Privacy Policy

GPB Capital Holdings, LLC (together with its affiliates “GPB”)

GPB is required to notify clients of its policies regarding the privacy of a client’s personal information on an annual basis. GPB recognizes and appreciates the importance of respecting the privacy of its clients. GPB values the trust our customers place with us and is committed to safeguarding against the unauthorized use of, and access to, customer information. The following policies apply to current and former clients of the GPB.

What does GPB do with your personal information?
Financial companies choose how they share your personal information. Federal law gives our clients the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.
We do not disclose nonpublic personal information about our clients, former clients or investors in our clients to third parties other than as described below.

Personal information we collect. We collect personal information about you in connection with our providing advisory services to you, or to our clients in which you invest (collectively, “you”). This information includes your name, date of birth, citizenship, social security number and may include other information such as your:
• Assets;
• Investment experience;
• Transaction history;
• Employment and Income Information; and
• Wire transfer instructions.

How we collect this information. We collect this information from you through various means in connection with providing a financial product or service to you and may include: when you give us your contact information, enter into an investment advisory contract with us, become a limited partner in the funds we advise, buy or sell securities (i.e., interests in a fund) with us, place a transaction with us, tell us where to send money, or make a wire transfer. We also may collect your personal information from other sources, such as our affiliates(¹) or other non-affiliated companies.

How we use this information. All financial companies need to share customers’ personal information to run their everyday business and we use the personal information we collect from you for our everyday business purposes. These purposes may include, for example:

• To provide and improve advisory services to you;
• To evaluate or analyze the services we provide to you;
• To open an account for you;
• To process a transaction for your account
• To market products and services to you; and
• To respond to court orders and legal investigations.

We may also share your information with third parties, including but not limited to third-party market research firms for analysis purposes and to help such third parties generate market research data for us which will not identify you personally. Such third parties will provide us market research data to help us better segment our customer base and understand what products and services would likely work best for our customers.

We may also hire other companies to perform certain business-related functions on our behalf. Examples of such functions include website hosting, mailing information, maintaining databases, ID verification, processing applications, processing payments and completing transactions. When we employ another company to perform a function of this nature, we only provide it with the information that it needs to perform its specific function. These companies are authorized to use your information only as necessary to provide these services to us.

Information Collected by or Received from Third-Party Sources. We may also collect personal information and information about your transactions with us and those you engage in with our affiliates, unaffiliated third parties, banking verification services and information from consumer reporting agencies. We may further collect information about you from third-party data sources, such as brokers, banks and government databases. We may combine data we collect about you from third-party data sources with data we collect from you and may use and share such data as described in this Privacy Policy. All information we collect and/or receive from such third-party sources is collectively referred to as “Third-Party Information.”

Disclosure to others. We may provide your personal information to our affiliates and to firms that assist us in servicing your account and have a need for such information, such as a prime broker, bank, accountant, or fund administrator. We may also disclose such information to service providers and financial institutions with whom we have joint marketing arrangements (i.e., a formal agreement between nonaffiliated financial companies that together market financial products or services to you, such as placement agents). We require third-party service providers and financial institutions with which we have joint marketing arrangements to protect the confidentiality of your information and to use the information only for the purposes for which we disclose the information to them. These sharing practices are consistent with Federal privacy and related laws, and in general, you may not limit our use of your personal information for these purposes under such laws. We note that the Federal privacy laws only give you the right to limit
the certain types of information sharing that we do not engage in (e.g., sharing with our affiliates certain information relating to your transaction history or creditworthiness for their use in marketing to you, or sharing any personal information with non-affiliates for them to market to you).

How we protect your personal information. To protect your personal information from unauthorized access and use, we use security measures that comply with Federal law. These measures include computer safeguards and secured files and buildings.

We take commercially reasonable technical, administrative, and physical safeguards to protect information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases or the databases of the third parties with which we may share such information, nor can we guarantee that the information you supply will not be intercepted while being transmitted over the Internet. In particular, email sent to us may not be secure, and you should therefore take special care in deciding what information you send to us via email.

Who is providing this Privacy Notice. This Privacy Notice relates to the following entities:
• GPB Capital Holdings, LLC
• GPB Holdings II, LP
• GPB Holdings III, LP
• GPB SLP, LLC
• GPB Holdings Qualified, LP
• GPB Automotive Portfolio, LP
• GPB Holdings, LP
• Armada Waste Management, LP
• GPB NYC Development, LP
• GPB Cold Storage, LP

Whom to contact with questions. If you have any questions about security on our website, you can contact us at (877)-489-8484.

¹ Our affiliates are companies related to us by common ownership or control and can include both financial and nonfinancial companies. Non- affiliates are companies not related to us by common ownership or control and can include both financial and nonfinancial companies.