Stone Ridge Asset Management LLC (“Stone Ridge,” “we,” “us” or “our”) values your privacy. This Privacy Notice describes how we may collect, use, share and otherwise process any personal information relating to a resident of California that we collect, as described below.

This Privacy Notice applies to all California residents who are not covered by our general Privacy Notice. Additionally, this Privacy Notice does not apply to employees, applicants for employment, contractors or business contacts.

I. Personal information we collect

“Personal information” is any kind of information that allows us to identify you, directly or indirectly, such as your name, contact details or address. We may collect and process the following personal information about you:

- Identifiers, such as your name, address, email address and telephone numbers;

- Protected classification information, such as personal information or information protected by state, federal or other applicable law, including your nationality, place and date of birth, race, color, national origin, age, sex, gender, marital status, number of children, citizenship status, information on criminal history/unlawful conduct and correspondence records;

- Commercial information, such as tax information, credit history, bank account details, money transfers including communications on bank transfers, source of funds details, investor profile and details related to your investment activity, including financial products or investment services purchased, obtained, or considered, and other investing or consuming histories or tendencies;

- Personal information categories listed in the California Customer Records statute (Cal. Civ. Code §1798.80(e)), including financial information;

- Internet or other electronic network activity information, such as your internet protocol (IP) address, login data, unique device identifiers, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, mobile device carrier and other technology on the devices you use to access this website; as well as usage information, such as information about how you use the website and our products and services, referring/exit web pages, date/time stamps, error logs, and the frequency of your use of the website;

- Inferences drawn from other personal information; and

- Marketing and communications information, such as your preferences in receiving marketing communications from us.

Some of the personal information we collect may be deemed sensitive under data protection laws, including identifiers such as Social Security number. We will use such information only for lawful purposes in compliance with data protection laws, and will not use sensitive personal information provided to infer characteristics about you other than as required to comply with law or legal process such as for AML/KYC purposes.

We may also collect, use and share aggregated information such as statistical or demographic data for any purpose. This information could be derived from your personal information but will not directly or indirectly reveal your identity. For example, we may aggregate your usage information to calculate the percentage of users accessing a specific feature on this website. However, if we combine or connect information with your personal information so that it can directly or indirectly identify you, we treat the combined information as personal information which will be used in accordance with this Privacy Notice.

II. How we collect your personal information

We collect personal information from you via the following:

1. Personal information you provide to us

- Forms you complete(or that are completed by your authorized representatives on your behalf); and

- Your correspondence and interactions with us, including by letter, email and telephone.

2. Personal information collected from third parties

We may collect personal information about you from third parties, such as business partners, vendors or from publicly available information. The conditions under which we may obtain such information are governed by the third-party source.

3. Information collected automatically

We may automatically collect certain information about the devices you use to access this website, as well as information on how you interact with this website, through cookies, web server logs, and other similar tracking technologies.

a) Cookies and other data collection technologies

We may automatically collect certain information about the devices you use to access this website, as well as information on how you interact with this website, through cookies, web server logs, and other similar tracking technologies.

“Cookies” are a feature of web browser software that allows web servers to recognize the computer used to access a website. They are small text files that are stored by a user’s web browser on the user’s hard drive. Cookies can remember what information a user accesses on one website to simplify subsequent interactions with that site by the same user or to use the information to streamline the user’s transactions on related websites. A number of cookies we use last only for the duration of your web session and expire when you close your browser. Other cookies last longer and are used to recognize your computer when you return to the website. Cookies are designed to make your online experience easier and more personalized. They can only be read by the server that placed them, and are unable to execute any code or virus. Web server logs are files that store the activity on a certain website.

Information gathered through cookies and web server logs may include information such as the date and time of visits to the website, the pages viewed, time spent at the website and the websites visited just before and just after the website. We use cookies and web server logs to manage your login session, help you move between websites in a smooth and secure manner and to gather information about the browsing activities of users of the website in order to continually improve it and better serve the needs of its users. We do not link cookies to personally identifiable information.

You can change your browser settings to notify you of the cookies being set or updated and to block cookies. Please note that if you have turned off all cookies, some features of the website may not be available to you or otherwise function as intended.

