Privacy Notice

Last Updated: September 1, 2026

Fisher Lynch Capital, LLC and its affiliates (“FLC”, “we”, “us”, “our”) respect the privacy of our investors and visitors to our website (“Site”). When you interact with the public sections of our Site or otherwise communicate or interact with us (collectively, “Services”), we may collect and process certain information about you, including information that is considered “personal information” or “personal data” under applicable law (“Information”). This Privacy Notice (“Notice”) is being provided to you to comply with applicable law so that you will know the types of Information we may collect about you, how we may use such Information, and the circumstances under which that Information may be disclosed to third parties (as well as the types of third parties). This Notice also details how we protect your Information once it is collected and how you can exercise your choices and rights with respect to your Information.

This Notice does not cover or include any of FLC’s advisory or investment services or the investor portal accessible via the Site. If you are an investor in a fund or the holder of an account managed directly or indirectly by us (or, in either case, their representative), please refer to FLC’s Notice Regarding Privacy of Financial Information,  Privacy Notice for California Residents, or GDPR Data Protection Notice (each as they are applicable), available in our investor portal or otherwise provided to you, for further information about how FLC collects and processes Information about its current, prospective, and former investors.

This Notices Describes:

• Information We Collect and How We Collect It
• Use of Your Information
• Protection of Your Information
• Disclosure of Your Information
• Cookies and Other Similar Technologies
• Your Choices and Rights
• Retention of Your Information
• Children’s Privacy
• Links to Third-Party Websites and Services
• Changes to this Notice
• Questions about this Notice
• California Supplement
• EEA and UK Supplement
• FLC GDPR Data Protection Notice

Information We Collect and How We Collect It

In the course of your use of our Services, we may collect Information directly from you. Such Information include:

• Name and contact information: when you communicate with us via our Site, email, phone, or any other forms of communication, you may provide us your name and contact information (e.g., physical address, email address and/or telephone numbers);
• Professional and employment-related information: such as your job title if you contact us on behalf of your employer or another business; and
• Communication content: when you communicate with us, we also may collect any other Information you choose to provide in your or communications (e.g., contents of your emails).  

When you visit or interact with our Site, we may collect Information about you and your devices by automated means, using cookies and other similar technologies. For more information regarding such technologies, please refer to the Cookies and Other Similar Technologies section below and our Cookie Notice. The Information we collect in this manner may include:

• Device information: such as your device ID, unique device identifier, web browser characteristics and/or type, device characteristics and/or type, operating system, domain server, and language preferences;
• Internet or other network activity information: such as your IP address;
• Geolocation data: such as your general location based on your IP address; and
• Clickstream and usage data: such as information regarding your usage of or interactions with our Site, including the referring URLs, the URLs you visit when leaving our Site, the pages or content viewed, the links clicked, items downloaded, clicks or scrolls, dates and times of Site visits and time spent on Site.

We may also collect Information about you from third parties, such as our service providers. We also may collect:

• Publicly available information: such as information from public databases, registers, media search results, industry associations and other public sources.
• Social media data: such as comments, content or details that you post on publicly available websites or social media platforms, including any information that accompanies those posts (e.g., your name, username, email address, your likes/preferences or profile picture), subject to your privacy settings on these platforms and/or websites.

Use of Your Information

We may use your Information for the following purposes:

• Providing and improving our Services: to provide, maintain, improve and personalize your experience on the Site;
• Operating business and improving our Services: to maintain and support our internal business functions, including finance, accounting, and auditing;
• Communications: to respond to your inquiries and other communications and provide customer service;
• Maintaining security of our systems: to help maintain the safety, security, and integrity of our Site, including to detect, investigate, and prevent security incidents and other malicious, deceptive, fraudulent, or illegal activity;
• Compliance with Law: to comply with our legal and financial obligations, including to respond to law enforcement requests as required by applicable law, court order or governmental regulations;
• Corporate change of control: to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of all or any portion of our, our affiliates’, or an FLC’s fund’s assets, whether as a going concern or as part of a bankruptcy, liquidation, or similar proceeding;
• Protecting our interests: to protect the rights and property of FLC and to otherwise enforce our rights, such as enforcing our Terms and Conditions; and
• Other purposes: to fulfill the purpose for which you provide it, such as to respond to your inquiries or for any other purpose disclosed by us when you provide the information.

