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PAG is a private asset manager for institutional investors. We do not provide
investment advice or services for individual retail investors. We do not solicit
or contact individual investors via chat, text or social messaging applications.
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PRIVACY POLICY

Personal information collection and privacy policy statements

PAG and other companies in the PAG group collect and use certain Personal Data.
PAG is responsible for ensuring that it uses that Personal Data in compliance
with data protection laws.

At PAG we respect the privacy of our clients and we are committed to keeping all
of your Personal Data secure.  This Privacy Policy governs the handling of
Personal Data by PAG in the course of conducting its commercial activities.

We use the following definitions in this Privacy Policy:

 * “PAG”, “we” or “us” means PAG and other companies in the PAG group.
 * “Personal Data” means any information / data related to a living individual
   who can be identified (directly or indirectly) from that data or from that
   data and other information which is in possession of, or is likely to come
   into the possession of PAG (or its representatives or service providers).

In the course of our correspondence and other dealings with you, we will receive
information relating to you and/or, where you act as an agent or a
representative of a legal person or other entity (rather than a natural person),
information relating to other officers, directors, partners, members or
employees of that legal person or other entity (such information, “personal
information”). If the personal information you provide to us does not relate to
you, you agree to provide the disclosures set out below to the individuals whose
personal information you have provided.

Personal information is subject to certain legal safeguards specified in the
European Union's General Data Protection Regulation (2016/679) (“GDPR”) and any
secondary and domestic legislation implementing the GDPR, and in the Data
Protection Law, 2017 (“DPL”) of the Cayman Islands (together, the “Data
Protection Legislation”). The Personal Data which you have provided to us will
at times also be governed by the terms of the Personal Data (Privacy) Ordinance,
as amended and supplemented from time to time (the “PDPO”). PAG is a
‘controller’ of your personal information for the purposes of the PDPO or GDPR.
The PDPO and Data Protection Legislation prescribe the ways in which we may
collect, retain and handle personal information.

What personal information will we process?

The types of personal information relating to you may include, for example:

 * name, business and/or private email address, postal address and/or telephone
   number, date of birth and gender;
 * domicile and other geographic location data;
 * bank account details, source of wealth information, accounts and bank
   statements;
 * information relating to regulatory status or eligibility to make investments;
   and
 * copies of passports and other documentation required for identity or address
   verification purposes.

How do we use your personal information?

We may process your personal information in order to market our investment
products, to process queries, undertake normal investment business activities in
order to offer our services and manage assets on behalf of clients, and to
exercise our rights at law or under contract. We will also use your personal
information, where required, in order to comply with our legal and regulatory
obligations.  This may include, without limitation, establishing investor
eligibility, preventing fraud, carrying out money laundering checks or conflict
checks, and reporting to national and international regulatory and tax
authorities.

We may also process your personal information to manage and administer our
business, to analyse and improve relationships with our clients and service
providers, and for business development activities.

We may share your personal information with third parties (including legal
advisors and law enforcement agencies) in order to respond to investigations,
court orders, legal process, or to investigate, prevent or take action regarding
illegal activities, suspected fraud, or as otherwise required by law.

PAG may also use your information in order to provide you with information of
investments or products you may be interested in.  If you object to being
contacted in respect of prospective products, please contact ir@pag.com.

Lawful bases for processing your personal information

The lawful bases for processing your personal information are as follows:

Performance of contract: to ensure our ability to perform our obligations under
investment contracts and other documents that form the basis for our contractual
relationship with you (or, in certain circumstances, another person), and
certain required pre-contractual steps.  If we cannot process personal
information as required, it may not be possible for us to perform our
obligations under the relevant contract, and we may be required to terminate the
contract.

Legal obligations: we are required to comply with applicable legal and
regulatory requirements,[1] including, for example, any regulatory or tax
reporting requirements; to carry out money laundering/terrorist financing
checks, conflict checks, for purposes of fraud prevention, to comply with any
applicable auditing or financial reporting requirements; and to comply with
information disclosure requests from regulatory, tax or other governmental or
public authorities.

In addition to the above lawful bases for processing your personal information,
your personal information may also be processed on the basis of our legitimate
interests:

 * to exercise and comply with our rights and obligations at law or under
   regulation, where such obligations are set out under the laws of countries
   outside the European Economic Area (“EEA”), or under a contract to which we
   are a party;
 * to manage and administer our business and to analyse and improve our business
   relationships;
 * to communicate with you in respect of any products offered by us;
 * to undertake risk assessment and operational control exercises; for
   statistical and trend analysis; for systems administration, operation,
   testing and support and to manage and ensure the security of our information
   systems;
 * to help detect, prevent, investigate, and prosecute fraud and/or other
   criminal activity;
 * to disclose information to a governmental, tax or regulatory body, financial
   market, broker or other intermediaries, counterparties, court, auditors or
   other third parties and to undertake compliance activities, when this is in
   our interests, or in the interests of any of our clients, including where the
   laws of the European Union (“EU”) or a member state of the EEA do not require
   us to do the same;
 * to establish, exercise or defend legal claims; and in order to protect and
   enforce the rights, property, or safety of PAG, our clients, or to assist our
   clients or investors or others to do the same;
 * to investigate and respond to any complaints about PAG and its business or
   any incidents relating to PAG and to help maintain quality and to deal with
   complaints and disputes; and
 * to make certain assessments about you in order to assess your investment
   objectives, risk tolerance, and understanding of investment risk to assess
   the suitability of an investment in any investment product offered by us.

