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WILSHIRE PRIVACY POLICY


Wilshire Advisors, LLC (“Wilshire”) and its affiliates and subsidiaries, have
adopted the following policy describing how third party and consumer information
is gathered by Wilshire and may be treated (Wilshire’s “Privacy Policy”).

Wilshire is a global company and conducts business around the world, including
within regions with unique rules that apply to the collection, processing, and
retention of Personal Information (as defined below) from individuals within
those areas. Appendices A, B and C include information regarding additional
rights, policies and procedures applicable to global data privacy laws,
including General Data Protection Regulation (“GDPR”, together with other EEA
data privacy laws “EEA Laws”), the California Consumer Privacy Act of 2018 and
the Cayman Islands Data Protection Law, 2017, respectively.


PRIVACY POLICY

Wilshire considers privacy to be a fundamental aspect of our relationships. We
are committed to maintaining the confidentiality, integrity, and security of
private, personal and confidential information in our possession. In the course
of providing our products and services, we may collect, retain, and use private,
personal and confidential information for the purpose of administering our
operations, and complying with legal and regulatory requirements. The kinds of
information we may collect will depend on the nature of the relationship in
which we are engaged and may include Personal Information (as defined below) for
all applicable global privacy laws. This information may include contact details
such as address, email address and telephone number and, where required for
contractual, legal or regulatory obligations, additional information (including,
but not limited to, date of birth, bank account details and tax identification
documents or numbers).

The term “Personal Information” as used in this Privacy Policy, and for purposes
of all global privacy laws, means any information that identifies, relates to,
describes, is reasonably capable of being associated, or could reasonably be
linked, directly or indirectly to an identified or identifiable natural person
(“Data Subject” or “ Consumer”); an identifiable natural person is one who can
be identified, directly or indirectly, in particular by reference to an
identifier such as a name, an identification number, location data, an online
identifier or to one or more factors specific to the physical, physiological,
genetic, mental, economic, cultural or social identity of that natural person.

In most cases, we collect information directly from the person or entity with
whom we have the relationship (e.g. through account applications, investment
policy statements, website usage, customer surveys, and electronic or verbal
correspondence); but may also obtain information from other sources (e.g.
transactions; brokers, consultants or financial advisory firms; or public
registers for background searches). Wilshire, generally, does not disclose
private, personal and confidential information with outside organizations except
for third party processors and service providers that are essential in
administering our operations, or as otherwise required or permitted by law. As
is common in the industry, non-affiliated companies may from time to time be
used to provide certain services, such as preparing and mailing prospectuses,
reports and account statements. These companies may be provided access to
private, personal and confidential information solely to provide the specific
service or as otherwise required or permitted by law. We may also provide
confidential information to brokerage, financial advisory, or other third party
financial intermediaries.

Wilshire reserves the right to disclose private, personal and confidential
information where we believe in good faith that disclosure is required either
under law or to cooperate with regulators or law enforcement authorities. In
addition, we may disclose Personal Information to a non-affiliated third party
upon the owner’s written request.

Wilshire takes seriously the obligation to safeguard private, personal and
confidential information (including Personal Information). We maintain
appropriate safeguards which includes the use of security procedures to prevent
revealing such information.

Any questions regarding Wilshire’s Privacy Policy should be referred to the
Chief Compliance Officer. As required by regulations, Wilshire will provide to
its clients annually a statement regarding their rights to privacy.


ABOUT WILSHIRE

Wilshire Associates Incorporated, a leading global independent investment
consulting and services firm, provides consulting services, analytics solutions
and customized investment products to plan sponsors, investment managers and
financial intermediaries. Its business units include Wilshire Analytics,
Wilshire Consulting, Wilshire Funds Management and Wilshire Private Markets.
Based in Santa Monica, California, Wilshire provides services to clients in more
than 20 countries representing more than 500 organizations. With ten offices
worldwide, Wilshire Associates and its affiliates are dedicated to providing
clients with the highest quality advice, products and services. For more
information please visit www.wilshire.com.

The information contained in this document is confidential or proprietary and is
intended for the exclusive use of the person(s) to whom it is provided. It may
not be modified or otherwise provided, in whole or in part, to any other person
or entity without prior written permission from Wilshire.

Wilshire reserves the right to update its Privacy Policy and the attached
Privacy Statements and Notices at any time and, in such cases, will make an
updated copy available to all relevant parties as required by relevant laws.





APPENDIX A

Privacy Policy Supplement for Data Subjects Whose Personal Information May Be
Collected in or from the European Economic Area

In accordance with applicable EEA Laws, Wilshire has adopted the following
additional policies and procedures for gathering and treating Personal Data,
further information can be found in the Privacy Notice for Data Subjects Whose
Personal Information May Be Collected in or from the European Economic Area.


GATHERING AND MAINTAINING ACCURATE INFORMATION

It is important that the Personal Data we hold is accurate and current. Wilshire
personnel must make reasonable efforts to obtain and maintain accurate records
for their relevant relationships. Wilshire may need to request specific
information from relevant individuals to confirm their identity.

It is in the sole discretion of the owner of Personal Data whether to share the
information with Wilshire. Reluctance to provide Wilshire with all or some of
the Personal Data requested by Wilshire, may restrict our ability to accept an
engagement from a client or prospect, provide all or some of services requested,
enter into a contract with a client or prospect or to send information about us
(e.g. marketing materials) to that client or prospect. If a client or prospect
refuses to provide the Personal Data requested, please contact Wilshire
Compliance.


USE OF PERSONAL DATA

Wilshire will only process Personal Data for specific purposes where there is a
lawful basis for doing so. The lawful basis, and purposes that we may rely on
include but are not limited to:

· We have received consent to do so (consent)

· In limited circumstances, we may obtain consent to send information about our
products and services but, in such instances we will also provide a means for
individuals to opt out of receiving further communications;

· It is required to perform a contract which we have executed with a third party
contract) – this includes, but is not limited to, where we have entered into an
agreement and the Personal Data is needed to ensure that the terms of the
contract can be fulfilled;

· It is necessary to comply with a legal obligation (legal obligation) – these
obligations include, for example, where we have a regulatory obligation to
conduct customer due diligence or are required to provide information to tax
authorities; or

· We (or a third party) having a legitimate interest which is not overridden by
the interests or fundamental rights and freedoms of the person from whom we have
obtained Personal Data (legitimate interest) – this includes the provision of
services by us and our direct marketing activities. To this end, we may use
Personal Data to deliver services to, complete work for or act on behalf of a
client. Furthermore, we may also use Personal Data to inform a client about us
and our services and to build a relationship with the client.

