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Oak Hill Advisors, L.P. and Certain Affiliated Entities Privacy Notice for Investors and Other Relevant Individuals

Commitment To Privacy

This Privacy Notice (“Notice”) is provided by Oak Hill Advisors, L.P. and, as applicable, the affiliates under its control, the funds we manage and their general partner entities (collectively, the “Firm” or “we,” “us” or “our”). We are committed to handling “non-public personal information” and “personal data” in accordance with applicable laws, rules and regulations.

This Privacy Notice applies to “Relevant Individuals,” defined in this Privacy Notice as anybody acting in one of the following capacities:

  • A visitor to our website located at oakhilladvisors.com (the “Website”);
  • An “Individual Investor,” i.e., a natural person investing with us or otherwise acting as our client in their individual capacity;
  • Directors and managers of the funds we manage; and
  • Any natural person affiliated with a client, investor or counterparty (such as an employee, director, officer, partner, member, shareholder, beneficial owner, affiliate, agent or representative).

In certain situations, such as when these individuals or others are interacting with us in relation to certain specific products, services, subsidiaries, affiliates, or digital properties, a separate privacy policy or privacy notice will apply instead of or in addition to this Notice.

This Privacy Notice is current as of the date stated at the end of the Notice, but as circumstances or requirements change, we may amend it. We will notify Relevant Individuals of any material amendment by posting an updated version on the Website and/or taking other steps.

What We Need You to Do

Please provide this Privacy Notice to any Relevant Individuals whose Personal Information (as defined above) may be provided to us. In addition, to the extent we are provided with sensitive Personal Data (as defined below), we recommend it is encrypted before being sent.

Key Concepts

“Personal data” (which may be referred to as “personal information”) is information relating to an identified or identifiable natural person (as further defined in the EU or UK General Data Protection Regulation (Regulation (EU) 2016/679) and any relevant transposition of, or successor or replacement to, that regulation and equivalent legislation in the UK (together, the “European Data Protection Legislation”), the Cayman Islands Data Protection Act and related regulations (together, the “Cayman Data Protection Legislation”), the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020, and their related regulations (collectively, “CCPA”), the Gramm-Leach-Bliley Act (“GLBA”) and other applicable laws and regulations relating to privacy, data protection, breach notification, or the processing of personal information). “Non-public personal information” is any personally identifiable financial information relating to natural persons that is not publicly available. We refer in this Privacy Notice to “non-public personal information” and other “personal data” together as “Personal Information”.
As applicable, the relevant Fund is a data controller.

Personal Information Collected

We may collect or otherwise process some or all of the following categories of Personal Information:

    • Identifiers, such as full name, residential/office address, and other contact information, as well as government-issued identification details (e.g., social security number, or details from a driver’s license, state or provincial identification card or passport);
    • Commercial information, such as:
      • information about a Relevant Individual’s interests in funds (such as account balances and percentage interests);
      • transaction and interaction information, such as transaction history, client service records, communications with or concerning us or the funds we manage by email or other methods, and other information about the Relevant Individual’s investments with us or other dealings with us;
      • other financial information (e.g., assets, net worth, income, investments, beneficial interests, investment history, bank account details, utility bills and other personal financial data);
    • Professional and employment information, such as education history;
    • Financial account information, including financial account number and in some cases a password, access code, or other credential that permits access to a financial account;
    • Account login credentials (usernames with password, access code or other credential that permits access to an account);
    • Internet or other electronic network activity information, including information collected by automated means when an individual visits the Website that may sometimes qualify as Personal Information, such as IP address, details about navigation on the Website, details about the individual’s browser or device, and a unique identifier or other information that we or our partners may store or read on the visitor’s browser or device with cookie technology (details further below);
    • Other Personal Information, such as date of birth, compliance program data including records related to tax laws, Know Your Customer (KYC), Office of Foreign Assets Control (OFAC), anti-money laundering (AML), and Foreign Corrupt Practices Act (FCPA), and background check information; and
    • Inferences we generate based on the data above.

    Where the client or investor (or other party engaging with us) is an individual acting on their own behalf, we will usually collect this information directly from the individual. Where the client or investor (or other party engaging with us) is an entity, we will usually collect the information from the client or investor or other party. Regardless of what the type of party engaging with us is, we may also collect this information from their professional advisors or agents. In some cases, we may receive the information from another type of third party, such as a background check provider.

