Privacy Policy

 

EIG Management Company: Privacy Notice

February 2026

What You Should Know As used herein, the term “EIG”, “we” or “our” shall mean EIG Management Company, LLC or its affiliates, including certain affiliates that act as manager, investment adviser or general partner for pooled investment vehicles, separately managed accounts (collectively, the “Investment Funds”). EIG recognizes the importance of keeping information about you secure and confidential.

EIG provides this privacy notice (the “Privacy Notice”) to current and prospective investors of Investment Funds that are natural persons (including “alter egos” and natural persons related to current and prospective investors that are not natural persons) (referred to herein as “Subscribers”, “investors”, “your”, “you”) in order to help you better understand why and how we collect certain personal information, the care with which we treat such information, and how we use such information.

EIG takes precautions to maintain the privacy of personal information concerning, or in connection with Subscribers, including the adoption of certain procedures designed to maintain and secure a Subscriber’s personal information from inappropriate disclosure to third parties. EIG does not sell or share your personal and financial information with marketers or others outside its affiliated group of companies other than as described herein.

Information We Collect: In connection with forming, operating, and performing asset management services for our Investment Funds and/or performing asset management services for our Subscribers, we collect and maintain the following categories of personal information about our individual Subscribers:

• names, dates of birth and birth place;
• contact details and professional addresses (including physical address, email address and telephone number);
• account data and other information contained in any document provided by Subscribers (whether directly or indirectly);
• information regarding the use of any our website, fund data room and investor reporting portal (as applicable) (e.g., cookies, browsing history and/or search history);
• risk tolerance, transaction history, investment experience and investment activity;
• information regarding a Subscriber’s status under various laws and regulations, including their social security number, tax status, income and assets;
• accounts and transactions with other institutions;
• information regarding a Subscriber’s interest in our Investment Funds, including ownership percentage, capital investment, income and losses;
• information regarding a Subscriber’s citizenship and location of residence;
• source of funds used to make the investment in our Investment Funds; and
• anti-money laundering, identification (including passport and drivers’ license), verification documentation, and identification numbers such as social security numbers.

Sources of Personal Information: EIG collects and maintains personal information about its Subscribers from the following sources:

i. information received in telephone conversations or in voicemails;

ii. information received through written correspondence, via e-mail, or on subscription agreements (or other related documents), investor questionnaires, applications or other forms (including, without limitation, any anti-money laundering, identification, and verification documentation);

iii. information about transactions with EIG or others;

iv. information captured on EIG’s website, fund data room and/ or investor reporting portal (as applicable), including registration information, information provided through forms and any information captured via “cookies”; and

v. information from available public sources, including from: o publicly available and accessible directories and sources;

o bankruptcy registers;

o tax authorities, including those that are based in another jurisdiction;

o governmental and competent regulatory authorities to whom EIG has regulatory obligations;

o credit agencies; and

o fraud prevention and detection agencies and organizations.

EIG may, in certain circumstances, combine personal information it receives from an investor with information that it collects from, or about such investor. This will include information collected in an online or offline context.

You may refuse, at your discretion, to communicate your personal information to EIG. In this event however, EIG or its agent may reject your request for subscription for interests in an Investment Fund if the relevant personal information is necessary to the subscription of interests.

Purposes for Collecting Personal Information: EIG may process, use, and/or disclose personal information we collect about you for one or more of the following business or commercial purposes:

i. The performance of obligations under the governing documents of the Investment Funds (and all applicable anti-money laundering, “know-your-client” and other related laws and regulations) in assessing suitability of potential Subscribers in the applicable Investment Funds;

ii. The administrative processes (and related communication) in preparing for the admission of Subscribers to the Investment Funds, including administering, managing and setting up a Subscriber’s account(s) to allow such potential Subscriber to purchase interests in the Investment Funds;

iii. Ongoing communication with existing and potential Subscribers and their respective representatives, advisors and agents, (including the negotiation, preparation and signature of documentation), including during the process of admitting potential Subscribers to the Investment Funds and the execution of all relevant agreements;

iv. The ongoing administrative, accounting, reporting, account maintenance and other processes and communication required to operate the business of an Investment Fund in accordance with the Partnership Agreement and other applicable documentation between the parties, including customer service, processing or fulfilling transactions, verifying personal information, processing contributions and distributions and financing;

v. Complying with laws, rules and regulations;