Where we use Personal Data to inform a client or prospect about us and our
services, we will ensure that these are targeted and proportionate.

We may use or disclose Personal Data if we are required by law to do so or if we
reasonably believe that use or disclosure is necessary to protect Wilshire’s
rights or to comply with judicial or regulatory proceedings, a court order or
other legal process.

Change of Purpose and Anonymization

Wilshire may only use Personal Data for the purposes for which we collect it,
unless we reasonably consider that we need to use it for another reason which is
compatible with the original purpose. If we need to use Personal Data for an
unrelated purpose, we must notify the individual and explain the legal basis
which allows us to do so.

In some circumstances, and where it is attributable to a lawful basis, we may
anonymize Personal Data so that it can no longer be associated with an
individual, in which case it is no longer Personal Data.


SHARING PERSONAL DATA

When using Personal Data for the purposes and on the legal basis described in
this Privacy Policy we may share Personal Data with other vendors that we work
with. Depending on the nature of the relationship (e.g. a client, an employee,
etc.) these other vendors may include, but are not limited to, accountants, tax
advisors, payroll agents, auditors, lawyers, regulatory advisors, insurance
brokers and IT providers. We may also have to share Personal Data with
regulators, public institutions, courts or other third parties. Wilshire may not
sell Personal Data nor may we distribute, disseminate or disclose Personal Data
to third party sales or marketing agencies. When sharing Personal Data with
others, Wilshire will ensure that we have an appropriate legal basis to do so
and will take all reasonable steps to ensure that Personal Data is treated in a
manner that is consistent with applicable laws and regulations relevant to data
protection and is not disclosed to any person who has no right to receive it.


STORAGE AND RETENTION OF PERSONAL DATA

Wilshire is a California corporation and the bulk of our critical operations are
based in the United States. For the purposes described above, Personal Data may
be stored outside of the European Economic Area (“EEA”). Wilshire must ensure
that there is a legal basis and take all reasonable steps to ensure relevant
safeguards are taken to secure such data transfer.

Wilshire may only retain Personal Data for as long as necessary to fulfil the
purposes for which it was collected, used and otherwise processed, including for
the purposes of satisfying any legal, regulatory, accounting or reporting
requirements.

To determine the appropriate retention period for Personal Data, Wilshire will
consider the amount, nature, and sensitivity of the Personal Data, the potential
risk of harm from unauthorized use or disclosure of Personal Data, the purposes
for which we process the Personal Data and whether we can achieve those purposes
through other means, and the applicable legal requirements.

Upon expiry of the applicable retention period Wilshire should take reasonable
efforts to securely destroy Personal Data in accordance with applicable laws and
regulations.


EEA RESIDENTS RIGHTS IN RELATION TO THEIR INFORMATION

Individual subject to EEA Laws have rights which they can exercise under certain
circumstances in relation to their Personal Data that we hold. These rights
include:

· Request access to their Personal Data (commonly known as a “data subject
access request”)

· Request certain information in relation to the processing of their Personal
Data;

· Request rectification of their Personal Data;

· Request the erasure of their Personal Data;

· Request restrictions regarding the of processing of their Personal Data; or

· Object to the processing of their Personal Data.

Some of the above rights may only be exercised in specific circumstances - they
are not absolute. EEA Residents may also have the right to make a complaint at
any time to the Information Commissioner’s Office (ICO), the UK supervisory
authority for data protection issues or, as the case may be, other competent
supervisory authority of an EU member state. Should a Wilshire employee become
aware of any such complaint being filed, they should contact Wilshire Compliance
immediately.


RIGHT TO WITHDRAW CONSENT

Owners of Personal Data may withdraw consent at any time where consent is the
lawful basis for processing such Personal Data. Should such withdrawal impede
our ability to comply with applicable laws and regulations, Wilshire may be
unable to provide further services to that client.


FEES

In general Wilshire will not charge a fee to exercise any of the individual
rights mentioned in this Privacy Policy. However, we may charge a reasonable fee
if a request to exercise an individual right is manifestly unfounded or
excessive. Wilshire may also refuse to comply with any request in such
circumstances.





Exhibit 1

Privacy Notice for Data Subjects Whose Personal Information May Be Collected in
or from the European Economic Area


The scope and purpose of this Privacy Notice

Wilshire Associates Incorporated (“we” or “Wilshire”) is a global company and
thus may conduct business and collect Personal Data (as defined below) from
individuals and institutions located within the European Economic Area (“EEA”).
This Privacy Notice explains how Wilshire uses Personal Data that we collect
from individuals and institutions located within the EEA in accordance with
applicable data privacy laws and the General Data Protection Regulation
(“GDPR”). Any capitalized terms or other terms not defined herein shall have the
meaning ascribed to them in the GDPR. To the extent of any conflict between this
Notice and the rest of our Privacy Policy, this Notice shall control only with
respect to EEA Individuals and their Personal Data, and to the extent of such
conflict.


DATA CONTROLLER

Wilshire typically acts as the controller of Personal Data collected regarding
EEA Individuals through the Websites or the Services we provide. This Notice
describes our general privacy and security practices in connection with your
Personal Data. For our contact information, see the section titled “Further
Information” below.


PERSONAL DATA

The term “Personal Data” as used in this Privacy Notice means any information
relating to an identified or identifiable natural person (“Data Subject”); an
identifiable natural person is one who can be identified, directly or
indirectly, in particular by reference to an identifier such as a name, an
identification number, location data, an online identifier or to one or more
factors specific to the physical, physiological, genetic, mental, economic,
cultural or social identity of that natural person.