    Some of the personal information we collect is described in Cal. Civ. Code Section 1798.80.

    Sensitive Personal Information – CCPA

    Some of the Personal Information described in the “Personal Information Collected” section above also constitutes “sensitive personal information” under the CCPA. We use and disclose sensitive personal information for our business and compliance functions and for other legally authorized purposes. We do not use or disclose it in a manner that would give rise to a right to limit its use or disclosure under the CCPA.

    • Government-issued identification numbers are used and disclosed for identification, compliance, and related purposes, and as otherwise authorized by the CCPA;
    • Account login credentials (user names with password, access code or other credential that permits access to an account) are used and disclosed as needed to allow you to access your account and/or account information, for related account security purposes, and as otherwise authorized by the CCPA; and
    • Financial account number, in some cases with a password, access code, or other credential that permits access to an account, are used and disclosed as needed, to allow you to access your account and/or account information, for related account security purposes, and as otherwise authorized by the CCPA.

    Uses of Personal Information

    We will use Personal Information for some or all of the following purposes:

    • to provide the service, information, or product requested;
    • to otherwise perform our obligations under contracts with Relevant Individuals or to take steps in anticipation of such contracts at their request;
    • on the basis of our legitimate interests in managing our relationship with the Relevant Individual (for example, to authenticate the Relevant Individual, to send transactional messages, and to maintain the integrity of our records);
    • on the basis of our legitimate interests in managing our business operations and information technology resources (for example, managing internal directories and client relationship management systems);
    • on the basis of our legitimate interests in protecting the Firm, its employees, clients, investors, trading partners and others (for example, risk management and fraud prevention);
    • to address legal requirements (including laws designed to protect the integrity of the financial sector, which require measures such as anti-money laundering checks and the recording of calls and emails); and
    • for Firm-related informational or marketing communications, where appropriate and permitted by applicable law, as part of our legitimate business interest.

    From time to time, we may also use a Relevant Individual’s Personal Information in other situations, such as with the Relevant Individual’s consent (for example, for certain marketing communications).

    Retention of Personal Information

    The Personal Information we collect, including sensitive Personal Information, will be retained for as long as necessary to satisfy the purposes for which it was collected and to meet our reasonable business requirements and legal obligations. As described above, these purposes include our business operations and complying with reporting, legal, tax and accounting obligations. In determining how long to retain information, we generally will consider the amount, nature and sensitivity of the information, the purposes for which we process the Personal Information and whether we can achieve those purposes in other ways, the applicable legal requirements, internal recordkeeping practices and/or our legitimate interests.

    Because we may collect and use the same category of Personal Information for different purposes and in different contexts, there is not typically a fixed retention period that always will apply to a particular category of Personal Information.

    Disclosures of Personal Information

    For the purposes described in the previous section, where permitted by applicable law, we may disclose Personal Information in some or all of the following ways:

    • to the client or investor;
    • within the Firm and our T. Rowe Price affiliates;
    • to other entities that assist in carrying out the activities described above, including professional advisors, technology providers, auditors, administrators, registrars, depositaries and other service providers;
    • to regulatory bodies and governmental authorities;
    • to other participants in certain transactions with us (for example, to assist another party in discharging their legal obligations in respect of, for example, anti-money laundering legislation and to honor their legal right to obtain a recording of certain regulated calls or a copy of certain regulated electronic communications between us and that other party);
    • to others (such as litigants, or an acquirer or others connected with an acquisition or similar transaction involving us); and
    • to agents, delegates, or related, associated or affiliated entities of the foregoing.

    From time to time, we may also disclose a Relevant Individual’s Personal Information in other situations, such as at the Relevant Individual’s request.

    Personal Information may be transferred to outside of the Relevant Individual’s state, province or country of residence, including to countries that may not have the same or equivalent data protection laws as those of the Relevant Individual’s home jurisdiction. For example, the Personal Information may be transferred among the Firm’s offices in the United States, the United Kingdom, Luxembourg, Australia or Hong Kong, as well as to any other countries where the recipients of the transfers described above are located. We make such transfers in compliance with the applicable law, such as (where required) through the use of standard contractual clauses published by the European Commission, with modifications relevant for other jurisdictions, such as the United Kingdom.

