual. Examples of personal data include:

• Identity Data – being name, signature, nationality, place of birth, date of birth, passport number, social security number or similar identifier, signature, marital status, title and gender;
• Contact Data – – being residential address, email address, contact details, corporate contact information, and correspondence records;
• Financial Data – being bank account details, tax identification, credit history, source of funds details, information about your financial circumstances including net assets and the size of your investment portfolio, and details relating to your investment activity;
• Marketing and Communication Data – being your preferences in receiving marketing from us and our third parties and your communication preferences; and/or
• Technical Data – includes your internet protocol (IP) address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website and/or platform.

Some of this personal data may be “special category” personal data, such as data revealing racial or ethnic origin, political opinions, trade union membership or criminal convictions. We may, in limited circumstances, collect and process this data in connection with our obligations under applicable AML legislation. Any special category personal data will only be used and disclosed, as necessary, for such purpose. Such special categories of personal data, as specified under the applicable Data Protection Laws, may be contained in relevant materials, documents, or obtained through background searches.

How We Collect Personal Data

We may collect personal data about you through: (i) information provided directly to us by you, or another person on your behalf; (ii) information that we obtain in relation to your investment in one of the Funds, or any transactions between you and us; and (iii) recording and monitoring of telephone conversations and/or email or other electronic communications with you.

We also may receive your personal data from third parties or other sources, such as our affiliates, the Administrator, publicly accessible databases or registers, tax authorities, governmental agencies and supervisory authorities, credit agencies, fraud prevention and detection agencies, or other publicly accessible sources, such as the Internet.

How We May Use Personal Information

We may collect, store and use the following categories of personal data under the following lawful bases for the lawful purposes described below:

Contract: We process Identity, Contact, Technical and Financial Data to reflect Investors' ownership of shares in the Funds (i.e., where this is necessary for the performance of the contract and to purchase shares in the Funds or to process redemption, conversion, transfer and additional subscription requests or the payment of distributions) where this is necessary for the performance of a contract with Investors;

Legal Obligation: We may process Identity, Contact and Financial Data of Investors and Connected Persons to discharge to discharge legal obligations of any jurisdiction to which we are subject, including, as applicable, in order to:

• undertake our AML and beneficial ownership due diligence on clients and Investors, including politically exposed persons screening, in accordance with applicable legislation, such as the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010, and financial sanctions screening, in order to comply with the financial sanctions regimes imposed by the EU, United States, the United Nations and any other relevant authorities;
• ensure that beneficial ownership information is held on a central register, pursuant to the relevant applicable law namely, the European Union (Anti-Money Laundering: Beneficial Ownership of Corporate Entities) Regulations 2019 (S.I. 110 of 2019) (modified by the European Union (Modifications of Statutory Instrument No. 110 of 2019) (Registration of Beneficial Ownership of Certain Financial Vehicles Regulations 2020) (S.I. No. 233 of 2020);
• comply with tax reporting obligations under applicable legislation, such as the Taxes Consolidation Act 1997;
• comply with regulatory requirements applicable to managing your investment, for example under the European Union (Alternative Investment Fund Managers) Regulations 2013, as well as the Central Bank of Ireland’s AIF Rulebook, guidelines and policy updates issued by the Central Bank of Ireland from time to time;
• maintain statutory registers including in accordance with Irish Collective Asset-management Vehicles Act 2015;
• comply with applicable legal sanctions requirements, such as those required under Irish, EU, UK, U.S., Cayman Island or other applicable jurisdictions; and/or
• comply with requests from regulatory, governmental, tax and law enforcement authorities, such as the EU and/or EU member states, the UK, U.S. and Cayman Islands, as applicable.

All references to laws are as may be amended, supplemented, consolidated, substituted in any form or otherwise modified from time to time.

Legitimate Interest: We may process Identity, Contact, Financial, Marketing, Technical and Communications Data of Individuals where this is necessary for our legitimate interests for day to day operational and business purposes, to take advice from the Fund’s external legal and other advisors, board reporting and management purposes (including quality assurance, business, risk and statistical analysis for tracking fees and costs, or for customer service and training-related purposes) and in carrying out our direct marketing activities (that is, us providing you with information on products and services) , in the event of a merger or proposed merger of the Fund or any sub-fund of the Fund, or any other restructuring or reorganisation of the Fund or any sub-fund of the Fund or relating to the assets of the Fund or any sub-fund of the Fund; or where necessary to establish, exercise or defend its legal rights or for the purpose of legal proceedings.

