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Privacy Policy

Your privacy is very important to us. We believe it is vital that you understand what information we collect about you and what we do with that information. To that end, Westrock Asset Management, LLC and its affiliates (collectively, "WAM," "we" or “us”) have adopted this Privacy Policy. Your visit to the westrockam.com website is subject to this Privacy Policy and our Terms of Use. By visiting our website, you agree that we may collect, disclose and use information about you except as expressly provided below. You should review this policy carefully, because if you do not agree with our practices, you should not visit our website.

WAM’s Privacy Policy

Information We Collect About You

When you invest with us or visit and browse our website or otherwise interact with us (as a trade counterparty or contractor, for instance), we may collect two different types of information about you: (1) information you provide to us; and (2) information we collect through visits to our website.

Information You Provide To Us

We may collect information from you from a variety of different sources, including correspondence and discussions with you, information we receive from you on applications or other forms or documents you provide to us, and information about your transactions with us, our affiliates or others. This information may include names, addresses, e-mail addresses, social security numbers, tax identification numbers and financial and other information we feel is necessary or useful in evaluating your ability to invest in our funds, in processing and managing your investment, or otherwise in furtherance of our business.

In addition, to access password protected areas of our website you will be required to provide your user name and password, which permits us to identify you and associate you with the personal information you have provided to us in the past.

We refer to all of this information collectively as your personally identifiable information.

Information We Collect Through Visits To Our Website - Use of Cookies

Visitors to our website may be assigned a “cookie.” Cookies are small text files sent to your computer browser from our web server and stored on your computer’s hard drive. We use cookies for a variety of purposes, including helping us gather information and provide services to you. For instance, when you return to our website after logging in, cookies provide information to our website so it will remember you and your technology preferences while visiting our website. Cookies also help us diagnose problems with our web server.

You may always choose to reject our cookies by adjusting the settings of your browser, though choosing to do so may inhibit your ability to use some of the features of our website. Each browser is different, so check your browser's "Help" menu to learn how to change your

 

cookie preferences.

We also collect certain technical information from your computer each time you visit our website. This information may include (among other things) the Internet protocol (IP) address used to connect your computer to the Internet, the type of computer and browser you are using, and the websites you access immediately before and after you visit our website.

We may use the information we collect through technological means to measure site activity, to develop ideas for improving our website, and for any other purpose. We may freely share this information with third parties so long as it does not contain any of your personally identifiable information. By continuing to visit and use our website, you are agreeing to our use of cookies.

How We Use Your Personally Identifiable Information

We may use your personally identifiable information to provide services to you, to open an account for you, to process transactions for our funds or your account or otherwise in furtherance of our business. In order to service your account, we may provide your personally identifiable information to our affiliates and to third parties that assist us in servicing your account and have a need for such information. We may also disclose personally identifiable information about you (1) to any third party to the extent you authorize us to do so, (2) to our attorneys, accountants and auditors to the extent permitted by law for purposes of preventing fraud, responding to judicial process or a subpoena, or complying with federal, state or local laws, and (3) to U.S. or foreign governmental authorities either directly or through counterparties or other intermediaries that are regulated by such authorities) to the extent we deem necessary or advisable. Except for these limited circumstances, we do not disclose your personally identifiable information.

We may store your personally identifiable information and use it for our own research and other business purposes, and we may associate your personally identifiable information with other information we collect about you.

Security

We endeavor to protect your personally identifiable information. Except as described above, we restrict access to personally identifiable information about you to our employees and our agents who need to know that information to enable us to provide services to you. We maintain physical, electronic and procedural safeguards to protect your personally identifiable information. However, we will not be responsible or liable for any losses or disclosures of your personal information, other than disclosures that we knowingly make in violation of this Privacy Policy.

Website Links

Our website may contain links to or from other websites. Please be aware that we are not responsible for the privacy practices of other websites and you visit those websites at your own risk. This Privacy Policy applies only to the information we collect on our website. We encourage you to read the privacy policies of other websites you visit.

Changes to this Privacy Policy

We may revise this Privacy Policy from time to time. Any such changes will be effective immediately, so we suggest that you review this policy periodically to insure you have the most recent version. The current version of our Privacy Policy may be accessed from the link on our website or by contacting our Investor Relations department at 501-320-4867.

Comments

If you have any questions, comments or concerns about our privacy practices, or if you wish to request access to, correct or delete any personally identifiable information that you have provided to us, please contact us at:

Westrock Asset Management, LLC


4009 N. Rodney Parham Rd.

 

Little Rock, AR 72212


United States


Attn: Investor Relations


Telephone: +1 501-320-4867

Last Updated 7/1/2023

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