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Aristeia Capital, L.L.C. – California-Specific Privacy Policy

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The California Consumer Privacy Act (with any implementing regulations and as may be amended from time to time, “CCPA”) imposes certain obligations on Aristeia Capital, L.L.C. and its affiliates and managed investment funds (together, “we” or “us”) and grants certain rights to California residents (“California Resident,” “you” or “your”) with regard to “personal information.”  If you are a California Resident, please review this California-Specific Privacy Policy (“CA Privacy Policy”) for information about how and why we collect, use, and disclose your personal information, our Notice at Collection and your potential rights with regard to your personal information under the CCPA.  The rights described herein are subject to exemptions and other limitations under applicable law.

Terms used herein have the meaning ascribed to them in the CCPA. We are a “business.”  “Personal information” under the CCPA means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly with, a California resident or a household.  It does not include deidentified information, aggregate consumer information or publicly available information, as those terms are defined in the CCPA. 

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Notice at Collection and Use of Personal Information 
 

Personal Information We Collect

Depending on how you interact with us, we may collect the following categories of personal information from or about you: (i) identifiers and similar information, such as name, address, date of birth, email address, social security number, driver’s license number, passport number, online identifiers or other similar identifiers; (ii) additional information subject to Cal. Civ. Code § 1798.80(e), including your education, credit card number, state identification card number, signature, or bank account or other financial information; (iii) characteristics of protected classifications under federal or certain state laws, including gender, national origin, or marital status; (iv) commercial information, including records of products or services purchased, obtained, or considered, or other purchasing histories or tendencies, including funds invested, investments considered, or sources of wealth; (v) audio, electronic, visual, or similar information; (vi) internet or other electronic network activity information, including interactions with our Site or use of certain online tools; (vii) professional or employment-related information, including occupation, compensation, employer, and title; (viii) inferences drawn from any of the information identified above to create a profile reflecting your preferences or similar information, including your potential interest in investing in new funds; and (ix) sensitive personal information under the CCPA such as your Social Security number, passport number, driver’s license, citizenship and immigration status, and state identification card.

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In the preceding 12 months, we may have disclosed for a business purpose all of the above categories of personal information to all of the categories of third parties discussed below in “Sharing Personal Information with Third Parties.”

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Purposes for Collecting and Using Personal Information

We may collect and use your personal information for the following business or commercial purposes, including: (i) performing services on behalf of a fund, including maintaining or servicing accounts, providing investor relations services, processing subscriptions and withdrawals, verifying information, processing payments or providing similar services; (ii) communicating with you; (iii) performing our contractual obligations to a California Resident as a subscriber to a fund, including providing updates on a fund’s performance, providing tax reporting and other operational matters; (iv) detecting security incidents and protecting against malicious, deceptive, fraudulent, or illegal activity, including preventing fraud and conducting “Know Your Client,” anti-money laundering, terrorist financing, and conflict checks; (v) enabling or effecting commercial transactions, including using bank account details to remit funds and process distributions; (vi) administering and improving our website; and (vii) internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.

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How Long We Keep Information

How long we keep your personal information will vary depending on the type of personal information and our reasons for collecting it. The retention period will be determined by various criteria, including the purposes for which we are using it (as it will need to be kept for as long as is necessary for any of those purposes) and our legal obligations (as laws or regulations may set a minimum period for which we have to keep your personal information).  In general, we will retain your personal information for as long as we determine we require it to perform our contractual rights and obligations or for periods required by our legal and regulatory obligations. 

 

Sale or Sharing of Personal Information 

 

We do not sell or share your personal information (as such terms are defined under the CCPA). 

 

For more information about our privacy practices, please review our entire Privacy Policy which is also located on the first page of this Privacy Policy.

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Our Collection, Use and Disclosure of Personal Information and Sensitive Personal Information

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What Information We Have Collected and Our Purpose for Collecting It

In the preceding 12 months, and depending on how you interact with us, we may have collected the categories of personal information listed above in Personal Information We Collect. We may have collected all or a few of these categories of personal information for the business or commercial purposes identified in Purpose for Collecting and Using Personal Information. 

 

Sources of Personal Information

We may collect personal information about you directly from you and/or your intermediaries through sources such as: (i) account applications, subscription agreements, and other forms or related documentation; (ii) written, electronic, or verbal correspondence with us or our service providers; (iii) investor transactions; (iv) an investor’s brokerage or financial advisory firm, financial advisor, or consultant; or (v) from information captured on applicable websites.  In addition, we may collect personal information from different sources, such as: (i) our affiliates, our service providers, or our affiliates’ service providers; (ii) public websites or other publicly accessible directories and sources, including bankruptcy registers, tax authorities, governmental agencies and departments, and regulatory authorities; or (iii) credit reporting agencies, sanctions screening databases, or from sources designed to detect and prevent fraud.

 

Disclosure Personal Information with Third Parties

We do not sell or share your personal information (as those terms are defined under the CCPA).  We do not knowingly sell or share the personal information of California residents under 16 years old.   