Protection of Your Information

We have implemented and maintain physical, electronic, and procedural safeguards to guard your Information from unauthorized access, use or disclosure. For example, we restrict internal access to Information about you to those employees who need to know that information to provide services to you. In addition, we will continue to assess new technology for protecting such information. While we seek to protect your Information to ensure that it is kept confidential, we cannot absolutely guarantee that any information, during transmission through the Internet or while stored on our system or otherwise in our care, will be absolutely safe from intrusion by others, such as hackers.

Disclosure of Your Information

We may disclose your Information as described below:

• to our affiliates and subsidiaries, who may use your Information for purposes consistent with this Notice;
• to our service providers, including our professional advisors and consultants, we use to operate this Site, provide our Services and/or support and manage our business;
• to government authorities, such as law enforcement, if we are required to do so by law, regulation, or a legal process (e.g., subpoena) or in the good faith belief that such disclosure is necessary to comply with a legal obligation, to protect and defend our rights or property, act in urgent circumstances to protect the personal safety of users of the Site or the public, or protect FLC against legal liability;
• to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of all or any portion of our, our affiliates’, or an FLC’s fund’s assets, whether as a going concern or as part of a bankruptcy, liquidation, or similar proceeding, your Information may be transferred along with such assets; and
• to third parties with your consent and/or at your direction.

We may aggregate and/or de-identify your Information such that it is no longer able to be linked to you or your device(s). This Notice does not limit our ability to use or disclose such aggregated or de-identified information, which we may disclose in our sole discretion. To the extent we process any aggregated and/or de-identified information, we will maintain and use such information in aggregated and/or de-identified form and will not attempt to re-identify the information, unless permitted by applicable law.

Cookies and Other Similar Technologies

• When you visit our Site, we collect certain Information about you and your devices by automated means, using cookies and other similar technologies. As further detailed in our Cookie Notice, cookies are small data files that websites send to your computer or device to recognize your browser or to store information or settings in your browser. For example, we use “strictly necessary” cookies for the operation of our Site, including cookies used to remember your cookie preferences and security-related cookies used to protect our contact form from spam and abuse. We also use limited “functional cookies” in connection with our contact form and reCAPTCHA functionality. These technologies help ensure that the Site functions properly, that user consent choices or cookie preferences are recorded, and that form submissions are protected against fraudulent or automated activity. For more information about these technologies and how to communicate your choices regarding their use, please refer to our Cookie Notice and Choices and Rights section below.

Your Choices and Rights

• Email Communications: If FLC sends you email communications about services that we think may be of interest to you, you may opt out of receiving such communications by following the instructions set forth in such communications. In addition, if at any time you wish not to receive any future email communications or you wish to have your name deleted from our mailing lists, please contact us as indicated below.
• Browser and Device Settings: Most browsers can be set to detect cookies and give you an opportunity to reject them, but refusing cookies may, in some cases, inhibit or preclude your use of our Site or certain features, including the contact form. Our Site does not currently respond to “Do Not Track” signals. To learn more about how to manage cookies on different browsers, you can visit the website, www.allaboutcookies.org  or https://ico.org.uk/for-the-public/online/cookies/.

You may also change your cookie preferences at any time through our cookie consent banner. To access the banner again, click “Cookie Preferences” in the bottom part of our Site.

• Privacy Rights: In addition to the above, depending on the jurisdiction of your residence, you may be afforded, in accordance with applicable law, certain rights respect to your Information. If you are a resident of California, please see our California Supplement for more information. If you are a resident of the European Economic Area or United Kingdom, please see our EEA and UK Supplement for more information.

Retention of Your Information

We will retain your Information for as long as necessary to provide our Services and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. The data retention period will be determined by various criteria, including the nature and sensitivity of the Information, purposes for which we are using it and our legal obligations (including any applicable statutes of limitations and records retention requirements). Generally, we endeavor not to keep your Information in an identifiable form for any longer than is needed. At the end of the applicable retention period, we may destroy, erase from our systems, or anonymize your Information as part of such efforts.