When processing your personal information, we will comply with the relevant
requirements under the PDPO, DPL or GDPR as applicable to us.

With whom do we share your personal information?

We may share certain of your personal information with the following categories
of third parties for the following reasons:

 * broker-dealers that provide trade execution services, custodians that provide
   custody services and other business services providers in connection with
   investment decisions, with respect to an investment account you hold with us
   and/or to enable PAG to provide services and operate its business;
 * advisers (e.g. auditors, legal counsel and tax advisers) to PAG relating to
   or in connection with the operation of PAG’s business, compliance with its
   legal, regulatory or contractual obligations and/or your investments with us;
 * affiliates of PAG for the purpose of undertaking investment advisory and
   investment management business; and
 * law enforcement agencies; regulatory or tax authorities and other
   governmental or public agencies or authorities in order to comply with our
   legal or regulatory obligations or at their request in furtherance of their
   objectives.

They may in turn use the services of their affiliates or service providers to
process your personal information where necessary or appropriate.  Where we
share your personal information with a third party, we generally take steps to
ensure the recipients of that personal information will process it
appropriately.

International Transfers of your personal information

Your personal information is held by PAG in its offices in Hong Kong, Japan and
Singapore, and may be shared with advisers, service providers, and disclosed to
regulatory, tax or other governmental or public authorities outside these
locations or the EEA, as described above.

Where we share your personal information with persons outside our office
locations or the EEA we will, to the extent practicable, take appropriate steps
to ensure your personal information is subject to safeguards in compliance with
the requirements of Data Protection Legislation. We will seek to achieve this,
for example, by entering into appropriate data transfer agreements with third
party recipients of your personal information which may set out the standard
contractual clauses approved by the PDPO or European Commission (as applicable)
governing the transfer of Personal Data outside the EEA, where possible.  Please
contact us if you would like a copy of the aforementioned standard contractual
clauses.

Personal Data collected for recruiting or employment purposes, regardless of
where collected, may be transferred to our Hong Kong headquarters and may be
transferred outside of the EEA (or your home country, if not the EEA) to our
affiliates or third parties that process application information for the
purposes described above. When this occurs, PAG requires such companies to treat
your information confidentially.

How long is your personal information retained?

We will not retain your personal information for longer than is necessary in
relation to the purposes for which your personal information is processed and in
accordance with regulatory requirements.  Generally, we will retain your
personal information concerning your investments for 7 years after the end of
any relevant contractual relationship.  Personal information may be retained for
longer if it is required by law, or by a tax or regulatory authority, a law
enforcement agency or other governmental or public body, or considered necessary
in order to allow us to act in accordance with a specific set of circumstances,
for example, in light of an actual or a potential legal action or a regulatory
investigation.

Where do we collect your personal information?

PAG may collect Personal Data through a range of means. These may include direct
interactions (where a person provides Personal Data to us through correspondence
or other direct methods of communication, including communications relating to
investments), third-party or publicly available sources (where a Fund receives
personal data through a publicly available source such as a website or publicly
available registry).

Safeguarding your information

We have extensive controls in place to maintain the security of our information
and information systems. Client files are protected with safeguards according to
the sensitivity of the relevant information. Appropriate controls (such as
restricted access) are placed on our computer systems. Physical access to areas
where particularly sensitive Personal Data (e.g., resumes/CVs submitted for
recruiting purposes) is gathered, processes or stored is limited to authorized
employees.

PAG employees are required to follow all applicable laws and regulations,
including in relation to data protection law. Access to sensitive Personal Data
is limited to those employees who need it to perform their roles. Unauthorized
use or disclosure of confidential client information by a PAG employee is
prohibited and may result in disciplinary measures.

EEA Data Subjects: Your rights in relation to the personal information we
process about you

In all of the above cases in which we collect, use or store your Personal Data
and you are in the EEA, or if controlled by a Cayman Islands entity, you have
various rights under Data Protection Legislation in relation to the personal
information relating to you.  These include:

 * the right to request access to your personal information;
 * the right to have your personal information rectified;
 * the right to have your personal information erased in certain circumstances;
 * the right to request that your personal information is only used for
   restricted purposes;
 * (if the lawful basis for processing your personal information is the
   legitimate interest of a Fund / PAG) the right to object to your personal
   information being processed, for example, for marketing purposes;
 * (in some circumstances) the right to require certain of your personal
   information to be transferred to you or a third party; and
 * the right to lodge a complaint with the relevant data regulator in your
   jurisdiction.

You can seek to exercise any of these rights by contacting us at
compliance@pag.com.

Questions or complaints

If you have any questions or complaints regarding the processing of your
personal information, please contact us directly at compliance@pag.com.

Complaints regarding our processing of your personal information may also be
made directly to the relevant data protection regulator in your local
jurisdiction in the EU or to the Office of the Ombudsman in the Cayman Islands.

[1] Where those obligations derive from the laws of the European Union or the
member states of the European Economic Area or the Cayman Islands.

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