Privacy Policy

Last Updated: September 11, 2026

Effective Date: September 11, 2026

This Privacy Policy explains how Senator Investment Group LP (“Senator,” “we,” “us,” or “our”) and its affiliates collect, use, disclose, and safeguard information in connection with use of www.senatorlp.com (the “Site”). This Privacy Policy applies only to information collected through the Site and does not extend to information collected through other channels, such as investor onboarding materials, subscription agreements, or offline correspondence, which are addressed under separate agreements and notices. Information that we collect in the context of providing financial services, such as investment advice, (e.g., to evaluate and establish investor, fund, account, and other business relationships, to conduct fund administration activities, to conduct investment and asset management and related business activities, and to perform regulatory compliance activities) is instead described in our Privacy Notice. Please contact us at legal@senatorlp.com to request a copy.

Certain parts of this Privacy Policy apply only to particular individuals, jurisdictions, products, services, or relationships. For example, the “Supplemental Information for California Consumers” section applies to California residents. The “Supplemental Information for the United Kingdom, European Economic Area, and Switzerland” section applies to individuals in the European Economic Area, the United Kingdom, and Switzerland.

1. INFORMATION COLLECTED

Senator may collect personal information from the following sources:

(a) Directly from visitors to the Site.
(b) Automatically through cookies, pixels, tags, scripts, server-side tools and similar technologies (collectively, “Cookies”). This may include information about how visitors use and interact with our Sites, information about visitors’ devices, and internet usage information.
(c) Third parties, such as service providers, our affiliated companies and subsidiaries, business partners, and other parties who interact with us.

Depending on the nature of a visitor's interaction with the Site, Senator may collect:

(a) contact and identifying details submitted voluntarily, such as name, email address, phone number, and any message content provided through a contact or inquiry form;
(b) credentials associated with any password-protected investor or portal access made available through the Site; and
(c) technical and usage information collected automatically, such as IP address, browser and device type, referring pages, and pages viewed, typically gathered through cookies or comparable technologies.

Visitors are asked not to submit through the Site any confidential, proprietary, or sensitive personal information beyond what is reasonably necessary to respond to an inquiry.

2. USE OF INFORMATION

Information collected through the Site may be used to:

(a) operate, maintain, and improve the Site;
(b) respond to inquiries and provide requested information;
(c) maintain the security and integrity of Senator's systems, including detecting and preventing fraudulent or unauthorized activity;
(d) comply with applicable law, regulatory obligations, or legal process; and
(e) communicate about Senator where such communication has been requested or is otherwise permitted by law.

We may use anonymized, de-identified, or aggregated information for any purpose permitted by law.

3. COOKIES AND SIMILAR TECHNOLOGIES

Senator and our authorized third parties may use Cookies and comparable technologies to collect certain information about your equipment, browsing actions, and patterns to support core functionality and to understand usage patterns. We may use Google Analytics to better understand how our Services are used and to improve them. To learn more about how Google Analytics collects and processes data, please visit www.google.com/policies/privacy/partners.

Most browsers permit blocking or deletion of Cookies, though doing so may limit certain Site functionality. The Site does not use any marketing or advertising Cookies. As a result, the Site does not currently respond to Global Privacy Control (“GPC”) browser settings or similar mechanisms. The Site does not currently respond to browser “Do Not Track” signals, given the absence of a common industry standard for interpreting them.

4. DISCLOSURE OF INFORMATION

Information collected may be disclosed to:

(a) Senator affiliates and subsidiaries, including parent entities, corporate affiliates, subsidiaries, business units, and other companies that share common ownership;
(b) service providers supporting Site operations, hosting, or security, or that otherwise work on our behalf to provide the information or services you request or support our relationship with you;
(c) professional consultants, such as accountants, lawyers, financial advisors, and audit firms;
(d) regulators, courts, or law enforcement where required by law, regulation, or legal process, or to enforce the Terms of Use and other agreements or policies, and protect ours or third parties’ safety, property, or rights;
(e) a successor entity in connection with a merger, reorganization, bankruptcy, or similar transactions and forms of corporate change; and
(f) entities to which you have consented to the disclosure.

5. DATA SECURITY AND RETENTION

Senator maintains administrative and technical safeguards designed to protect information collected through the Site from unauthorized access, use, or disclosure. No method of transmission or storage can be guaranteed fully secure, and information transmitted to the Site is done at the sender's own risk. Information is retained only for as long as reasonably necessary to fulfill the purposes described in this Policy or to satisfy applicable legal, regulatory, or recordkeeping obligations, after which it is deleted or de-identified.