What information do we collect about you, how do we collect it and what do we
use it for?

The kinds of Personal Data we may collect depends on the nature of the
relationship you have with us. This information may include your contact details
such as your address, email address and telephone number and, where required for
contractual, legal or regulatory obligations, additional information (including,
but not limited to your date of birth, bank account details and tax
identification documents or copies of identification documents). In most cases,
we will collect the Personal Data directly from you (e.g., through account
applications, investment policy statements and electronic or verbal
correspondence), but we may also obtain it from other sources (e.g. through
public registers for background searches).

In accordance with applicable data privacy laws and the GDPR, we will only
process your Personal Data for specific purposes where there is a lawful basis
for doing so. The lawful basis, and purposes that we may rely on are:

• You have consented to us doing so (consent) – in limited circumstances, we may
obtain your consent to send you information about our products and services
(but, in such cases, you can opt out of receiving such communications at any
time through the method provided in the communications themselves or by using
the contact information provided below);

• We need it to perform the contract we have entered into with you (contract) –
this includes, but is not limited to, where we have entered into an agreement
with you and the Personal Data is needed to ensure that the terms of the
contract can be fulfilled;

• We need it to comply with a legal obligation (legal obligation) – these
obligations include, for example, where we have a regulatory obligation to
conduct customer due diligence or are required to provide information to tax
authorities; or

• We (or a third party) have a legitimate interest which is not overridden by
your interests or fundamental rights and freedoms (legitimate interest) – this
includes the provision of services by us and our direct marketing activities. To
this end, we will use your Personal Data to deliver services to you and/or to
work or act for you. Furthermore, we will also use your Personal Data to inform
you about us and our services and to build our relationship with you.

Where we use your Personal Data to inform you about us and our services, we will
ensure that these are targeted and proportionate.

Please note that we may use or disclose Personal Data if we are required by law
to do so or if we reasonably believe that use or disclosure is necessary to
protect our rights and/or to comply with judicial or regulatory proceedings, a
court order or other legal process.

What might we need from you?

We may need to request specific information from you to help us confirm your
identity and ensure your right to access Personal Data (or to exercise any of
your other rights). This security measure is designed to ensure that Personal
Data is not disclosed to any person who has no right to receive it.

Accuracy of information

It is important that the Personal Data we hold about you is accurate and
current. Please let us know if your Personal Data changes during your
relationship with us.

What if you do not provide the personal data we request?

It is in your sole discretion to provide Personal Data to us. If you do not
provide us with all or some of the Personal Data we request, we may not be able
to accept an engagement from you, to provide all or some of our services, to
enter into a contract with you or to send you information about us (e.g.
marketing materials).

Change of purpose and anonymization

We will only use your Personal Data for the purposes for which we collected it,
unless we reasonably consider that we need to use it for another reason which is
compatible with the original purpose. If we need to use your Personal Data for
an unrelated purpose, we will notify you and we will explain the legal basis
which allows us to do so.

In some circumstances, and where it is attributable to a lawful basis, we may
anonymize your Personal Data so that it can no longer be associated with you, in
which case it is no longer Personal Data.

With whom will we share your information?

When using your Personal Data for the purposes and on the legal basis described
above we may share your Personal Data with vendors that we work with. Depending
on the nature of your relationship with Wilshire these other vendors may
include, but are not limited to, accountants, tax advisors, payroll agents,
auditors, lawyers, regulatory advisors, insurance brokers and IT providers. We
may also have to share your Personal Data with regulators, public institutions
or courts. Wilshire will not sell your Personal Data nor will we distribute,
disseminate or disclose your Personal Data to third party sales or marketing
agencies. When sharing your Personal Data with others, we will ensure that we
have an appropriate legal basis to do so and will take all reasonable steps to
ensure that your Personal Data is treated in a manner that is consistent with
applicable laws and regulations.

Will your information be stored outside of the EEA?

Wilshire is a California corporation and the bulk of our operations are based in
the United States. For the purposes described above, your Personal Data will
likely be stored outside of the European Economic Area (“EEA”). In such cases,
we will always ensure that there is a legal basis and a relevant safeguard
method for such data transfer.

We will only retain your Personal Data for as long as necessary to fulfil the
purposes for which it was collected, used and otherwise processed, including for
the purposes of satisfying any legal, regulatory, accounting or reporting
requirements. For retention of data, we abide by applicable law related to the
services we provide to you in the jurisdictions where we provide them.

Your rights in relation to your information

You have rights as an individual which you can exercise under certain
circumstances in relation to your Personal Data that we hold. These rights are
to:

 * Request access to your Personal Data (commonly known as a “data subject
   access request”) and request certain information in relation to its
   processing;
 * Request rectification of your Personal Data;
 * Request the erasure of your Personal Data;
 * Request the restriction of processing of your Personal Data;
 * Object to the processing of your Personal Data.

Please note, some of the above rights may only be exercised in specific
circumstances ‐ they are not absolute. In addition, you may also have the right
to make a complaint at any time to the Information Commissioner’s Office (ICO),
the UK supervisory authority for data protection issues or, as the case may be,
another competent supervisory authority of an EU member state.

Right to withdraw consent

You may withdraw consent at any time where consent is the lawful basis for
processing your Personal Data. Should you withdraw consent for processing or
otherwise object to processing that impedes our ability to comply with
applicable laws and regulations, you may be unable to avail yourself of the
services we provide.

How long will we retain your information?

We will only retain your Personal Data for as long as necessary to fulfil the
purposes for which it was collected and processed, including for the purposes of
satisfying any legal, regulatory, accounting or reporting requirements.

To determine the appropriate retention period for your Personal Data, we will
consider the amount, nature, and sensitivity of the Personal Data, the potential
risk of harm from unauthorized use or disclosure of your Personal Data, the
purposes for which we process your Personal Data and whether we can achieve
those purposes through other means, and the applicable legal requirements. If
you would like to know more information about our retention practices, please
contact us using the information provided below.

In some circumstances we may anonymize your Personal Data so that it can no
longer be associated with you, in which case it is no longer Personal Data. Upon
expiry of the applicable period we will destroy your Personal Data in accordance
with applicable laws and regulations.

