CLOUGH CAPITAL PARTNERS L.P.

WEBSITE PRIVACY POLICY

Effective as of October 1, 2020

Clough Capital Partners L.P. (the “Firm”) and the investment funds for which it serves as investment manager may collect nonpublic information, including “personal data” as defined under applicable European Data Privacy Laws (defined below), of the Firm’s clients or prospective clients. This Website Privacy Policy (the “Policy”) applies to the processing of personal information that may be collected through this website (www.cloughcapital.com) (the “Site”). The Firm maintains a strong commitment to the importance of protecting data privacy, and to taking the appropriate steps to seek to ensure that any nonpublic information or personal data collected from any of our clients or prospective clients through this Site is protected in compliance with applicable data protection laws in the jurisdictions in which we operate or where our clients or prospective clients are located.

For European residents, this Policy describes the basis on which we process personal data and for what purposes, a summary of the privacy rights under applicable European privacy laws, including the General Data Protection Regulation, and other UK and European data privacy laws (collectively, the “European Data Privacy Laws”) and how we protect personal data privacy.

For purposes of the European Data Privacy Laws, the Firm is the data controller in relation to the processing activities described herein. This means that the Firm decides why and how any personal data is used. All personal data provided to us by clients or prospective clients located within the European Economic Area (the “EEA”) may be retained in the United States, processed in the United States by the Firm or its agents, and may also be transferred to other countries outside the EEA. Not all countries have similar data protection laws to those of the EEA, and even countries that do have data protection laws may have less robust provisions than those of the EEA.

Certain information collected by the Firm may be “nonpublic personal information” or “NPI” and, as such, subject to Regulation S-P. For more information on how we collect, use and share NPI, please see the Firm’s Privacy Notice, available by calling the Firm at 617-204-3400. Such Privacy Notice and the practices described therein are applicable to individuals only and are subject to change.

In addition, the Firm may, with consent if legally required under the European Data Privacy Rights, process personal information in order to communicate with the customers for marketing purposes. In this event, the Firm may provide additional information to clients or prospective clients that it believes may be of interest, including about services, news updates, research or market commentary, conferences, or events offered by or in conjunction with the Firm. A client/relevant individual whose email address is used for such communications has the right to unsubscribe by contacting the Firm or by following the instructions in any such communication, e.g. by clicking on an embedded link to unsubscribe.

Site Data Collection:

When someone visits our Site from their computer, mobile phone, tablet, or other device, we may collect certain information from them, including their Internet Protocol (“IP”) address, media access control (“MAC”) address, browser type, operating system, device-identifying information, the specific web pages visited during the connection, and the domain name from which they accessed the Site. In addition, we may collect information about browsing activity on our Site, such as the date and time they visit the Site, the areas or pages of the Site that they visit, the amount of time they spend viewing the Site, the number of times they return to the Site and other clickstream data. We may also use non-personal or aggregated information for statistical analysis, research, and other purposes.

The Firm may also collect information about you when you access the Site if you voluntarily choose to send electronic mail to the Firm, request information, or ask to be contacted. The Firm may use this information to provide you with updated information about the products and services we offer.  Certain employees of the Firm may be given the information you provide in order to respond to your requests. Employees of the Firm are required to handle any personal information you provide confidentially.

Our Site may also use “cookies” and “web beacons” (such as Google Analytics, for example) to collect, store and aggregate data about usage and browsing patterns. With respect to web analytics, we may use cookies and web beacons for session management and to analyze site usage; we do not use cookies and web beacons to store any personally identifiable information about you. A “cookie” is a small text file containing a random and unique alphanumeric identifier that we transfer to your computer’s hard drive through your web browser (unless you set your browser to reject cookies) that enables our systems to recognize your browser. A “web beacon” (also known as a “page tag,” “data tag” or “image tag”) is a mechanism by which a small section of code that is embedded in our Site pages allows us to check that a user has viewed the page. These technologies can help us analyze and better understand how our Site is being used and improve the user experience.  A person browsing the internet may adjust their browser settings to reject cookies, or they can manually delete individual cookies or all of the cookies on their computer or other device, by following their browser’s help file directions. However, if their browser is set to reject cookies or they manually delete cookies, they may have some trouble accessing and using some of the pages and features that are currently on our Site, or that we may put on our Site in the future. Note that browser-management tools for cookies are outside of our control and we cannot guarantee their effectiveness.