6. CHILDREN'S PRIVACY

The Site is not directed to individuals under the age of eighteen, and Senator does not knowingly collect personal information from children through the Site.

7. CONTACT INFORMATION

Questions, requests, or complaints regarding this Privacy Policy may be directed to:

Senator Investment Group LP

124 East 14th Street, 20th Floor

New York, NY 10003

Attn: Compliance

Telephone: (212) 376-4300

Email: legal@senatorlp.com

8. CHANGES TO THIS PRIVACY POLICY

This Privacy Policy may be updated from time to time. The effective date of the current version will be reflected wherever this Policy is posted, and material changes will be communicated to you as required by applicable law, such as highlighted through a notice on the Site.

9. EXTERNAL LINKS

The Site may contain links to external sites or other online services that we do not control, including those embedded in third party advertisements or sponsor information. Senator is not responsible for the privacy practices or data collection policies of such third-party services. You should consult the privacy notices of those third-party services for details on their practices.

Supplemental Information for California Consumers

This notice contains disclosures required by the California Consumer Privacy Act (“CCPA”). Terms defined in the CCPA have the same meaning when used in this section. This section “Supplemental Information for California Consumers” is only relevant to California residents (“consumers” or “you”). Consumers with disabilities may access this notice by contacting us on (212) 376-4300.

Information We Collect. In the past 12 months, we have collected and disclosed for a business purpose the following categories of personal information (“Personal Information”), as described in the “Information Collected” section above:

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Categories of Personal Information
Category	Examples	Collected	Disclosed to third parties listed in “Disclosure of Information” section above, for Business Purposes described in “Use of Information” section above
A. Identifiers	A real name, alias, email address, postal address, Internet Protocol (IP) address, account name, Social Security number, driver’s license number, passport number, or other similar personal identifiers.	YES	YES
B. Other personal information categories, as listed in the California Customer Records Statute	A signature, physical characteristics or description, telephone number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.	YES	YES
C. Protected classification characteristics under California or federal law	Age (40 years or older), race, citizenship, marital status, sex, veteran or military status.	YES	YES
D. Commercial information	Account activity, records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	NO	NO
E. Biometric information	Fingerprints, faceprints, voiceprints, and iris or retina scans.	NO	NO
F. Internet or other similar network activity	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	YES	NO
G. Geolocation data	Physical location or movements.	NO	NO
H. Sensory data	Audio, electronic, visual, thermal, olfactory, or similar information.	NO	NO
I. Professional or employment-related information	Current or past job history or performance evaluations.	YES	YES
J. Non-public education information (per the Family Educational Rights and Privacy Act)	Education records directly related to a student maintained by an educational institution or party acting on its behalf.	NO	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	NO
L. Sensitive personal information	A consumer's Social Security, driver’s license, state ID card, or passport number; account log‐in or debit/credit card number in combination with any access code, password, or account credentials; precise geolocation; racial/ethnic origin, religious/philosophical beliefs, or union membership; contents of mail, email, and text messages; genetic data; biometric information; health information; or sex life or sexual orientation	YES	YES

In the past 12 months, we have not sold Personal Information to third parties or shared Personal Information for cross-context behavioral advertising, including information about consumers under the age of 16.

We do not use or disclose sensitive Personal Information for purposes other than (i) performing services or providing goods reasonably expected by an average consumer; (ii) detecting security incidents; (iii) resisting malicious, deceptive, or illegal actions; (iv) ensuring the physical safety of individuals; (v) short-term, transient use, including non-personalized advertising; (vi) performing or providing internal business services; (vii) verifying or maintaining the quality or safety of a service or device; or (viii) purposes that do not infer characteristics about you.

Rights of California Consumers. The CCPA provides a California consumer the following rights, subject to certain exceptions and limitations:

The right to request: (a) the categories and specific pieces of Personal Information we collect about you; (b) the categories of sources from which we collect your Personal Information; (c) our business or commercial purposes for collecting, selling or sharing your Personal Information; (d) the categories of Personal Information disclosed for a business purpose and the categories of persons to whom it was disclosed; (e) the categories of your Personal Information (if any) that we have either sold, shared, or disclosed.
The right to request that we delete your Personal Information, subject to certain exceptions.
The right to opt out of our sale(s) or sharing for the purposes of cross-context behavioral advertising of your Personal Information.
The right to request we correct any inaccurate Personal Information maintained about you.
The right to limit our use of your sensitive Personal Information. As described above, we do not use or disclose sensitive Personal Information in ways that would require us to provide a right to limit.

We will not discriminate or retaliate against you for exercising your privacy rights.

