Maverick Capital, and its affiliates, including Maverick Ventures (collectively, “Maverick”), is organization that prides itself on our deeply held values of responsibility and integrity. Since our founding in 1993 we have been committed to maintaining a work environment free from all forms of discrimination and harassment including sexual harassment.

Maverick has equal employment opportunity and anti-harassment policies, complaint resolution procedures and a whistleblower protection policy that can be requested from the firm. In addition, to continue our strong history of inclusivity, Maverick conducts firm-wide training sessions to cover respect and dignity in the workplace.

A summary of some of our relevant policies can be found below. If anyone has any questions, concerns or would like to report harassment-related issues, they can contact our general counsel, Trevor Wiessmann, Esq., at trevor.wiessmann@maverickcap.com.

EQUAL EMPLOYMENT OPPORTUNITY POLICY. It is Maverick’s policy to hire well qualified people to perform the many tasks necessary in providing high quality investment management services. An integral part of this policy is to provide equal employment opportunity for all persons.

In this regard, Maverick (1) adheres to federal and local laws, regulations, and guidelines with regard to nondiscrimination against job applicants and Maverick employees, and (2) provides equal employment opportunity for all persons, including in its recruiting practices and its administration of all hiring, working conditions, benefits and privileges of employment, compensation, training opportunities for advancement, and terminations of employment, without regard to the person's age, race, religious creed, sex, color, national origin, ancestry, or mental or physical disability unrelated to the job to be performed. All Maverick Personnel are expected to carry out their various job responsibilities in a manner that comports with Maverick’s equal employment policy.

ANTI-HARASSMENT POLICY. Maverick is committed to the principle that all of its employees, clients, vendors and other counterparties should be able to enjoy a work environment free from all forms of discrimination and harassment, including, but not limited to, sexual harassment and harassment based on race, color, national origin, religion, gender, age, disability, and other bases of discrimination prohibited by law.

All Maverick Personnel are prohibited from offering, promoting, or granting preferential treatment to any employee, applicant for employment or other counterparty or potential counterparty as a result of that individual's engaging in or agreeing to engage in sexual conduct. Likewise, all Maverick Personnel are prohibited from using an employee's, applicant's, counterparty’s or potential counterparty’s refusal to engage in such conduct as a basis for a professional decision affecting that individual. An intimidating, hostile, or offensive working environment may be created by such circumstances as pressure for sexual activities, unwanted and unnecessary physical contact with another employee, verbal abuse of a sexual nature, the inappropriate use of sexually explicit or offensive language, or the display in the workplace of sexually suggestive objects or pictures.

If you believe that you have been a victim of harassment in any form by a supervisor, coworker, client, vendor, or other visitor, report the incident to any partner, senior member of management, office manager or member of the HR Department immediately.

Maverick will investigate all allegations of discrimination and harassment in as prompt and confidential a manner as possible and will take appropriate corrective action when warranted. Any person who is determined by Maverick, as a result of such an investigation, to have engaged in discrimination or harassment in violation of this policy may be subject to appropriate disciplinary action, up to and including termination of employment. Further, retaliation in any form against an employee or applicant who complains of discrimination or harassment is strictly prohibited, and may itself be cause for appropriate disciplinary action.

WHISTLEBLOWER POLICY. Maverick’s Whistleblower Policy covers the treatment of all concerns or complaints relating to activity that Maverick personnel reasonably believe could be improper, including, but not limited to, any violations of Maverick’s equal employment opportunity and harassment policies.

Maverick will take seriously any report regarding a potential violation of Maverick policy or other improper or illegal activity, and will promptly investigate such allegations in the manner appropriate based on the circumstances. Maverick recognizes the importance of keeping the identity of the reporting person confidential, and provides assurances that Maverick will respond to all such reported concerns or suspicions of improper activity in a timely and professional manner, confidentially and without retaliation.