Where we process personal data on the basis of our legitimate interests, we do so in a fair, transparent and accountable manner and take appropriate steps to prevent such activity having any unwarranted impact on you. We do not process your personal data where such legitimate interests are overridden by your interests, fundamental rights or freedoms. You have a right to object to us processing your personal data on the basis of our legitimate interests.

Consent: Should we wish to use your or your Connected Persons' personal data for other specific purposes (including, if applicable, any purpose that requires your consent), we will contact you.

What Are the Consequences of Failing to Provide Personal Data

Where we require personal data of Investors and/or Connected Persons (e.g., to comply with AML or other legal requirements) failure to provide this information means we may not be able to deal with such Individuals, or the Investor to which the Individual is connected. Identity, Contact and Financial Data is required to assess your application and perform our contract with Investors. Failure to provide such information may result in your subscription in the applicable Fund being rejected or your Shares or Interests becoming subject to compulsory redemption or withdrawal, as applicable. Where there is suspicion of unlawful activity, failure to provide personal data may result in the submission of a report to the relevant law enforcement agency or supervisory authority.

How We May Share Personal Data

We may disclose information about you to our affiliates, service providers or other third parties to accept your subscription, administer and maintain your account(s), perform our contractual obligations with you or otherwise engage in business activities with you.

We anticipate that the following affiliates and delegates will process your Personal Data on our behalf and this may include certain entities located outside the European Economic Area (the “EEA”):

• the Administrator; auditor; legal counsel; and other service providers who assist us in providing and managing our services and products;
• 36 South Investment Managers (Cayman) Limited, which is the Procurement Agent of Kohinoor Core (Cayman) Master Fund and its Feeder Funds (this is relevant to our funds domiciled in the Cayman Islands and Delaware, U.S.).
• 36 South Investment Managers (Ireland) Limited, which is the Management Company of 36 South Funds ICAV and its sub funds (this is relevant to our funds domiciled in Ireland).
• any distributors, intermediaries, brokers, and agents, who may be appointed from time to time in order to assist us in marketing and selling our services and products;
• where the fund needs to share Investor’s and Connected Person’s personal data with courts, regulators, tax authorities, and other competent authorities, and who require us to disclose your personal data for legal or regulatory purposes;
• other third parties, and who may be involved in any merger, acquisition, reorganisation, or transfer of the Fund or its assets, or in any litigation, dispute, or claim involving the Fund;

and each of their respective affiliates and delegates.

Where We May Transfer Your Personal Data

Certain of our affiliates and delegates are located outside the EEA:

• Where we transfer personal data from the EEA to the United Kingdom, we transfer this personal data on the basis of Article 45 of the Data Protection Legislation (Transfers on the basis of an adequacy decision).
• In the event that we transfer personal data to other jurisdictions outside of the EEA (such as the United States of America), to a country in respect of which the European Commission has not adopted an adequacy decision, such transfer will be on the basis of Article 46 of the Data Protection Legislation (Transfers subject to appropriate safeguards).

We ensure that appropriate safeguards are in place in respect of any such transfer such as standard contractual clauses as adopted by the European Commission in accordance with Article 46(2) of the Data Protection Legislation on 4 June 2021.

Please contact us if you wish to obtain more information on the appropriate safeguards. See "Getting in Touch" below.

Retention Periods and Security Measures

We or our duly authorised delegates may retain your personal data for as long as necessary for the purpose for which it is processed, including to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. We or our duly authorised delegates may retain your personal data for a period of up to seven (7) years following your disinvestment from the Fund or following the point where your business relationship with us has ceased or potentially for a longer period where necessary for compliance with a legal obligation or for the establishment, exercise or defence of legal claims.

Thereafter, we and our duly authorised delegates will refrain from collecting any further personal data on you and shall take appropriate steps to dispose of, delete or anonymise any records containing your personal data, to the extent this is operationally feasible and proportionate. Where your personal data has been anonymised, we may retain this information indefinitely. To protect your personal data from unauthorised access and use, we apply organisational and technical security measures in accordance with applicable Data Protection Laws. These measures include computer safeguards and secured files and buildings.

We will notify you of any material personal data breaches affecting you in accordance with the requirements of applicable Data Protection Laws.