You may submit requests relating to your exercise of CCPA rights to us via:

Phone: (212) 376-4300

email: legal@senatorlp.com

To process rights requests, we may need to obtain information to locate you in our records or verify your identity depending on the nature of the request, such as information necessary to verify your identity and that you are a resident of a state that provides for these rights. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. If we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity, and for security or fraud-prevention purposes. We may deny your request if we cannot verify your identity.

Where permitted by law, you may also designate an authorized agent to requests on your behalf. Depending on the request, Senator may reach out to you directly to verify your own identity or to confirm that you provided the authorized agent with permission to submit the request, or seek additional information directly from the authorized agent to process the request.

Supplemental Information for the United Kingdom, European Economic Area, and Switzerland

The following terms supplement the above disclosures with respect to our processing of EEA, Swiss, and UK personal information, and only apply to the extent that EEA, Swiss, or UK data protection laws, apply to our processing of personal information.

Data Controller: Unless otherwise specified Senator Investment Group LP is responsible for the processing of your personal information as the controller.

Legal Bases for Processing: We process personal information in reliance on the following legal bases:

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Legal Bases for Processing
Processing Purposes	Categories of Personal Information	Legal Bases
To deliver our services	All categories of information we collect	Performance of a contract to which you are a party or to take steps at your request prior to entering a contract. Legitimate interests as set out in the “Use of Information” section above. Your consent, when appropriate.
To market to you and send you information	Contact and identifying details	Legitimate interests as set out in the “Use of Information” section above. Your consent, when appropriate.
To contact you when necessary	Contact and identifying details	Legitimate interests as set out in the “Use of Information” section above. Compliance with a legal or statutory obligation to which we are subject. Your consent, when appropriate.
For our internal business purposes	All categories of information we collect	Performance of a contract to which you are a party or to take steps at your request prior to entering a contract. Compliance with a legal or statutory obligation to which we are subject. Legitimate interests as set out in the “Use of Information” section above. Your consent, when appropriate.
For our internal research and improvement purposes	All categories of information we collect	Legitimate interests as set out in the “Use of Information” section above. Your consent, when appropriate.
To protect the security or integrity of our business	All categories of information we collect	Performance of a contract to which you are a party or to take steps at your request prior to entering a contract. Compliance with a legal or statutory obligation to which we are subject. Legitimate interests as set out in the “Use of Information” section above. Establishment, exercise, or defense of legal claims. Protection of vital interests. Your consent, when appropriate.
For legal reasons	All categories of information we collect	Performance of a contract to which you are a party or to take steps at your request prior to entering a contract. Compliance with a legal or statutory obligation to which we are subject. Legitimate interests as set out in the “Use of Information” section above. Establishment, exercise, or defense of legal claims. Protection of vital interests. Your consent, when appropriate.
In connection with a corporate transaction	All categories of information we collect	Legitimate interests as set out in “Use of Information” section above.

Your Data Protection Rights. You may exercise certain rights regarding your personal information.

Right to Access. You may have the right to obtain confirmation from us whether we are processing your personal information and a copy of your personal information.
Right to Data Portability. You may have the right to your personal information be provided to you in a structured, commonly used, and machine-readable format.
Right to Rectification. You may have the right to request that we rectify inaccurate personal information and complete incomplete data.
Right to Objection. You may have the right to object to the processing of your personal information in certain cases.
Right to Restrict Processing. You may request that we restrict the processing of your personal information in certain cases.
Right to Erasure. You may request that we erase your personal information in certain cases.
Right to Refuse or Withdraw Consent. In case we ask for your consent to process your personal information, you are free to refuse to give it. If you have given your consent, you may withdraw it at any time without any adverse consequences. The withdrawal of your consent will not affect the lawfulness of any processing of your Personal Information that occurred prior to your withdrawal.
Right to Not Be Subject to Automated Decision-making. You have the right not to be subject to a decision based solely on automated processing and to be given more information about why any such decision was made.

You may exercise these rights by contacting us using the information described under the “Contact Information” section above. If you are not satisfied with our response, you have the right to lodge a complaint with a supervisory authority in the country where you reside or where the conduct that is the subject of the complaint occurred. You can also lodge a complaint with us using the information in the “Contact Information” section above if UK laws apply to you and you think we have infringed our UK data protection obligations when handling your personal information.

International Transfers

Personal information may be transferred to and processed in the United States and other jurisdictions that do not provide an adequate level of data protection as defined by data protection laws in your country. Where required, appropriate safeguards, such as standard contractual clauses, are used to protect data transferred outside the European Economic Area or the United Kingdom.

Privacy Inquiries. Requests or questions concerning our processing of personal information under EEA, UK, or Swiss data protection law may be submitted using the contact details in the "Contact Information" section above.