    Security of Personal Information

    We take steps to restrict access to Personal Information to our employees, representatives and agents who require access for the purposes described in this Notice, including through various physical, electronic, and procedural safeguards. The specific security measures we use in a particular context depend on that context, but we draw from measures such as access controls, malware defenses, encryption, facility security, and various monitoring strategies. We also maintain incident response procedures and other internal procedures and policies regarding our handling of Personal Information to facilitate our compliance with this Privacy Notice and applicable laws.

    Rights and Choices

    Where the European Data Protection Legislation, Canadian Privacy Laws, and the Cayman Data Protection Legislation or certain other laws apply, Relevant Individuals may have the right to:

    • In certain cases, object to our processing of their Personal Information.
    • Request access to their Personal Information (commonly known as a “data subject access request”). This enables the Relevant Individual to receive a copy of Personal Information we hold about them as well as certain details about its processing to be able to check that we are processing it lawfully.
    • Request correction of the Personal Information we hold about them. This enables Relevant Individuals to have incomplete or inaccurate information we hold about them corrected.
    • Request erasure of their Personal Information. This enables Relevant Individuals to ask us to delete or remove Personal Information if we do not need to continue to process it. Relevant Individuals also have the right to ask us to delete or remove their Personal Information where they have exercised their right to object to processing (see above).
    • Request the restriction of processing of their Personal Information. This enables Relevant Individuals to ask us to suspend the processing of their Personal Information, if, for example, the Relevant Individual wants us to establish its accuracy or the reason for processing it.
    • Under Canadian Privacy Laws, withdraw their consent to our processing of their Personal Information.
    • Request to receive a copy of their Personal Information in a machine-readable, commonly used and structured format, or to have it transmitted in such format to a third party.

    Some Relevant Individuals may have additional rights under certain laws. If a Relevant Individual wishes to exercise any of the rights they have, they should contact us using the contact details at the end of this notice, except that eligible Californian Relevant Individuals who wish to exercise the rights described in the “California Privacy Information” section below should contact us as described in that section. The various rights are not absolute and each is subject to certain exceptions, qualifications and conditions. For example, if a Relevant Individual wishes to object to processing or withdraw their consent, we may need to discuss with the Relevant Individual whether our use of their Personal Information needs to continue for certain lawful purposes, such as fulfilment of a legal or contractual requirement.

    We will respond to a Relevant Individual’s request within the legally mandated deadline for a response. In some cases, we may not be able to fulfill the request to exercise the right by this date and may need more time. Where we cannot provide a full response to the Relevant Individual for any reason, we will endeavor to let the Relevant Individual know about this in its initial reply to the request.

    Where these rights apply, a Relevant Individual will not normally have to pay a fee to access their Personal Information (or to exercise any of the other rights described above). In some cases, where permitted by law, we may charge a reasonable fee if the request for access is unfounded or excessive, or if the Relevant Individual requests multiple copies of the information. Alternatively, where permitted by law, we may refuse to comply with the request in such circumstances. We may need to request specific information from the Relevant Individual to confirm their identity and ensure their right to access the Personal Information (or to exercise any of their other rights). For example, we may request that you confirm, depending on the sensitivity of the information involved, the nature of our relationship with you, and the type of request you are making. We may also require your cooperation for steps such as verifying your name, email address, account number, and other information regarding your relationship with us.

    If Relevant Individuals have any questions, concerns or complaints relating to our handling of their Personal Information, they should contact us as described below. Relevant Individuals may also contact the relevant governmental authority (e.g., the UK Information Commissioner’s Office, for UK individuals, or the Luxembourg National Commission for Data Protection for Luxembourg individuals) with a complaint related to our handling of their Personal Information. However, we invite Relevant Individuals to allow us to try to resolve the situation directly. Privacy is important to us, and we will do our best to address any concerns.

    Notwithstanding anything to the contrary in this Privacy Notice, Relevant individuals will have the rights described above only to the extent that such rights apply to such Relevant Individuals under applicable law.