Fees

You will in general not have to pay a fee to exercise any of your individual
rights mentioned in this Privacy Notice. However, we may charge a reasonable fee
if your request to exercise your individual rights is manifestly unfounded or
excessive. Alternatively, we may refuse to comply with the request in such
circumstances.

Changes to this Privacy Notice

Wilshire reserves the right to update this Privacy Notice at any time and, in
such cases, we will make an updated copy available on our website, or where
required by law, we will contact you directly.

Further information

If you have any queries, questions, concerns or require any further information
in relation to the Privacy Notice or you wish to exercise any of your rights,
please do not hesitate to contact Wilshire at: Privacy@Wilshire.com

Appendix B

Privacy Policy Supplement for US Clients

Wilshire Associates Incorporated (‘we’ or "Wilshire") values your trust and
wants you to be familiar with how we collect, use, and disclose information.
This Privacy Policy describes our practices in connection with information that
we may collect, maintain, and use in the course of providing our products and
services though our website(s).

Wilshire is committed to ensuring that your privacy is protected. Should we ask
you to provide certain information by which you can be identified when using
this website, you can be assured that it will only be used in accordance with
this Privacy Notice.

Residents of California should review the Privacy Notice for the California
Consumer Privacy Act of 2018 for additional disclosures.

Personal Information We May Collect

The term Personal Information as used in this policy means any information that
identifies you as an individual or relates to an identifiable person. The kinds
of Personal Information we may collect depends on the nature of the relationship
you have with us. This information may include your name, job title, and contact
details such as your address, email address and telephone number. Occasionally
additional information, such as demographic information, preferences, interests,
and other information relevant to customer surveys may also be collected.

How We May Collect Personal Information

In most cases, we collect information directly from the person or entity with
whom we have the relationship (e.g. through account applications, customer
surveys, or general website usage).

How We May Use Personal Information

We require and use this information to understand your needs and provide you
with a better service. More particularly, we use information we gather to do the
following:

 * Maintain internal records;
 * Improve our products and services;
 * Send promotional emails with information which we think you may find
   interesting using the email address which you have provided; and
 * Contact you by email, phone, fax or mail for market research purposes.

Security

We are committed to ensuring that your information is secure. In order to
prevent unauthorized access or disclosure we have put in place suitable
physical, electronic, and managerial procedures to safeguard and secure the
information we collect online.

Controlling Your Personal Information

We do not share your Personal Information with third parties for use in
marketing their products and services. However, we may share your Personal
Information in the following circumstances:

 * Where we have your permission to do so;
 * With unaffiliated service providers (for example, printing and mailing
   companies); and
 * With government agencies, other regulatory bodies or law enforcement
   officials.

Our service providers are obligated to keep the Personal Information we share
with them confidential and use it only to provide services specified by
Wilshire.

Retention Period

We will retain your Personal Information for the period necessary to fulfill the
purposes outlined in this Privacy Policy unless a longer retention period is
required or permitted by law.

Updates to This Privacy Policy

We may change this Privacy Policy. Any changes will become effective when we
post the revised Privacy Policy on our website. Your use of our website
following these changes means that you accept the revised Privacy Policy.

Contact Us

If you have any questions about this Privacy Policy, please contact Wilshire via
email at: Privacy@Wilshire.com




Exhibit 1

Privacy Notice for the California Consumer Privacy Act of 2018

Wilshire Associates Incorporated (“we” or “Wilshire”) is a global company which
conducts business and collects, uses, shares and otherwise processes Personal
Information (as defined below) from individuals and institutions located across
the world and is subject to applicable data privacy laws, including the
California Consumer Protection Act of 2019 (“CCPA”).

Personal Information

The term Personal Information as used in this policy means any information that
identifies, relates to, describes, is reasonably capable of being associated, or
could reasonably be linked, directly or indirectly with you as an individual or
household.

Personal Information We May Collect

The kinds of Personal Information we may collect, process, hold and share
depends on the nature of the product or service you have with us. This may
include your contact details (such as your address, email address and telephone
number), on-line identifiers or network activity (such as cookie data, website
usage, browsing history and other online identifiers) and, where required for
contractual, legal or regulatory obligations, additional information (including,
but not limited to, date of birth, bank account details, tax identification
numbers, copies of identification documents and numbers). In most cases, we will
collect the Personal Information directly from you but may also obtain it from
other sources (for example, public registers for background searches).

We may request specific information from you to help us confirm your identity.
It is important that the Personal Information we hold about you is accurate and
current. Please let us know if your Personal Information changes during your
relationship with us.

It is in your sole discretion to provide Personal Information to us. If you do
not provide us with all or some of the Personal Information we request, we may
not be able to accept an engagement from you, to provide all or some of our
services, to enter into a contract with you or to send you information about us
(e.g. marketing materials).

Categories of Personal Information

We collect and disclose the following Personal Information for our business
purposes, including:

• To perform the contract we have entered into with you (contract) – this
includes, but is not limited to, where we have entered into an agreement with
you and the Personal Data is needed to ensure that the terms of the contract can
be fulfilled;

• To comply with a legal obligation (legal obligation) – these obligations
include, for example, where we have a regulatory obligation to conduct customer
due diligence or are required to provide information to tax authorities; or

• Our legitimate business purposes (business purposes) – this includes the
provision of services by us and our direct marketing activities. To this end, we
will use your Personal Data to deliver services to you and/or to work or act for
you. Furthermore, we will also use your Personal Data to inform you about us and
our services and to build our relationship with you.


CATEGORIES OF PERSONAL INFORMATION

EXAMPLES


SOURCE OF PERSONAL INFORMATION



Identifiers
 * Name
 * Alias
 * Postal address
   
 * Online identifier
   
 * Internet Protocol address
   
 * E-mail address
   
 * Account name
   
 * Social security number
   
 * Driver’s license number, passport number or other similar identifiers.
   