Children’s Privacy

Our Site and Services are not intended for individuals under the age of 16 and FLC does not knowingly collect Information from individuals under the age of 16. If you are a parent or legal guardian and you believe we have collected your child’s Information, please contact Dana O’Brien at compliance@fisherlynch.com. 

Links to Third-Party Websites and Services

Our Services may contain links, banners or widgets that lead to other websites or online services (such as social media platforms) not owned or operated by us. For example, our Site may include features that allow you to share or publicly post content from our Site to your profile on a third-party social media platform (e.g., LinkedIn). We are not responsible for these other sites or online services, and their posted privacy policies (not this Notice) will govern the collection and use of your Information on them. We encourage you to read the privacy policies of each website or online service visited after leaving our Site to learn about how your information is treated by others.

We maintain a presence on certain social media platform, to communicate with our customers. This Notice applies to our use of Information you submit to us on such platforms or receive about you from such platforms, but it does not apply to what those third-party platforms do with your Information. As noted above, these platforms have their own privacy policies. In accordance with those policies (and your privacy settings within your social media accounts), information about your activities on those platforms (such as “John“ likes or follows “Fisher Lynch Capital”) may be published to your social media account.

Changes to this Notice

The Notice may change from time to time and at our discretion. We encourage you to review this Notice regularly to stay informed about our privacy practices.

Questions about this Notice

To ask questions about this Notice or our privacy practices, please contact Dana O’Brien at compliance@fisherlynch.com.

California Supplement

Last Updated: September 1, 2026

This California Supplement (“California Supplement”) provides information for residents of California (“you”). This California Supplement should be read with our Privacy Notice to fully understand our collection, use and disclosure of your personal information.

For purposes of this California Supplement, “personal information” shall mean any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to any individual or a household. Any other terms used here and not otherwise defined in our Privacy Notice shall have the meanings given to them in the Consumer Privacy Act, Cal. Civ. Code § 1798.100 et seq., as amended and the regulations promogulated thereunder, (collectively, the “CCPA”).

We may collect (and may have collected in the preceding 12 months) the following categories of personal information for the purposes described in the “Use of Your Information” section of our Privacy Notice:

• Identifiers, such as name and contact information (e.g., email address, physical address, telephone number); online identifier (e.g., device identifier, cookie ID, etc. IP address) and other similar identifiers.
• Internet or other Electronic Network Activity Information: Internet and other electronic network activity information, including information regarding your interaction with our Site.
• Geolocation Data: such as your general location information based on IP address.
• Professional or employment-related information, such as, your job title. 
• Inferences: inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, attitudes, and aptitudes.

Sensitive Personal Information

Certain categories of personal information listed above may be considered sensitive personal information as defined under the CCPA. We do not collect or use sensitive personal information for the purpose of inferring characteristics about you. We do not use or disclose sensitive personal information for any purposes other than the purposes permitted under the CCPA.

We collect (and may have collected in the preceding twelve (12) months) the categories of personal information above from you (both directly and indirectly) and from the following categories of sources:

• our affiliates and subsidiaries; and
• our service providers (vendors who perform services to or on our behalf), including our professional advisors and consultants.

We may disclose (and may have disclosed in the preceding 12 months) the categories of personal information above to the following third parties for the purposes described in the “Use of Your Information” section of our Privacy Notice:

• our affiliates and subsidiaries;
• our service providers (vendors who perform services to or on our behalf), including our professional advisors and consultants);
• government entities; and
• other third parties, such as in connection with a corporate change of control (as described in our Notice), or at your direction.

We do not sell or share, as defined or as contemplated by the CCPA, (and have not sold or shared in the preceding twelve (12) months) your personal information. We do not sell or share, as defined and contemplated by the CCPA, personal information of minors under the age of 16.

Your Rights

Subject to certain exceptions, the CCPA provides you with specific rights regarding your personal information.

• Right to Know and Data Portability: You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Such information includes the following, as applicable:
  • the categories of personal information we collected about you
  • the categories of sources from which we collected your personal information
  • our business or commercial purpose(s) for collecting, disclosing, selling or sharing that personal information
  • the categories of third parties with whom we disclose, sell, or share personal information
  • if we sold, shared, or disclosed your personal information for a business purpose:
    • the categories of personal information sold or shared and the categories of recipients to whom we sold or shared personal information; and
    • the categories of personal information disclosed and the categories of recipients to whom we have disclosed personal information
  • the specific pieces of personal information we collected about you (also called a data portability request).
• Right to Correct: You have the right to request that we correct any inaccuracies in the personal information we have collected about you.
• Right to Delete: You have the right to request that we delete the personal information we have collected from you.