    California Privacy Information – CCPA

    This section provides detailed information applicable only to eligible California residents under the CCPA. This section does not apply to Individual Investors, as our processing of their Personal Information is exempt from the CCPA, and it also does not cover any other Personal Information for which we are exempt from the CCPA, such as “publicly available information” as defined in the CCPA. Data that is not subject to the CCPA may be handled differently than described here.

    During the past 12 months, we may have collected all of the types of personal information described in the “Personal Information Collection” section of this Privacy Notice, and disclosed at least some of each category of personal information in some instances to our affiliates, service providers and other entities that assist us with our business. We also made the other disclosures described in this paragraph. We disclosed government-issued identification details (e.g., social security number, or details from a driver’s license, state identification card or passport), other identifiers (such as full name, residential address and other contact information) and professional and employment information to regulatory bodies and governmental authorities, transaction participants and entities involved in legal matters. We disclosed other Personal Information (except account credentials, inferences and internet or electronic network activity), such as date of birth and background check information, to regulatory bodies and governmental authorities, transaction participants and entities involved in legal matters. We made these disclosures of personal information about Californians for the purposes described in the “Disclosure of Personal Information” section above.

    We do not “sell” or “share” Personal Information (as those terms are defined in the CCPA) nor have we over the last 12 months. We do not “sell” or “share” personal information if we have actual knowledge that the individual is less than 16 years of age.

    Subject to some limitations, the CCPA allows you to ask us to:

    • provide access to and/or a copy of certain personal information we hold about you;
    • correct certain personal information we have about you;
    • delete certain personal information we have about you; and
    • inform you about the categories of personal information we have collected about you in the preceding 12 months, the categories of sources of such information, the business or commercial purpose for collecting or selling your personal information, the categories of third parties to whom we have disclosed certain personal information, confirmation that we did not “sell” or “share” your Personal Information, and more specific detail about what categories of information were otherwise disclosed to particular categories of third parties.

    If you would like to exercise any of these rights, you may submit your request by completing the CCPA Rights Request Form on our website or calling us at 1 (888) 992-0501. We may need to request specific information from the Relevant Individual to confirm their identity and ensure their right to access the Personal Information (or to exercise other rights). For example, we may request that you confirm, depending on the sensitivity of the information involved, the nature of our relationship with you, and the type of request you are making, your name, email address, account number, and other information regarding your interactions with us.

    You can designate an authorized agent to make a CCPA request on your behalf. To do so, we must receive a legally sufficient power of attorney signed by you pursuant to California Probate Code sections 4121 to 4130, or other written authorization acceptable to us, for the agent to act on your behalf. You may still need to verify your identity and confirm the agent’s authority directly with us. For security and legal reasons, we may refuse to accept requests that require us to visit an agent’s website. You also have a right not to receive “discriminatory treatment” (within the meaning of the CCPA) for the exercise of the privacy rights conferred by the CCPA.

    Cookies

    We and service providers and vendors may collect information from your computer or other device by automated means such as cookies, web beacons, local storage, JavaScript, mobile-device functionality and other computer code (collectively, “cookies”). This information may include unique browser identifiers, IP address, browser and operating system information, device identifiers, other device information, Internet connection information, as well as details about your interactions with our Website (for example, the URL of the website from which you came, the pages on our Website that you visit, and the links you click on in our Website). In some cases (such as cookies), the tools described here may involve storing unique identifiers or other information on your device for later use.

    You may be able to set your browser to refuse certain types of cookies, or to alert you when certain types of cookies are being used. Some browsers offer similar settings for HTML5 local storage and other technologies. However, if you block or otherwise reject cookies, local storage, JavaScript or other technologies, some current or future interactive aspects of our Website may not function as expected.

    Contacting Us

    To exercise any rights under applicable law (including to request further information on the mechanisms we have put in place in relation to Personal Information transfers outside the European Union and/or the UK), to notify us of your preferences, or to provide us with complaints, concerns or questions, please contact our Chief Compliance Officer via oakhilladvisorsupdate@oakhilladvisors.com, as well as, if your notice relates to your rights under the European Data Protection Legislation, via GDPR@oakhilladvisors.com. Californians wishing to exercise CCPA rights should contact us as described in the CCPA section of this Notice.

    Effective: February 21, 2024