 * Unique personal identifier
   

(i.e. – persistent identifier such as device identifier, cookies, beacons, pixel
tags, mobile ad identi­fiers or similar technology; customer number, unique
pseudonym or user alias; telephone numbers, or other forms of persistent or
probabilistic identifiers)
Websites, Account Applications, Investment Policy Statements, Verbal or Written
correspondence, or Services (information collected directly from user)

Other Sources (transactions, brokers, consultants, financial advisory firms,
public databases, or other third parties)
Legally Protected Characteristics

 * Gender
   
 * National origin
   

Websites, Account Applications, Investment Policy Statements, Verbal or Written
correspondence, or Services (information collected directly from user)

Other Sources (transactions, brokers, consultants, financial advisory firms,
public databases, or other third parties)
Commercial Purchasing Information

 * Products or services purchased, obtained, or considered
   
 * Other purchasing or consuming histories or tendencies
   

Websites, Account Applications, Investment Policy Statements, Verbal or Written
correspondence, or Services (information collected directly from user)

Other Sources (transactions, brokers, consultants, financial advisory firms,
public databases, or other third parties)
Financial Information (information described in CA Code §1798.80)

 * Bank account number
   
 * Credit card number
   
 * Debit card number
   
 * Other financial information
   
 * Credit Score
   

Websites, Account Applications, Investment Policy Statements, Verbal or Written
correspondence, or Services (information collected directly from user)

Other Sources (transactions, brokers, consultants, financial advisory firms,
public databases, or other third parties)


CHANGES TO THIS PRIVACY NOTICE

If, in the future, we intend to process your personal information for a purpose
other than that which it was collected, we will provide you with information on
that purpose and any other relevant information at a reasonable time prior to
such processing. After such time, the relevant information relating to such
processing activity will be revised or added appropriately (either within this
Privacy Policy or elsewhere).

Further information

If you have any queries, questions, concerns or require any further information
in relation to the Privacy Notice or you wish to exercise any of your rights,
please do not hesitate to contact us at: Privacy@Wilshire.com.




Appendix C

Data Protection Policy Supplement for Wilshire’s Cayman Islands Funds Subject to
the Cayman Islands Data Protection Law (the “Funds”)

1. Introduction AND PURPOSE

1.1 In the course of business, the Funds and their service providers obtain
personal information about investors and others. This information may come from
sources such as account applications and related forms, other written,
electronic or verbal correspondence, transactional documents, documents provided
by investors further to the anti-money laundering and other regulatory
requirements, and/or from information captured on websites.

1.2 As the Funds are incorporated or formed in the Cayman Islands, the Data
Protection Law, 2017 applies to the Funds' processing of this information to the
extent it constitutes Personal Data.

1.3 The purpose of this policy is to set out how we, and persons processing
Personal Data on our behalf, shall handle Personal Data, including that of our
investors, suppliers, and other relevant third parties. This policy covers
Personal Data held by us, and by third parties processing Personal Data on our
behalf, regardless of the media on which that data is stored.

1.4 The Funds are committed to the lawful processing of Personal Data, and to
upholding the confidentiality, integrity, and security of Personal Data.

1.5 This Policy applies to the Funds and shall be reviewed and updated as and
when required. It should be read in conjunction with the Cayman Islands Privacy
Notice (see Exhibit 1).

2. Definitions

2.1 "Service Provider" means U.S. Bancorp Fund Services;

2.2 "data controller" has the meaning given in the Data Protection Law, 2017;

2.3 "data subject" has the meaning given in the Data Protection Law, 2017;

2.4 "DPL" means the Data Protection Law, 2017 of the Cayman Islands;

2.5 "Funds" means Wilshire Asia Private Markets Fund VIII (Offshore) L.P.,
Wilshire European Private Markets Fund VIII (Offshore) L.P., Wilshire
Institutional Master Fund II SPC, Wilshire Institutional Master Fund SPC,
Wilshire Private Markets Japan Master Fund III, Ltd., Wilshire U.S. Private
Markets Fund VI (Offshore) L.P., and Wilshire European Private Markets Fund VIII
(Offshore) L.P. (each a "Fund");

2.6 "Manager" means Wilshire Associates Incorporated;

2.7 "Personal Data" has the meaning given in the DPL. Examples of Personal Data
include an individual's name, address, email address, date of birth, passport
details or other national identifier, driving licence number, national insurance
or social security number, income, employment information, tax identifier and
tax residence, account numbers, and economic information. It also includes data
which, when aggregated with other data, enables an individual to be identified,
such as an IP address and geolocation data;

2.8 "Processing" has the meaning given in the DPL. It is widely construed and
includes obtaining, recording and holding data, as well as carrying out any
operation on Personal Data, such as sharing, destroying and mining the Personal
Data; and

2.9 "we", "us" and "our" in this notice refer to the Funds.

3. The DPL, the role of the Funds and Service Providers

3.1 The Funds are the decision makers as to the purposes, conditions and manner
in which Personal Data are processed, and as such, are data controllers. This is
so even though the Funds have appointed Service Providers to carry out certain
processing operations in relation to Personal Data.

3.2 The Service Providers appointed on behalf of the Funds have confirmed in
writing that they shall only act in accordance with the instructions of the
Funds and that appropriate arrangements related to the security of any
processing undertaken by that Service Provider. Appropriate arrangements have
also been put in place for any cross border processing of personal data. A
summary of Service Provider agreements is included at clause 13 below.

3.3 The Funds may be data controllers jointly with another person where that
person is also a decision maker. As data controllers, whether joint or sole, the
Funds recognise we are responsible and accountable for compliance with the DPL.

3.4 The Wilshire Associates Incorporated Compliance Department (“Wilshire
Compliance”) is the relevant point of contact for any correspondence, issues or
queries related to the DPL. All escalations related to data breaches and or
subject access requests (as discussed below) shall be made to Wilshire at
Privacy@Wilshire.com.

4. Ombudsman

4.1 The Ombudsman is the supervisory authority of the Cayman Islands for
oversight of the DPL. The primary roles of the Ombudsman are to investigate,
mediate and make determinations on complaints made by data subjects. The
Ombudsman also provides guidance to data controllers and data subjects through
publishing information resources and template documentation.