vi. Keeping existing and potential investors informed about the business of EIG and its affiliates generally, including offering opportunities to make investments other than in the applicable Investment Fund;

vii. facilitating the execution, continuation or termination of the contractual relationship between a Subscriber, EIG, the general partner or managing member for the relevant Investment Fund;

viii. facilitating the transfer of Investment Fund interests, and administering and facilitating any other transaction, between a Subscriber, EIG, the general partner or managing member for the relevant Investment Fund;

ix. auditing and performing verifications related to Subscriber interactions, including but not limited to, verifying the quality and effectiveness of services and compliance;

x. maintaining the safety, security and integrity of our products and services, databases, technology assets and business, including detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity;

xi. enabling any actual or proposed assignee or transferee of the Investment Fund(s) to evaluate proposed transactions;

xii. facilitating business asset transactions involving the Investment Funds; and

xiii. any other purpose that has been notified, or has been agreed, in writing.

EIG monitors communications where the law requires it to do so. EIG also monitors communications, where required to do so, to comply with regulatory rules and practices and, where permitted to do so, to protect its business and the security of its systems.

Disclosure of Information: EIG does not disclose any of the categories of personal information set out in the “Information We Collect” section above to anyone, except: (i) as permitted or required by law and regulation; (ii) to affiliates; and (iii) to our service providers and other third parties in accordance with the agreement governing your investment in our Investment Funds, including:

• financial service providers, such as broker-dealers, custodians, banks lenders and others used to finance or facilitate transactions by, or operations of, our Investment Funds;

• actual and potential portfolio companies, purchasers thereof and potential co-investors, and each of their respective advisors if requested in connection with an investment or disposition;

• other service providers to EIG and our Investment Funds and/or their general partners, managers and affiliates, such as those who provide accounting, legal, consulting, administration, auditing or tax preparation services and placement agents;

• other partners and potential investors in our Investment Funds; and

• transfer agents, portfolio companies, brokerage firms and the like, in connection with distributions to our partners.

Former Subscribers: We maintain personal information of our former Subscribers and apply the same policies that apply to current Subscribers.

Information Security: We consider the protection of personal information to be a sound business practice. EIG restricts access to personal information about its Subscribers to those employees and agents of EIG who need to know that information in order to provide services to its investors. To the extent any personal information of a Subscriber is disclosed for necessary business purposes to a third party, EIG will require such parties to protect the confidentiality of the investors’ personal information and to use the information only for purposes for which it is disclosed to them. EIG maintains physical, electronic, and procedural safeguards that comply with applicable federal standards to safeguard the Subscriber’s personal information and which EIG believes are adequate to prevent unauthorized disclosure of such information.

Further Information: We reserve the right to change our privacy policies and this Privacy Notice at any time and will keep Subscribers informed of changes. If we update this Privacy Notice, we will make an updated draft available to you via our investment portal or notify Subscribers through other routine communications. The examples contained within this notice are illustrations only and are not intended to be exhaustive. This Privacy Notice is intended to comply with the privacy provisions of Regulation S-P of the Gramm-Leach-Bliley Act and certain privacy provisions of other laws.

Further Privacy Notice Supplements: A Subscriber may have additional rights under other laws that apply to you, including as set forth in the California Privacy Notice, the EEA-UK Privacy Notice, and in the section below titled “Supplement for Australian Investors”.

Supplement for Australian Investors: EIG is providing this Supplemental Notice to you to comply with the requirements of The Privacy Act 1988 (“Privacy Act”) which is an Australian law which regulates the handling of personal information about individuals.

EIG may from time to time transfer personal information outside Australia in accordance with the Privacy Act to countries whose privacy laws do not provide the same level of protection as Australia’s privacy laws. For example, EIG may transfer your personal information to the Asia-Pacific, European Union or the United States of America. EIG may also use cloud storage and IT servers that are located offshore.

If you contact us to access your Personal Data, to seek to correct it, or to make a complaint about privacy, we will respond as soon as we reasonably can, and in any event within any timescales stipulated by applicable law. We do not impose any charge for a request, but we may charge you a reasonable fee for our costs associated with providing you access and retrieval costs. For complaints about privacy, we will establish in consultation with you a reasonable process including time frames, for seeking to resolve your complaint

Contact us, complaints and exercising your rights:

If you have any questions concerning this Privacy Notice, or wish to exercise any of your rights, submit requests, or appeal any of our decisions in connection with this Privacy Notice, or to view this Privacy Notice in an alternative format (each, a “Communication”), please contact our Privacy Officer on the contact details below.