Your Data Protection Rights

You have certain rights regarding our use of your personal data summarised as follows:

• the right to access your data (in an easily readable form);
• the right to examine and correct your data;
• the right of erasure and/or to restrict the use of your data;
• the right to data portability;
• the right to withdraw any consent given to the processing of your data (where applicable) without affecting the lawfulness of the processing carried before withdrawal of consent;
• the right to receive information regarding any entities we disclose your data to;
• the right to request not to be subject to a decision based on automated processing (including profiling) which produces legal or similarly significant effects and to have safeguards in place if any such processing occurs; and
• the right to lodge a complaint with the Data Protection Commission (our lead supervisory authority) or a supervisory authority in the EU member state of your usual residence or place of work.

Please note that the right for your data to be erased (the "right to be forgotten") that applies in some contexts is not likely to be applicable to most, if not all, of the personal data we hold, given the specific nature of the purposes for which we use the data, as described above.

Monitoring of Communications

We may record and monitor telephone conversations and electronic communications with you for the purposes of: (i) ascertaining the details of instructions given, the terms on which any transaction was executed or any other relevant circumstances; (ii) ensuring compliance with our regulatory obligations; and/or (iii) detecting and preventing the commission of financial crime.

Additional Information Under U.S. Gramm-Leach-Bliley Act 1999 (Reg S-P) and Fair Credit Reporting Act (Reg S-AM)

For purposes of U.S. federal law, this Privacy Notice applies to current and former Investors who are individuals or individual retirement accounts. We are providing this additional information under U.S. federal law.

We may disclose information about our Investors to affiliates (i.e., financial and non-financial companies related by common ownership or control) or non-affiliates (i.e., financial or non-financial companies not related by common ownership or control) for our everyday business purposes, such as to process your transactions, maintain your account(s) or respond to court orders and legal investigations. Thus, it may be necessary or appropriate, under AML and similar laws, to disclose information about the Investors in order to accept subscriptions from them. We will also release information about you if you direct us to do so.

We may share your information with our affiliates for direct marketing purposes, such as offers of products and services to you by us or our affiliates. You may prevent this type of sharing by contacting us at +44 203 205 3000 or by emailing [email protected]. If you are a new investor, we can begin sharing your information with our affiliates for direct marketing purposes 30 days from the date we sent this Privacy Notice. When you are no longer our investor, we may continue to share your information with our affiliates for such purposes.

You may contact us at any time to limit our sharing of your personal information. If you limit sharing for an account that you hold jointly with someone else, your choices will apply to everyone on your account. U.S. state laws may give you additional rights to limit sharing.

We do not share your information with non-affiliates for them to market their own services to you.

Additional Information Under Cayman Islands Data Protection Act (2021 Revised) (“DPA”)

The Fund in which you are invested (or which you intend to invest in) may share your personal information with its services providers, including the Investment Manager, Administrator, Custodian(s), Prime Broker(s), or others who are located outside the Cayman Islands. It may also be necessary to share your information with the Cayman Islands Monetary Authority or the Tax Information Authority, which may, in turn, exchange this information with foreign tax authorities, regulatory or law enforcement agencies. Any transfer of your personal data by us, our affiliates or service providers outside the Cayman Islands will be carried out in accordance with the DPA.

You may have certain rights under the DPA, including: (i) the right to be informed; (ii) the right of access; (iii) the right to rectification; (iv) the right to stop or restrict processing; (v) the right to stop direct marketing; (vi) rights in relation to automated decision making; (vii) the right to seek compensation; and (viii) the right to complain to the supervisory authority. A complaint in respect of a Fund formed and established in the Cayman Islands may be lodged with the Office of the Ombudsman in the Cayman Islands. Please use the contact details under Who to Contact About This Privacy Notice if you wish to exercise these rights.

Due to the international nature of our business, your personal data may be transferred to jurisdictions that do not offer equivalent protection to personal data as under the GDPR (“Third Countries”). In such cases, we will process personal data (or procure that it be processed) in the Third Countries in accordance with the requirements of GDPR, which may include having appropriate contractual undertakings in legal agreements with service providers who process personal data on our behalf in such Third Countries. We may also be required to transfer your personal information to our regulators or government agencies in Third Countries in cases where such transfers are necessary in the context of administrative proceedings, such as requests for information, examinations or investigations, or to other relevant parties in Third Countries where it is necessary for the purposes of establishing, bringing, or defending legal claims, or for another legitimate business purpose, such as compliance with our legal or regulatory obligations under foreign law.

Rev. September 2025