4.2 The Ombudsman also has the power to impose monetary penalties under the DPL
for serious contraventions. Information orders and enforcement orders can also
be imposed.

4.3 In the case of a data breach as further described below, a report must be
made by the Funds to the Ombudsman. The Ombudsman's recommended form for breach
notification is included at Exhibit 2.

4.4 Wilshire Compliance is responsible for considering any notifications
received from staff or persons providing services to the Funds and determining
if a data breach notification is required to be made to the Ombudsman.

5. Data Protection Principles

5.1 Each Fund is committed to processing Personal Data in accordance with the
data protection principles set out in the DPL. The Funds require all persons
processing Personal Data on our behalf to adhere to these principles which are:

(a) First Principle: personal data shall be processed fairly, and only if at
least one of the conditions set out in paragraphs 1 to 6 of Schedule 2 of the
DPL is met. When the data is sensitive personal data (as defined), additional
conditions must be met.

(b) Second Principle: personal data shall only be obtained for one or more
specified lawful purposes, and shall not be further processed in any manner
incompatible with that purpose or those purposes

(c) Third Principle: personal data shall be adequate, relevant and not excessive
in relation to the purposes

(d) Fourth Principle: personal data shall be accurate and, where necessary, kept
up to date

(e) Fifth Principle: personal data processed for any purpose shall not be kept
for longer than is necessary for that purpose

(f) Sixth Principle: personal data shall be processed in accordance with the
rights of data subjects under the DPL.

(g) Seventh Principle: appropriate technical and organizational measures shall
be taken against unauthorised or unlawful processing of personal data and
against accidental loss or destruction of, or damage to, personal data

(h) Eighth Principle: personal data shall not be transferred to a country or
territory unless that country or territory ensures an adequate level of
protection for the rights and freedoms of data subjects in relation to the
processing of personal data

6. The rights of data subjects

6.1 The Funds recognise that individual data subjects have specific rights
conferred on them by the DPL, including:

(a) the right to be informed about the purposes for which the individual's
Personal Data are processed;

(b) the right to access the individual's Personal Data (known as a “subject
access request”). Where a request is received on or behalf of a data subject
pursuant to this right, it should be reported;

(c) the right to restrict the processing of the individual's Personal Data;

(d) the right to have incomplete or inaccurate Personal Data corrected;

(e) the right to ask the Funds to stop processing the individual's Personal
Data;

(f) the right to be informed of a Personal Data breach (unless the breach is
unlikely to be prejudicial);

(g) the right to complain to the Data Protection Ombudsman; and

(h) the right to require the deletion of the individual's Personal Data in some
limited circumstances.

6.2 As mentioned above at 6.1 b), individual data subjects have the right to
access their own personal data and receive information about its use. There are
some exemptions to this right. Such a request must be made in writing. However,
a request does not have to include the phrase 'subject access request' or refer
to the DPL, as long as it is clear that the individual is asking for their own
personal data. This may present a challenge as any staff could receive a valid
request.

6.3 A copy of the personal data must be provided within a 30 day deadline. An
individual is only entitled to their own personal data and certain information
about the data, but not to information relating to other people (unless the
information is also about them or they are acting on behalf of someone else).
Therefore, it is important to vet and potentially redact the information
provided. No fee can be imposed for providing a copy of the personal data,
except in exceptional circumstances. Details of subject access requests received
should be recorded. Cayman counsel can advise further if required.

6.4 In relation to the above rights, the Funds:

(a) have disclosed the purposes for processing individuals' Personal Data in the
Funds' data protection notice;

(b) will act on a legitimate request from a data subject promptly; and

(c) will disclose breaches in accordance with the DPL.

7. Lawfulness, fairness and transparency

7.1 The Funds recognise that Personal Data must be processed lawfully, fairly
and in a manner that is transparent to the individual whose Personal Data is
being processed. We also recognise that Personal Data may only be processed for
specified and legitimate purposes and not further processed in a manner that is
incompatible with those purposes.

7.2 The basis for the Funds' processing of Personal Data, including the purposes
for which Personal Data are processed and the persons with whom Personal Data
are shared, are disclosed in a data protection notice issued to investors. In
summary, each Fund processes Personal Data: where it is necessary to perform
contracts to which the data subjects are party or in the interests of the data
subjects; where the processing is necessary for compliance with an applicable
legal or regulatory obligation to which the Funds are subject; and for the
Funds' legitimate interests, or those of a third party.

7.3 The Funds only rely on these legitimate interests where it is considered
that, on balance, the Funds' legitimate interests are not overridden by data
subjects' interests, fundamental rights or freedoms.

7.4 The Funds prohibit any processing for purposes not already disclosed in the
notice unless the purpose is obvious. The Funds also prohibit disclosure to
third parties not already specified in the notice unless such disclosure would
be lawful. The Funds do not buy or sell Personal Data or otherwise seek to
monetise it, and require those acting on our behalf to act accordingly.

8. Purpose limitation, data minimisation and accuracy

8.1 The Funds require that Personal Data be adequate, relevant and limited to
what is necessary in relation to the purposes for which it is processed.
Irrelevant or unnecessary data must not be collected and, if collected, it must
be deleted without delay.

8.2 The Funds also require that Personal Data be accurate and, where necessary,
kept up to date. Any inaccurate Personal Data must be erased or rectified
without delay.

8.3 Personal Data must be kept in a form which permits identification of data
subjects for no longer than is necessary for the purposes for which the Personal
Data is processed. If there is no longer any legal, regulatory or legitimate
business purpose to keep Personal Data, the Funds require that the data be
erased or anonymised.

9. Storage limitation

9.1 The Funds keep Personal Data for as long as the Funds require it for
legitimate business purposes, to perform contractual obligations, or such longer
period as is required by law or regulation. The Funds will generally retain
Personal Data relating to investors throughout the life cycle of any investment.
Some Personal Data will be retained after an investor relationship ends.

9.2 As a general principle, the Funds do not retain Personal Data for longer
than necessary. The Funds will usually delete Personal Data (at the latest)
after an investor relationship ceases and there is no longer any legal or
regulatory requirement or business purpose for retaining Personal Data.