You can contact EIG by calling on +1 202.600.3300, emailing at compliance@eigpartners.com or by writing to:

The Privacy Officer

C/O Chief Compliance Officer

EIG

600 New Hampshire Ave. NW

Suite 1200

Washington, DC 20037

We verify Communications by matching information provided in or in connection with your Communication to information contained in our records. Depending on the sensitivity of the Communication and the varying levels of risk in responding to such Communications (for example, the risk of responding to fraudulent or malicious Communications), we may request further information or your investor portal access credentials, if applicable, in order to verify your Communication.

CALIFORNIA PRIVACY NOTICE

This notice (the “California Privacy Notice”) supplements the Privacy Notice set forth above with respect to specific rights granted under the California Consumer Privacy Act of 2018 (as amended by the California Privacy Rights Act of 2020 and the California Consumer Privacy Act Regulations issued thereto (together, the “CCPA”) to natural person California residents and provides information regarding how such California residents can exercise their rights under the CCPA. This California Privacy Notice is only relevant to you if you are a resident of California as determined in accordance with the CCPA. Information required to be disclosed to California residents under the CCPA regarding the collection of their personal information that is not set forth in this CCPA supplement is otherwise set forth above in the Privacy Notice. To the extent there is any conflict with the privacy requirements under the Gramm-Leach-Bliley Act and/or Regulation S-P (“GLB Rights”), GLB Rights shall apply.

Categories of Personal Information We Collect: We collect, or have collected within the last 12 months some or all of the following categories of personal information from individuals:

Category	Examples	Collected
A. Identifiers	Name, contact details and address (including physical address, email address, and Internet Protocol address), and other identification (including social security number, passport number and driver’s license or state identification card number).	YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))	Telephone number, signature, bank account number, other financial information (including accounts and transactions with other institutions and anti-money laundering information), and verification documentation and information regarding investors’ status under various laws and regulations (including social security number, tax status, income, and assets).	YES
C. Protected classification characteristics under California or federal law	Date of birth, citizenship, and birthplace.	YES
D. Commercial information	Account data and other information contained in any document provided by investors to authorized service providers (whether directly or indirectly), risk tolerance, transaction history, investment experience and investment activity, information regarding a potential and/or actual investment in the applicable fund(s), including ownership percentage, capital investment, income and losses, source of funds used to make the investment in the applicable fund(s).	YES

E. Biometric information	Imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns and voice recordings or keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contains identifying information.	YES, as to voicemail recordings.
F. Internet or other similar network activity	Use of our website, fund data room, and investor reporting portal (e.g., cookies, browsing history and/or search history), as well as information you provide to us when you correspond with us in relation to inquiries.	YES
G. Geolocation data	Physical location or movements.	NO
H. Sensory data	Audio, electronic, visual, thermal, olfactory, or similar information.	YES, as to voicemail recordings.
I. Professional or employment-related information	Current or past job history or performance evaluations.	NO
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	NO
K. Inferences drawn from other personal information	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	NO
L. Sensitive personal information (see	Social security, driver’s license, state identification card, or passport numbers; account log-in, financial account, debit card, or credit card number in combination with any required	YES, as to the following types of information: social

further information on use of sensitive personal information below)

security or access code, password, or credentials allowing access to an account; precise geolocation; racial or ethnic origin; religious or philosophical beliefs; union membership; genetic data; the contents of a consumer’s mail, email, and text messages unless you are the intended recipient of the communication; biometric information for the purpose of uniquely identifying a consumer; and personal information collected and analyzed concerning a consumer’s health, sex life, or sexual orientation.

security, driver’s license, state identification care, or passport numbers, account log-in, financial account in combination with any required security or access code password, or credentials allowing access to

We do not collect or use sensitive personal information other than:

• To perform services, or provide goods, as would reasonably be expected by an average consumer who requests those goods or services;

• As reasonably necessary and proportionate to detect security incidents that compromise the availability, authenticity, integrity, and confidentiality of stored or transmitted personal information;

• As reasonably necessary and proportionate to resist malicious, deceptive, fraudulent, or illegal actions directed at us and to prosecute those responsible for such actions;

• For short-term, transient use (but not in a manner that discloses such information to another third party or is used to build a profile of you or otherwise alter your experience outside of your current interaction with us);

• To perform services on behalf of our business;

• To verify or maintain the quality or safety of a service or to improve, upgrade, or enhance such service or device; and

• To collect or process sensitive personal information where such collection or processing is not for the purpose of inferring characteristics about a consumer.