How to Exercise Your Rights

To exercise your right to know, correct or delete your personal information, please submit a request by contacting Dana O’Brien at compliance@fisherlynch.com or 617-406-3120. Only you, or someone legally authorized to act on your behalf, may make a request. You may only submit a request to know twice within a 12‑month period. Your request must: (1) provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative; and (2) describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. When using an authorized representative, unless you have provided your authorized representative a Power of Attorney pursuant to the California Probate Code, you must: (1) provide the representative with signed permission clearly describing their authority to make a request on your behalf; (2) verify your own identity with FLC; and (3) directly confirm that you have provided the authorized agent permission to submit the request. That authorized representative also must be able to verify their identity with us and provide us with their authority to act on your behalf. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

You may need to provide additional information in order to verify your request. Depending on the nature of the request, we may require additional verification actions be taken, including but not limited to providing a signed declaration under penalty of perjury that you are the person whose personal information is the subject of the request. We will only use personal information provided in the request to verify the requestor’s identity or authority to make it.

Response Timing and Format

We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10‑day timeframe, please contact Dana O’Brien at compliance@fisherlynch.com. We endeavor to substantively respond to a verifiable request within forty‑five (45) days of its receipt. If we require more time (up to another forty-five (45) days), we will inform you of the reason and extension period in writing. We reserve the right to deny requests as allowed by applicable law, such as where we have a reasonable belief that the request is fraudulent, where your identity cannot be confirmed, or where we must retain your personal information consistent with applicable law.

Non‑Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not: deny you goods or services; charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties; provide you a different level or quality of goods or services; or suggest that you may receive a different price or rate for goods or services, or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA‑permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt‑in consent, which you may revoke at any time.

Changes to this California Supplement

The California Supplement may change from time to time and at our discretion. We encourage you to review this Supplement regularly to stay informed about our privacy practices.

Questions about this California Supplement

If you have any questions about this California Supplement or our privacy practices, please do not hesitate to contact Dana O’Brien at compliance@fisherlynch.com.

EEA and UK Supplement

Last Updated: September 1, 2026

This EEA and UK Supplement (“EU/UK Supplement”) provides information for individuals residing in the European Economic Area (“EEA”) and United Kingdom (“UK”) (“you”). This EU/UK Supplement should be read with our Privacy Notice to fully understand our collection, use and disclosure of your Information. If you reside in the EEA or UK, Fisher Lynch Capital, LLC will be the controller of the Information provided to, collected by or for, or processed by us in connection with our Services.

For purposes of this EU/UK Supplement, Information means “personal data” as such term is defined by applicable data protection laws in the EEA and UK. Any other terms used here and not otherwise defined in our Notice shall have the meanings given to them under applicable data protection laws in the EEA and/or UK, as applicable.

Legal Basis for Processing Your Information

Under applicable data protection laws in the UK and EEA, we can only use your Information if we have a relevant lawful basis. The most common lawful bases we rely upon are as follows:

• where you have given consent (“Consent”);
  • to comply with our legal obligations (“Legal Obligations”);
  • for the performance of a contract with you or to take steps at your request before entering into a contract (“Contract”); or
  • for our legitimate interests or those of a third party (“Legitimate Interests”).

A legitimate interest is when we or a third party have a business or commercial reason to use your Information, so long as this is not overridden by your own rights and interests.

We do not generally process information about a person’s racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, health or sexual life, or genetic or biometric data (also known as “Special Category Personal Data”) unless permitted by applicable law. Where we do process such information, it is generally because you have volunteered it.

The nature of your interaction with us will determine how we will process your Information. The table below sets out the Information (as noted in the Information We Collect and How We Collect It section of the Notice) that will be used for the relevant specific purposes (as noted in the Use of Your Information section of the Notice) alongside the applicable lawful basis:

Failure to provide us with the relevant Information, in cases where you are legally or contractually required to provide it, may result in our being unable to establish or continue our relationship with you or to provide Services to you.