10. Security, integrity and confidentiality

10.1 The Funds take seriously the obligation that Personal Data be processed in
a manner that ensures the security of the Personal Data. This is particularly
the case given the data includes financial information, and evidence of
identity. The Funds recognise that protection against unauthorised or unlawful
processing and against accidental loss, destruction or damage is critical.

10.2 Taking into account the state of the art, the costs of implementation and
the nature, scope, context and purposes of processing, as well as the rights and
freedoms of individuals, each Fund implements appropriate technical and
organisational measures to ensure a level of security appropriate to the risk,
and requires those processing Personal Data on its behalf to do so.

11. Breach/INTERNAL COMMUNICATION AND CORRESPONDENCE WITH THE OMBUDSMAN

11.1 The Funds, and those processing Personal Data on the Funds' behalf, must
have effective measures in place to enable the detection, investigation, and
(where appropriate) timely reporting by the Funds to the Ombudsman (and impacted
individuals) of Personal Data breaches.

11.2 If there is a Personal Data breach, the Funds will, without undue delay
and, in any event, not later than 5 days after having become aware, notify the
personal Data Breach to the Ombudsman and the impacted individuals. As also set
out above the Ombudsman's recommended form for breach notification is included
at Exhibit 2.

11.3 Wilshire Compliance on behalf of the Funds will also specify in such notice
the measures taken in light of the breach, and those which individuals are
recommended to take. The Funds will only refrain from reporting where the
Personal Data breach is unlikely to result in a risk to the rights and freedoms
of natural persons.

11.4 The Funds, and those processing Personal Data on the Funds' behalf, shall
document any Personal Data breaches, setting out the facts relating to the
Personal Data breach, its effects and the remedial action taken. Given that
trust is of paramount importance to the Funds' business, it is critical that the
breach be appropriately investigated and reported without delay.

11.5 Staff and those associated with the Funds should make breach notifications
as soon as possible after becoming aware of them to Wilshire Compliance.

11.6 Wilshire Compliance is responsible for considering any notifications and
making any breach notifications to the Ombudsman.

11.7 Failing to notify a breach when required to do so is an offence under the
DPL and can result in a conviction and a fine of up to one hundred thousand
dollars. Failing to notify may also be subject to a monetary penalty imposed by
the Ombudsman.

11.8 As with any security incident, Funds should investigate whether the breach
was a result of human error or a systemic issue and see how a recurrence can be
prevented – whether this is through better processes, further training or other
corrective steps. Cayman counsel can advise further on data breaches if required

12. Cross-border transfer

12.1 The DPL requires specific measures to be taken where there is any transfer
of Personal Data to jurisdictions which do not have a level of data protection
comparable to that of the Cayman Islands. The Funds commit to transferring
Personal Data to such jurisdictions only where they are satisfied that specific
measures have been taken to ensure an adequate level of protection for data
subjects and their Personal Data.

12.2 In particular, the Funds will require any such data transfers be performed
pursuant to appropriate contractual terms. These provisions are addressed in
agreements with Service Providers. The Funds will reserve the right to audit the
measures put in place by the transferee so as to ensure an adequate degree of
protection for data subjects and any Personal Data transferred.

13. Service PRovider Agreements

Service Provider

Agreement

U.S. Bancorp Fund Services

Amended and Restated Administration Agreement

Exhibit 1


CAYMAN ISLANDS PRIVACY NOTICE

Each of Wilshire Asia Private Markets Fund VIII (Offshore) L.P., Wilshire
European Private Markets Fund VIII (Offshore) L.P., Wilshire Institutional
Master Fund II SPC, Wilshire Institutional Master Fund SPC, Wilshire Private
Markets Japan Master Fund III, Ltd., Wilshire U.S. Private Markets Fund VI
(Offshore) L.P., and Wilshire European Private Markets Fund VIII (Offshore) L.P.
(each, the “Fund”) is a fund created under the laws of the Cayman Islands. The
purpose of this document is to provide you with information on the Fund's use of
your personal data in accordance with the Cayman Islands Data Protection Law,
2017 (the " Data Protection Legislation").

If you are an individual investor, this will affect you directly. If you are an
institutional investor that provides us with personal data on individuals
connected to you for any reason in relation to your investment with us, this
will be relevant for those individuals and you should transmit this document to
such individuals or otherwise advise them of its content.

Your personal data will be processed by the Fund, and by persons engaged by the
Fund. Under the Data Protection Legislation, you have rights, and the Fund has
obligations, with respect to your personal data. The purpose of this notice is
to explain how and why the Fund, and persons engaged by the Fund, will use,
store, share and otherwise process your personal data. This notice also sets out
your rights under the Data Protection Legislation, and how you may exercise
them.

Your personal data

By virtue of making an investment in the Fund (including the initial application
and ongoing interactions with the Fund and persons engaged by the Fund) or by
virtue of you otherwise providing us with personal information on individuals
connected with you as an investor (for example directors, trustees, employees,
representatives, shareholders, investors, clients, beneficial owners or agents),
you will provide us with certain personal information which constitutes personal
data within the meaning of the Data Protection Legislation.

In particular, you will provide us with personal information within the forms
and any associated documentation that you complete when subscribing for shares;
when you provide it to us or our service providers in correspondence and
conversations (including by email); when you make transactions with respect to
the Fund; and when you provide remittance instructions.

We may also obtain personal data on you from other public accessible directories
and sources. These may include websites; bankruptcy registers; tax authorities;
governmental agencies and departments, and regulatory authorities, to whom we
have regulatory obligations; credit reference agencies; sanctions screening
databases; and fraud prevention and detection agencies and organizations,
including law enforcement.

This includes information relating to you and/or any individuals connected with
you as an investor in the Fund such as: name, residential address, email
address, contact details, corporate contact information, signature, nationality,
place of birth, date of birth, tax identification, credit history,
correspondence records, passport number, bank account details, source of funds
details and details relating to your investment activity.

How the Fund may use your personal data

The Fund, as the data controller, may collect, store and use your personal data
for purposes including the following.