We also may include tracking pixels and web beacons in email messages, newsletters and other electronic communication. They help us to determine whether a message has been opened and to analyze and personalize our interactions with you. Instructions on how to unsubscribe are included in each email.

b) Cookie management

We use the following categories of cookies on the Site. Most web browsers automatically accept cookies. You can, however, change your browser to prevent this or to notify you each time a cookie is set. To learn more about how to manage cookies on different types of browsers, you can visit the website www.allaboutcookies.org.

- Essential cookies: These cookies are necessary for the function of the website and cannot be switched off by us. They do not store any personally identifiable information. While you can set your browser to block or alert you about these cookies, some parts of the website will not work if you do so.

- Performance, functionality and customization cookies: These cookies improve the performance and functionality of the website, but are not essential to its use. Without these cookies, the website and its functions might be more cumbersome to load or navigate, but are still available. The information these cookies collect is aggregated and thus anonymous. This information is solely used for internal purposes in managing the website and improving its functionality. If you do not allow these cookies, we will not be able to monitor the performance of the website, and some of its services may not function properly.

- Analytics cookies: These cookies collect anonymous information that helps us understand how you use our services and to customize the website and our services for you. The functionality of the website is not impacted by the rejection of such cookies.We may use third-party analytics providers such as Hubspot and Google Analytics to collect and analyze usage of the website. You can prevent Google Analytics from using your information by downloading and installing the Google Analytics Opt-out Browser Add-on (https://tools.google.com/dlpage/gaoptout). We also utilize Microsoft Clarity to capture how you use and interact with our website in order to improve and market our products/services. For more information about how Microsoft collects and uses your data, visit the Microsoft’s Privacy Statement.

- Targeting cookies: These cookies record your visit to the website, the pages you have visited and the links you have followed. They recognize you as a previous visitor and track your activity on the website as well as other websites you visit. The functionality of the website is not impacted by the rejection of such cookies. These cookies may be set by our advertising partners and used to build a profile of your interests and show you relevant advertisements on other sites. Targeting cookies do not directly store personal information, but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising.  

c) “Do Not Track” Browser Settings

We currently respect Global Privacy Control privacy settings from your web browser.

III. How we use your personal information

We will only use your personal information when the law allows us to. Any of the information we collect from you may be used in one of the following ways:

- Where the processing is necessary for us to perform services we have been contracted to perform or to take steps prior to entering into a contract – for example, to provide information you have requested or to respond to your questions;

- Where necessary for the purposes of the Company’s legitimate business interests, including to operate and facilitate our business and services, communicate with you, undertake business management, planning, statistical analysis, market research and marketing activities, administer and maintain theCompany’s core records, protect the Company’s rights and interests, ensure the security of the Company’s assets, systems and networks, prevent, detect and investigate fraud, unlawful or criminal activities in relation to our services and enforce our terms and conditions;

- Where required by applicable laws and regulations, including laws relating to know-your-client requirements, tax, the prevention of money laundering, fraud, terrorist financing and sanctions; and

- Where the processing is necessary for the establishment, exercise or defense of legal claims.

IV. When we disclose your personal information

We do not disclose personal information except as may be required or permitted by law, rule or regulation. We do not disclose any personal information to anyone other than our affiliates, service providers and relevant counterparties without your consent, or as required by applicable law or regulation. This means that we may disclose your personal information described above to other third parties for a business purpose, including:

- To service providers (including financial, technical, marketing and professional service providers and consultants) and financial institutions that provide services to the Stone Ridge, who are required protect the confidentiality of your personal information and to use the information only for the purposes for which it is disclosed to them).

- To regulatory, self-regulatory, administrative or law enforcement agencies or other oversight bodies in certain circumstances where we are required to share personal information and other information with respect to your interest in an investment with the relevant regulatory authorities. They, in turn, may exchange this information with other authorities, including tax authorities.

- As authorized, for example, by subscription agreements or organizational documents of an investment and as authorized by you or your designated representatives or other authorized persons.

- In connection with a corporate transaction — for example, to third parties as part of a corporate business transaction, such as a merger, acquisition, joint venture or financing or sale of company assets.

- We also may disclose personal information (1) when disclosure is necessary or appropriate to prevent harm or financial loss or in connection with an investigation of suspected or actual illegal activity, (2) to protect our operations, and (3) to establish and protect the rights, privacy, safety or property of Stone Ridge, our affiliates, you, and others.