We will only use your Information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

Certain third parties also act as data controllers for the Information that we share with them and any Information that partners may collect independent of our relationship with them. If you have any questions about the processing of your Information by a business partner, you should contact the partner directly.

We do not anticipate that we will make any decision with respect to your Information using fully automated means.

Processing & Transfer of Information Outside the EEA & UK

We are based in the United States. We make our Services available in a number of jurisdictions, thus Information that we collect, disclose or share can be stored and processed in various other jurisdictions around the world (“Other Jurisdictions”), for the purposes detailed in our Notice. Where required, in order to provide adequate protection for the transfer of your Information, we only transfer Information to countries that provide an adequate level of legal protection as judged by relevant authorities in the UK and/or European Commission, or, where required, we ensure we have in place applicable contractual arrangements with our subsidiaries, affiliates and other third parties in respect of such transfers that accord with applicable laws.

You can obtain more information about our policies and practices with respect to the use of service providers located in other jurisdictions by contacting us as described in the Contact Us section of our Notice.

Your Rights and How to Exercise Your Rights

If you reside within the EEA or the UK, you may have the right to (depending on the circumstances):

• Receive confirmation as to whether or not Information concerning you is being processed, and access your stored Information, together with supplementary information.
• Receive a copy of Information you directly volunteer to us in a structured, commonly used and machine-readable format.
• Request rectification of your Information that is in our control.
• Object to the processing of Information by us.
• Restrict processing of your Information by us.
• Have your Information erased.
• Lodge a complaint with a supervisory authority.

If you would like to exercise any of the rights mentioned in this section, please submit a request by contacting us at compliance@fisherlynch.com. We take our obligations seriously and we ask that any concerns are first brought to our attention, so that we can try to resolve them.

Changes to this EU/UK Supplement

The EU/UK Supplement may change from time to time and at our discretion. We encourage you to review this Supplement regularly to stay informed about our privacy practices.

Cookie Notice

Last Updated: September 1, 2026

As noted in the Cookies and Other Similar Technologies section of our Privacy Notice, when you visit our Site, we collect certain Information about you and your devices by automated means, using cookies and other similar technologies. Cookies are small data files that websites send to your computer or device to recognize your browser or to store information or settings in your browser. For example, we use cookies to help ensure that the Site functions properly, that user consent choices or cookie preferences are recorded, and that form submissions are protected against fraudulent or automated activity. Any capitalized terms we do not define in this Cookie Notice are defined in our Privacy Notice.

We may use the following categories of cookies:

• Strictly necessary cookies. These are cookies that are required for the operation of our Site. They include cookies that are necessary for the Site to function (e.g., site’s basic features, technical functions), cookies that enable you to log into secure areas of the Site, or cookies set in response to your request for services (e.g., setting your cookie preferences)..
• Performance cookies. These cookies allow us to measure and improve the performance of the Site. These include cookies that count the number of visitors of the Site, identify the traffic sources, and record your interactions with the Site (e.g., your navigation path on the Site, pages visited, content viewed, links clicked).
• Functional cookies. These cookies allow us to provide enhanced functionality, a personalized digital experience (e.g., remembering your preferences and settings) and certain support features. 
• Targeting cookies. These cookies allow us and our advertising partners to deliver tailored advertising. These cookies enable us and our partners to build profiles of your interests, show you tailored advertisements, and track the effectiveness of our advertising campaigns.

You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

Most browsers can be set to detect cookies and give you an opportunity to reject them, but refusing cookies may, in some cases, inhibit or preclude your use of our Site or certain features. Our Site does not currently respond to “Do Not Track” signals. To learn more about how to manage cookies on different browsers, you can visit the website, www.allaboutcookies.org  or https://ico.org.uk/for-the-public/online/cookies/.

To the extent a legal basis is required by applicable data protection laws, the legal basis for any processing of your Information in connection with the use of performance cookies, functional cookies or targeting cookies is your consent. You can revoke your consent (if given) at any time, by changing your cookie preferences on the cookie banner. You may access our cookie banner, by click “Cookie Preferences” at the footer of our Site. However, such revocation will have no effect on the lawfulness of the processing that took place before you revoked your consent.

The legal basis for any processing of your Information in connection with the use of strictly necessary cookies is that it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.