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In the preceding 12 months, we may have disclosed for a business purpose the following categories of personal information to the following categories of third parties, as described in the following chart:

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In addition, in the preceding 12 months, we may have disclosed all of the categories of personal information identified in Personal Information We Collect section above, to the following categories of third parties: (i) judicial courts, regulators, or other government agents purporting to have jurisdiction over us, our subsidiaries or our affiliates, or opposing counsel and parties to litigation; and (ii) other third parties as may otherwise be permitted by law. We may disclose personal information to all of the third parties listed above to comply with our legal obligations or for the business or commercial purposes identified above in Purpose for Collecting and Using Personal Information. We may also transfer to another entity or its affiliates or service providers some or all information about you in connection with, or during negotiations of, any merger, acquisition, sale of assets or any line of business, change in ownership control, or financing transaction.  Additionally, we may disclose your personal information to third parties upon your request, at your direction or with your consent.

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We also may disclose or make available all of the categories of personal information identified in Personal Information We Collect above to our service providers such as our administrator, tax and accounting providers, CRM provider, other entities that have agreed to limitations on the use of your personal information, or entities that fit within other exemptions or exceptions in or as otherwise permitted by the CCPA.

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Use and Disclosure of Sensitive Personal Information

As noted above in Personal Information We Collect, under the CCPA, certain personal information we collect and process may be considered “sensitive personal information.” The CCPA requires that we provide you with a right to limit our use or disclosure of such sensitive personal information in certain circumstances. Currently we are not using your sensitive personal information for purposes that would require that we provide you with a right to limit.

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California Residents’ Rights under the CCPA

If your personal information is subject to the CCPA, you may have certain rights concerning that information, subject to applicable exemptions and limitations, including the right to: (i) be informed, at or before the point of collection, of the categories of personal information to be collected and the purposes for which the categories of personal information shall be used; (ii) not be discriminated against because you exercise any of your rights under the CCPA; (iii) request that we delete any personal information about you that we collected, subject to certain exceptions (“Request to Delete”); (iv) opt-out of the “sale” (as that term is defined in the CCPA) of your personal information if a business sells your personal information (we do not); (v) opt-out of the “sharing”  (as that term is defined in the CCPA) of your personal information if a business shares your personal information with third parties (we do not); (vi) limit the use and disclosure of sensitive personal information where required by the CCPA (“Right to Limit”) (please note that we are not using your sensitive personal information for purposes that would require that we provide you with a Right to Limit); (vii) correct inaccurate personal information (“Request to Correct”);  and (viii) request that we, as a business that collects personal information about you and that discloses your personal information for a business purpose, disclose to you (“Request to Know”): (a) the categories of personal information we have collected about you; (b) the categories of sources from which we have collected the personal information; (c) the business or commercial purpose for collecting the personal information; (d) the categories of third parties to which we disclosed personal information about you for a business purpose; and (e) the specific pieces of personal information we have collected about you.

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The CCPA does not restrict our ability to do certain things like comply with other laws or comply with regulatory investigations.  In addition, the CCPA does not apply to certain information, like personal information collected, processed, sold or disclosed pursuant to the federal Gramm-Leach-Bliley Act and its implementing regulations.  We also reserve the right to retain, and not to delete, certain personal information after receipt of a Request to Delete from you where permitted by the CCPA or another law or regulation.

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How to Submit a Request under the CCPA

You may submit a Request to Know, Request to Delete, or Request to Correct (“Consumer Rights Request”), as described above through the following telephone number: (212) 842-8900, by sending an email to the following email address: investors@aristeiacapital.com, or through our website via our Contact Us page. You may also submit Consumer Rights Requests via mail to:

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Aristeia Capital, L.L.C.

One Greenwich Plaza

Greenwich, CT 06830

Attn: Chief Compliance Officer

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We are only required to respond to verifiable Consumer Rights Requests made by you or your authorized agent. When you submit a Consumer Rights Request, we may ask that you provide clarifying or identifying information to verify your request. Such information may include, depending on the information you are requesting and the type of request you are making, account login credentials or other account information, answers to security questions, name, government identification number, date of birth, contact information, or other personal information. Any information gathered as part of the verification process will be used for verification purposes only.

You are permitted to designate an authorized agent to submit a Consumer Rights Requests on your behalf and have that authorized agent submit the request through the aforementioned methods. We may deny requests from authorized agents who do not submit proof that they have been authorized by you to act on your behalf. We may also require that you directly verify your own identity with us and directly confirm with us that you provided the authorized agent permission to submit the request.

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Contact for More Information

This CA Privacy Policy is available in alternative formats upon request. If you have any questions or concerns about this CA Privacy Policy, or to request this Privacy Policy in an alternative format, please email investors@aristeiacapital.com

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We may update this CA Privacy Policy from time to time and to reflect changes in our personal information practices.  We encourage you to review the most current Privacy Policy provided to you. This CA Privacy Policy was last updated on January 7, 2026.  A copy of Aristeia’s general privacy policy can be found on our Site. 

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