We do not sell personal information obtained about you to any third parties, and have not done so in the twelve (12) months preceding the effective date of this policy. However, some of the ways in which we share your personal information with third parties on certain of our websites may, under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively, the"CCPA"), be considered to be a 'sale' of personal information or 'sharing' of personal information for 'cross-context behavioral advertising'. As described above, we engage third-party marketing and advertising vendors to personalize your browsing experience on our websites, to provide certain targeted advertising services for us, and to help us measure the effectiveness of our websites and our online advertising. This sharing of your information with certain third parties via cookies and similar methods, and our providers' use of certain cookies, may be considered to be a 'sale' of personal information or 'sharing' of personal information for 'cross-context behavioral advertising' under theCCPA. California residents covered by the CCPA have the right to opt out of this "sale" or "sharing" of personal information. For those websites where we engage in these activities and are covered by the CCPA, if we determine that you are visiting the website from a location in California, you will see a "Do Not Sell or Share my Personal Information" link on the footer of the website's homepage. To opt out of this sale or sharing of your personal information, please click on the link and follow the prompts.

V. Third-party links

The website may contain links to third-party websites, products and services. These third-party websites and services may have separate and independent privacy policies, which we encourage you to read. We have no responsibility or liability for the content and activities of such linked sites.

VI. Children’s Privacy

The website is not directed toward children under the age of 18. We do not promote our products or services online to minors, and we do not intentionally collect any personally identifiable information from any person under 18.

VII. Security

We have implemented measures to help protect personal information from loss, misuse or unauthorized access or disclosure. While we strive to protect personal information, we cannot guarantee its security.

VIII. Retention

Stone Ridge may retain your personal information for such a period as permitted or required by any applicable laws or regulations and for such a period as may be permitted in accordance with the lawful purposes or legitimate interests outlined above.

IX. Privacy rights

We are committed to providing individuals with reasonable and appropriate access to their personal information. If you believe that we are processing personal information about you and wish to have access to that information, we can provide you with that data or at least an explanation of why we cannot do so in the particular context.

In the preceding 12 months, we have collected and used personal information in the manner described above in the sections “PersonalInformation we Collect; How we collect your personal information; and How we use your Personal information.” We may have disclosed to third parties for our business purposes all of the categories of personal information as described above in that section. We will not discriminate against you for exercising data subject access rights.

The CCPA entitles California residents who are natural persons (other than investors) to certain rights which, subject to certain limitations and restrictions, may include the right to: (i) request additional disclosures about the personal information we collect, use, and disclose, i.e.,a “Request to Know (Categories of Information);” (ii) obtain a copy of personal information in a portable format, i.e., a “Request to Know (Specific Pieces ofInformation),” sometimes called the Right to Access or Right to DataPortability; (iii) request erasure of personal information, i.e., a “Request toDelete Information,” sometimes called the Right to Be Forgotten; (iv) request the correction/rectification of personal information; (v) restrict or object to the processing of personal information; and (vi) opt out of the sale of personal information, sharing of personal information for purposes of cross-context behavioral advertising, targeted advertising, and profiling in furtherance of decisions that produce legal or similarly significant effects, i.e., a “Request to Opt Out.”

Additionally, under California Civil law,Californians are entitled to request information relating to whether a business has disclosed personal information to any third parties for the third parties’ direct marketing purposes. If you need to reach us about a privacy or data protection matter, please contact us using the details below. These rights are not absolute and we reserve all ofour rights available to us at law in this regard. Additionally, if we retain your personal information only in de-identified form, we will not attempt tore-identify your data in response to a request.

If you make a request related to personal information about you, we will need to verify your identity. To do so, we will request that you match specific pieces of information you have provided us previously, as well as, in some instances, provide a signed declaration under penalty of perjury that you are the individual whose personal information is the subject of the request. If it is necessary to collect additional information from you, we will use the information only for verification purposes and will delete it as soon as practicable after complying with the request. For requests related to particularly sensitive information, we may require additional proof of identification. If you make a request through an authorized agent, we will require written proof that the agent is authorized to act on your behalf. We will process your request within the time provided by applicable law.

We can be reached at info@stoneridgeam.com or call us at (212) 257-4770.

X. Changes to this Privacy Notice

We may change or update portions of this Privacy Notice at any time without notice to you. Please check back from time to time so you are aware of any changes or updates to the Privacy Notice. The revision date appearing on the first page of this Privacy Notice underneath the title will identify the date of the last update or revision.

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