Purposes for Collecting Personal Information: We collect or disclose personal information for any of the business or commercial purposes and from the sources set forth in “Purposes for Collecting Personal Information” and “Sources of Personal Information” in the Privacy Notice above. We retain the categories of personal information set forth above in the “Categories of Personal Information We Collect” section of this California Privacy Notice only as long as is reasonably necessary for those business or commercial purposes set forth above in “Purposes for Collecting Personal Information,” except as may be required under applicable law, court order or government regulations.

Disclosure of Information: We do not share for the purpose of cross-context behavioral advertising or sell (as such terms are defined in the CCPA) any of the personal information we collect about you to third parties.

We disclose or have disclosed within the last 12 months, personal information collected from you for a business or commercial purpose to the categories of third parties indicated in the chart below. We may also disclose your information to other parties as may be required by law or regulation, or in response to regulatory inquiries.

Category	Category of Third-Party Recipients
A. Identifiers	Administrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, vendors of IT, software and similar services, consultants, and placement agents.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80I)	Administrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, vendors of IT, software and similar services, consultants, and placement agents.
C. Protected classification characteristics under California or federal law	Administrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, vendors of IT, software and similar services, consultants, and placement agents.
D. Commercial information	Administrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, vendors of IT, software and similar services, consultants, and placement agents.
E. Biometric information	Administrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, vendors of IT, software and similar services, consultants, and placement agents.
F. Internet or other similar network activity	Administrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, vendors of IT, software and similar services, consultants, and placement agents.
G. Geolocation data	N/A
H. Sensory data	Administrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, vendors of IT, software and similar services, consultants, and placement agents.
I. Professional or employment-related information	N/A
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))	N/A
K. Inferences drawn from other personal information	N/A
L. Sensitive Personal Information	Administrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, vendors of IT, software and similar services, consultants, and placement agents.

Rights Under the CCPA

Deletion Rights: You have the right to request that we delete any of your personal information that we retain, subject to certain exceptions, including, but not limited to, our compliance with U.S., state, local and non-U.S. laws, rules and regulations. We will notify you in writing if we cannot comply with a specific request and provide an explanation of the reasons.

Disclosure and Access Rights: You have the right to request that we disclose to you certain information regarding our collection, use, disclosure and sale of personal information specific to you. Such information includes:

• The categories of personal information we collected about you;

• The categories of sources from which the personal information is collected;

• Our business or commercial purpose for collecting such personal information;

• Categories of third parties to whom we disclose the personal information;

• The specific pieces of personal information we have collected about you; and

• Whether we disclosed your personal information to a third party, and if so, the categories of personal information that each recipient obtained.

Correction Right: You have the right to request that we correct any inaccuracies in the personal information that we retain, subject to certain statutory exceptions, including, but not limited to, our compliance with U.S., state, local and non-U.S. laws, rules and regulations. We will notify you in writing if we cannot comply with a specific request and provide an explanation of the reasons.

No Discrimination: We will not discriminate against you for exercising your rights under the CCPA, including by denying service, suggesting that you will receive, or charging, different rates for services.

Privacy Notice in an alternative format, please submit a request on your behalf using any of the methods set forth below.

If you would like to contact us by telephone without incurring telephone charges, please submit your request and telephone number by email at compliance@eigpartners.com and we will return your call.

Email us at the following email address: compliance@eigpartners.com.

We will contact you to confirm receipt of your request under the CCPA and request any additional information necessary to verify your request. We verify requests by matching information provided in connection with your request to information contained in our records. Depending on the sensitivity of the request and the varying levels of risk in responding to such requests (for example, the risk of responding to fraudulent or malicious requests), we may request further information or your investor portal access credentials, if applicable, in order to verify your request. You may designate an authorized agent to make a request under the CCPA on your behalf, provided that you provide a signed agreement verifying such authorized agent’s authority to make requests on your behalf, and we may verify such authorized person’s identity using the procedures above. If we request that you verify your request and we do not receive your response, we will pause processing of your request until such verification is received.

Please contact the Chief Compliance Officer of EIG Management Company, LLC, at compliance@eigpartners.com with any questions or concerns about this California Privacy Notice.