We may work with service providers that help us track, collect and analyze information gathered through cookies or web beacons. We may also combine the information we collect through cookies and web beacons with other information we have collected from clients or information from other sources. We only use such information to evaluate usage of the Site and improve performance and customer services, as well as to protect the security and integrity of the Site and our business, such as preventing fraud, hacking, and other criminal activity or to meet legal obligations. We only share such information with our service providers to perform a business, professional or technical support function for us.

Sharing of personal information:

Like other financial companies, the Firm needs to share some of our clients’ information to run our business. The Firm may disclose personal information to its affiliated entities and brokers, banks, agents, employees, and third parties who need to know that information in order to perform services on the clients’ behalf or in connection with the services provided to such clients, and to other third parties, including (but not limited to) the following types of third parties:

  • Financial service providers, such as the Firm’s (or its clients’) administrators, prime brokers, registered broker/dealers, auditors, regulators, and transfer agents in order to service customer accounts and/or who assist the Firm as part of the ordinary course of servicing clients’ investments or providing any other services to clients;
  • Legal representatives of the Firm, such as our counsel, accountants and auditors;
  • Third parties who may perform marketing services for the Firm or with whom we have entered into marketing arrangements for services or information about services that clients may request;
  • Other service providers; and/or
  • Parties to a dispute or litigation, and their representatives and advisors, or regulatory or governmental authorities or otherwise as permitted by law.

The Firm will exercise appropriate due diligence in the selection of its third-party service providers, including with respect to their maintenance of adequate technical and organizational security measures to safeguard personal information.

The Firm may also disclose personal information to governmental authorities as required or permitted by law; public and private social security and insurance agencies; consultants in connection with business operations; to business partners, agents and customers; external consultants and professionals; courts and other dispute forums. This personal information will be disclosed to such third parties only as necessary in connection with the performance of contracts, the Firm’s business activities and the purposes listed above or as otherwise authorized, required, or permitted by law. The Firm may continue to maintain and share information about its clients and/or the investors therein even after they are no longer clients or investors.

In addition, to comply with Massachusetts Data Security Regulation and other applicable laws, the Firm has developed a process to ensure confidentiality and integrity of personal information maintained by the Firm and its administrators that could create the risk of identity theft or fraud against a resident of the Commonwealth of Massachusetts and have codified the policies and procedures in writing.

Your California Privacy Rights:

The Firm complies with the California Consumer Privacy Act of 2018 (“CCPA”) by providing California residents with the following rights with respect to their personal information:

  • The right to know what personal information the Firm has collected, used, disclosed and sold. To submit a request to know, California residents may call the Firm at 617-204-3400. California residents may also designate an authorized agent to make a request for access on their behalf by calling the Firm at 617-204-3400.
  • The right to request that the Firm delete any personal information it has collected. To submit a request for deletion, California residents may call the Firm at 617-204-3400. California residents may also designate an authorized agent to make a request for deletion on their behalf by calling the Firm at 617-204-3400.

When California residents exercise these rights and submit a request, the Firm will verify their identity by asking them for their email address, telephone number, and/or information about their account with the Firm. The Firm will endeavor to honor customers’ requests unless such a request conflicts with certain lawful exemptions under the CCPA. Please note that the Firm is only required to honor such requests twice in a twelve (12) month-long period.

Any exercise of these rights will have no adverse effect on the price and quality of the Firm’s services.

For the twelve (12) month-long period prior to the date of this Privacy Notice, the Firm has not sold any personal information about its customers; nor does it have any plans to do so in the future.

Your European Privacy Rights:

Where the European Data Privacy Laws apply, the relevant individual whose personal data is processed by the Firm has certain rights relating to their personal data in accordance with and subject to the European Data Privacy Laws including to: (i) check whether the Firm holds personal data about them and to access such personal data; (ii) request the correction of personal data that is inaccurate; (iii) have a copy of the personal data provided to another data controller (as defined under the European Data Privacy Laws) where technically feasible; (iv) request the erasure of the personal data; and (v) request the restriction of processing the personal data. To exercise any of these rights, customers should send the request to the email below.
The Firm retains personal data for a period of at least six (6) years from the date on which the relevant business relationship, for which purpose such personal data was provided, has ended.

We may change this Policy from time to time, including as necessary to keep current with rules and regulations, new technologies and security standards. When we do, we will post the change(s) on our Site. Please visit our Site (www.cloughcapital.com) periodically to review this Policy, so as to ensure that you have access to the most current version. Please do not hesitate to contact us at (617) 204-3400 with any questions about this Policy.

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