The processing is necessary for the performance of a contract, including:

 * administering or managing the Fund;
 * processing your subscription and investment in the Fund, such as entering
   your information in the register of shareholders;
 * sending you statements relating to your investment;
 * facilitating the continuation or termination of the contractual relationship
   between you and the Fund; and
 * facilitating the transfer of funds, and administering and facilitating any
   other transaction, between you and one or more of the Fund.

The processing is necessary for compliance with applicable legal or regulatory
obligations, including:

 * undertaking investor due diligence including anti-money laundering and
   counter-terrorist financing checks, including verifying the identity and
   addresses of our investors (and, where applicable, their beneficial owners);
 * sanctions screening and complying with applicable sanctions and embargo
   legislation;
 * complying with requests from regulatory, governmental, tax and law
   enforcement authorities;
 * surveillance and investigation activities;
 * carrying out audit checks, and instructing our auditors;
 * maintaining statutory registers; and
 * preventing and detecting fraud.

In pursuance of our legitimate interests, or those of a third party to whom your
personal data are disclosed, including:

 * complying with a legal, tax, accounting or regulatory obligation to which we
   or the third party are subject;
 * assessing and processing requests you make;
 * sending updates, information and notices or otherwise corresponding with you
   in connection with your investment in the Fund;
 * investigating any complaints, or pursuing or defending any claims,
   proceedings or disputes;
 * providing you with, and informing you about investment products and services;
 * managing our risk and operations;
 * complying with audit requirements;
 * ensuring internal compliance with our policies and procedures;
 * protecting the Fund against fraud, breach of confidence or theft of
   proprietary materials;
 * seeking professional advice, including legal advice;
 * facilitating business asset transactions involving the Fund or related
   entities;
 * monitoring communications to/from us (where permitted by law); and
 * protecting the security and integrity of our IT systems.

We will only process your personal data in pursuance of our legitimate interests
where we have considered that the processing is necessary and, on balance, our
legitimate interests are not overridden by your legitimate interests, rights or
freedoms.

The Fund continues to be a data controller even though it has engaged the
service providers (the " Service Provider") and other third parties to perform
certain activities on the Fund's behalf.

Sharing your personal data

We may share your personal data with our affiliates and delegates. In certain
circumstances we may be legally obliged to share your personal data and other
financial information with respect to your interest in the Fund with relevant
regulatory authorities such as the Cayman Islands Monetary Authority or the Tax
Information Authority. They, in turn, may exchange this information with foreign
authorities, including tax authorities and other applicable regulatory
authorities.

The Fund’s affiliates and delegates may process your personal data on the Fund’s
behalf, including with our banks, accountants, auditors and lawyers which may be
data controllers in their own right. The Fund's services providers, such as the
Service Provider, are generally processors acting on the instructions of the
Fund. Additionally, a service provider may use your personal data where this is
necessary for compliance with a legal obligation to which it is directly subject
(for example, to comply with applicable law in the area of anti-money laundering
and counter terrorist financing or where mandated by a court order or regulatory
sanction). The service provider, in respect of this specific use of personal
data, acts as a data controller.

In exceptional circumstances, we will share your Personal Data with regulatory,
prosecuting and other governmental agencies or departments, and parties to
litigation (whether pending or threatened) in any country or territory.

Sending your personal data internationally

Due to the international nature of our business, your personal data may be
transferred to jurisdictions that do not offer equivalent protection of personal
data as under the Data Protection Legislation. In such cases, we will process
personal data or procure that it be processed in accordance with the
requirements of the Data Protection Legislation, which may include having
appropriate contractual undertakings in legal agreements with service providers
who process personal data on our behalf.

Retention and deletion of your personal data

We will keep your personal data for as long as it is required by us. For
example, we may require it for our legitimate business purposes, to perform our
contractual obligations, or where law or regulation obliges us to. We will
generally retain your personal data throughout the lifecycle of the investment
you are involved in. Some personal data will be retained after your relationship
with us ends. We expect to delete your personal data (at the latest) once there
is no longer any legal or regulatory requirement or legitimate business purpose
for retaining your personal data.

Automated decision-making

We will not make decisions producing legal effects concerning you, or otherwise
significantly affecting you, based solely on automated processing of your
personal data, unless we have considered the proposed processing in a particular
case and concluded in writing that it meets the applicable requirements under
the Data Protection Legislation.

Your rights

You have certain data protection rights, including the right to:

 * be informed about the purposes for which your personal data are processed;
 * access your personal data;
 * stop direct marketing;
 * restrict the processing of your personal data;
 * have incomplete or inaccurate personal data corrected;
 * ask us to stop processing your personal data;
 * be informed of a personal data breach (unless the breach is unlikely to be
   prejudicial to you);
 * complain to the Data Protection Ombudsman; and
 * require us to delete your personal data in some limited circumstances.

Contact us

We are committed to processing your personal data lawfully and to respecting
your data protection rights. Please contact us if you have any questions about
this notice or the personal data we hold about you. Our contact details are: c/o
Wilshire Associates Incorporated, 1299 Ocean Avenue, Suite 700, Santa Monica, CA
90401, U.S.A., Email: Privacy@Wilshire.com marking your communication "Cayman
Fund Data Protection Enquiry".




Exhibit 2

Please complete this form to the extent possible when notifying a personal data
breach to the Office of the Ombudsman.

Please submit the completed form to: info@ombudsman.ky

Description

Answer

1.

Name and registered address of the reporting organization

2.

Nature of the incident

2.1.

Categories of data subjects concerned

2.2.

Types of personal data concerned

2.3.

Approximate number of data subjects concerned

2.4.

Approximate number of personal data records concerned

2.5.

Date and time the incident occurred

2.6.

Date and time the incident was first noticed

2.7.

Duration of the incident

2.8.

Location of the incident

2.9.

How the incident was discovered

3.

Name and contact details for communication purposes regarding the incident

3.1.

If the breach occurred at a data processor: Name and contact details of contact
point at the data processor

4.

Likely consequence of the incident for the data subjects

5.

Measures taken to address the breach and/or mitigate its effect

6.

Measures proposed to address the breach and/or mitigate its effect


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