It is Maverick’s policy that no person who submits a complaint (or concern) made in good faith, including to any governmental, regulatory or law enforcement agency, will experience retaliation, harassment, or unfavorable or adverse employment consequences as a result of the complaint. Anyone who retaliates against a person reporting a complaint will be subject to disciplinary action, which may include termination of employment.

Whistleblowers are required to act in good faith in reporting a complaint and must have reasonable grounds for believing a violation of Maverick’s compliance policies, employment policies or a law or regulation has occurred. Making a malicious allegation that an individual knows to be false would be considered a serious offense and would be treated as such.

PRIVACY POLICY AND DATA PROTECTION NOTICE. Maverick Capital, Ltd., its affiliates and the funds that they manage (collectively, “Maverick”) are required by various laws to make individuals aware of our established practices concerning the protection of their privacy and non-public personal information. Maverick collects non-public personal information about investors and employees in the regular course of doing business. The information includes but is not limited to information provided to use by investors in conjunction with their investments as well as information about their investments. Maverick discloses such information as permitted or required by law. Maverick does not sell personal data.

Access to personal information concerning our investors and employees is restricted to our employees, affiliates and required service providers (as described in more detail below). Maverick maintains and routinely reviews physical, electronic and procedural safeguards to protect the privacy of its investors and individual data.

Where your details are provided to any fund managed by Maverick (each, a “Fund”) as a consequence of your investment in the Fund, then Maverick, acting as a data controller may itself (or through a third party acting in its capacity as the applicable Fund’s administrator or its affiliates (collectively, the “Administrator”)) process your personal data or that of your directors, officers, employees and/or beneficial owners. The Administrator may also act as a data controller of your personal data in connection with the performance of its legal and contractual obligations as Administrator of the Fund.

Please ensure that you provide a copy of this Privacy Policy and Data Protection Notice to any third parties, including individuals, whose personal data you provide to the Fund, Maverick or the Administrator. Should this Privacy Policy and Data Protection Notice be materially updated at any time, you will specifically be notified of such changes.

1. Personal Data Collected

Maverick, as a “data controller”, and the Administrator, as a data processor, processes and discloses your personal data. The types of personal data collected, processed and disclosed varies. This information can include:

• Name
• Address
• E-mail address
• Social Security number
• Tax identification number
• Account balance

2. Method of Collecting Personal Data

• Maverick may obtain your data from multiple sources including but not limited to:
• The Administrator;
• Applications for employment;
• Through transactions with any Fund;
• Third parties conducting background checks to satisfy anti-money laundering and sanctions compliance obligations; or
• Publicly available sources such as social media.

Cookies and Tracking Technologies

This website may use “cookies,” which from time to time automatically collect certain information and data. “Cookies” are small pieces of data sent to your computer browser from our web server and stored on your computer’s hard drive. The data identifies you as a unique user and facilitates your ongoing access to and use of this website. Cookies also help us diagnose problems with our server.

3. Purposes of Processing and Legal Basis for Processing

Your personal data may be processed by Maverick or the Administrator (or any of their affiliates, agents, employees, delegates or sub-contractors) for the following purposes:

• Managing and administering your holdings in a Fund, including assessing and processing applications, communicating with you about your holdings and account related activities on an on-going basis;
• To update and maintain records and provide NAV and other calculations;
• To manage and maintain Maverick’s relationships with you and for ongoing customer service;
• To enforce or defend a Fund’s rights, itself or through third parties to whom it delegates such responsibilities;
• To comply with any applicable legal, tax or regulatory obligations on Maverick or the Administrator, which derive from anti-money laundering and counter-terrorism legislation;

This use of your personal data is necessary for performance of your contract with Maverick.

• In order to carry out anti-money laundering checks and related actions including sharing data with police, law enforcement, tax authorities or other government and fraud prevention agencies where Maverick has a legal obligation, including screening transactions, reporting suspicious activity and complying with production and court orders;
• To report tax related information to tax authorities;
• To investigate and resolve complaints and manage contentious regulatory matters, investigations and litigation;
• To monitor electronic communications for investigation and fraud prevention purposes, crime detection, prevention and investigation;

This use of your personal data is necessary in order to comply with any legal or regulatory obligations.

The day to day running and management of a Fund including to:

• Monitor, maintain and improve the processes, information and data, technology and communications solutions and services used by the Fund;
• Perform general, financial and regulatory accounting and reporting;
• Monitor and record calls for quality, business analysis, training and related purposes in order to pursue the legitimate interests of the Fund to improve its service delivery; and
• Protect Maverick’s legal rights and interests including screening transactions for fraud prevention and anti-money laundering purposes.

This use of your personal data is necessary for Maverick’s legitimate business interest in managing our business including legal, personnel, administrative and management purposes and for the prevention and detection of crime provided Maverick’s interests are not overridden by your interests.

4. Recipients of Data and International Transfer of Data

Maverick and the Administrator may disclose your personal data as follows:

• To their affiliates and third-party service providers engaged in connection with the oversight, safekeeping, administration, distribution or operation of a Fund, in order to process the data for the above-mentioned purposes (including Maverick and non-Maverick entities);
• To competent authorities (including tax authorities), courts and bodies as required by applicable law or requested by such entities or to affiliates for internal investigations and reporting; or
• To third party service providers engaged in background checks

If you are located within the European Economic Area (“EEA”), please be aware that the disclosure of personal data to the third parties set out above likely involves the transfer of data to the USA and other jurisdictions outside the EEA. Such countries may not have the same data protection laws as your jurisdiction and the Funds have, inter alia, authorised the Administrator as its agent to ensure the transfer of data by the Administrator outside the EEA is subject to a contract incorporating standard contractual clauses in the form adopted by the European Commission under Decision 2010/87/EU, Decision 2004/915/EC or an equivalent or replacement decision (the “Model Clauses”).

5. Retention period

Maverick and the Administrator will retain your personal data for a minimum period of 5 years from the date on which you redeem all your investment in the Funds or for as long as required for Maverick or the Administrator to perform the services or comply with applicable legal/regulatory obligations.

6. Consequences of not Providing Required Data

Where Maverick or the Administrator requires your personal data to comply with anti-money laundering or other legal requirements, failure to provide this information means a Fund may not be able to accept you as an investor and/or may be unable to process or release your investment. This may result in the Fund terminating its relationship with you. When you are asked for your information you will be informed whether it is a statutory or contractual requirement to provide the information and the consequences of not providing the information.

7. Data Subject Rights

You have various rights in relation to your personal data, including the right to request access to your personal data, correct any mistakes on Maverick’s records, request the deletion of your personal data, restrict the processing of personal data where you contest its accuracy or the lawfulness of its processing, or where your personal data are no longer required, object to use of personal data based on legitimate business interests, and ask not to be subject to automated decision making if the decision produces legal or other significant effects on you.

In addition, you are entitled to the portability of the personal data that you provided on the basis of consent or for the performance of the contract of which you are party and only to the extent that the processing is carried out by automated means.

Maverick will acknowledge receipt of your request within 10 days and respond to your request in writing, or orally if requested, as soon as practicable and in any event not more than within one month after receipt of your request. In exceptional cases, Maverick may extend this period by two months and will tell you why. Maverick may request proof of identification to verify your request.

You have the right to lodge a complaint to Maverick’s Chief Compliance Officer or with a supervisory authority if you consider that the processing of your personal data infringes applicable data protection laws.

HOW TO CONTACT MAVERICK. If you have any questions about Maverick’s use or the Administrator’s use of your personal data, please contact Maverick at compliance@maverickcap.com or (214) 880-4000. To make a request under the California Consumer Protection Act, in addition to the contact information previously provided, California consumers and their agents may dial toll free +1 (844) 771-7319.