Privacy Notice for California Residents

This California Consumer Privacy Act Notice (“CCPA Notice”) explains how Capula Investment US LP (“CIUS”) and its affiliated entities (collectively, “we,” “our”, or “us”) collect, use, and disclose personal information relating to California residents covered by the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively, the “CCPA”). This CCPA Notice constitutes our notice at collection and our privacy policy pursuant to the CCPA. Please see below for specific details on your rights under California law.

This notice applies to California residents who are investors, prospective investors, employees, contractors, directors, and website users.

This notice was last updated in February 2026.

Definitions of Terms Used in this Notice

“CCPA” means the California Consumer Privacy Act of 2018, Cal. Civil Code § 1798.100 et seq. and its implementing regulations.

“Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, device, or household. Anonymous, de-identified, or aggregate information is not Personal Information.

“Sensitive Personal Information” means personal information that reveals: (a) your Social Security or other state identification number; (b) a consumer’s account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; (c) a consumer’s geolocation; (d) a consumer’s racial or ethnic origin, religious or philosophical beliefs, or union membership; (e) the contents of a consumer’s mail, email, or text messages, unless the business is the intended recipient of the communication; and (f) a consumer’s genetic data. In addition, “sensitive personal information” includes processing of biometric information for purposes of identifying a consumer; personal information collected and analyzed concerning a consumer’s health, and personal information collected and analyzed concerning a consumer’s sex life or sexual orientation.

“Service Provider” has the same meaning as set forth in the CCPA, which in general means a for-profit legal entity to whom we disclose Personal Information for processing on our behalf for a “business purpose” (as defined in the CCPA) pursuant to a written contract.

“Special Categories Personal Information” has the same meaning as set forth in the European Union General Data Protection Regulation, which generally includes, subject to certain exceptions, personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation shall be prohibited.

“Third-Party Business” means any third party unaffiliated with us to whom we disclose Personal Information for their own purposes.

Categories of Your Personal Information that We May Acquire

We may collect, obtain or otherwise acquire the following types of Personal Information about you, and we may make and retain inferences drawn from such information:

The categories of sources from which we collected Personal Information are:

• Directly from you or your adviser in the context of your relationship with us;
• Service Providers, credit reporting agencies and other similar persons or entities;
• Public record sources;
• Information from our affiliates;
• Our website;

Use of Your Personal Information

Basis for Use of Your Personal Information

We collect and use for our business purposes Personal Information, including Sensitive Personal Information, relating to California resident users of our website and services, as well as directors and consultants to operate, manage, and maintain our business and to accomplish our business or commercial purposes, including the following:

• Administering payroll, benefits, pensions, expenses and other employment related payments and records;
• Managing recruitment, onboarding, workforce planning, performance management, training, career development and succession planning;
• Maintaining personnel records and internal reporting;
• Ensuring the security and integrity of our systems, premises and operations, where the use of Personal Information is reasonably necessary and proportionate for these purposes;
• Monitoring and maintaining the quality, safety and proper use of our systems, services and website and services;
• Conducting internal audits, investigations and research; and
• Complying with applicable laws and regulations, responding to legal process and meeting our regulatory and law enforcement obligations.

We may disclose Personal Information to the following categories of recipients for business purposes: service providers (such as payroll providers, recruitment agencies, and IT service providers), professional advisers (including legal, audit and tax advisers), affiliates, and regulators or authorities where required by law.

We use Sensitive Personal Information only for purposes permitted under applicable law, including to perform our services, manage our business operations, and comply with legal and regulatory obligations. We do not use Sensitive Personal Information for purposes that would require offering a right to limit its use under the CCPA.

Retention of Personal Information

The period we hold your Data for will vary. The retention period will be determined by the following criteria:

• the purpose for which we are using your Personal Information – we will need to keep the Personal Information for as long as is necessary for that purpose; and
• legal obligations – laws or regulation may set a minimum period for which we have to keep your Personal Information.

Categories of Personal Information We Disclose or Sell

We may share or disclose Personal Information for business purposes as described above, including to administrators, custodians, auditors, professional advisers and technology providers. We do not sell or share Personal Information for cross-context behavioral advertising.

Protection of Your Personal Information

Security Measures: We take reasonable security measures to protect against unauthorized access to, or unauthorized alteration, disclosure or destruction of, Personal Information.

No Liability for Breach: Since no security system is impenetrable, we cannot guarantee the security of your Personal Information. While we implement reasonable security measures, no system can be guaranteed to be completely secure.

Breach Notification: If we believe the security of your Personal Information in our possession or control may have been compromised, we may seek to notify you subject to applicable laws and regulations governing such notifications.

Retention: We will retain your Personal Information for as long as it is reasonably useful for commercial purposes. We will retain and use your Personal Information as necessary to comply with our legal obligations or data retention policies, resolve disputes and enforce our agreements.

Your Privacy Rights

Rights of California Residents: The CCPA grants residents of California certain rights with respect to their Personal Information.

California residents have the following rights under the CCPA:

• the right to know the ways in which we collect, use, share, disclose, and otherwise process your Personal Information;
• the right to know the categories of Personal Information we have collected about you;
• the right to know the categories of sources from which Personal Information is collected, sold or shared, and to whom;
• the right to know our business or commercial purpose for collecting, selling, or sharing your Personal Information;
• the right to know the categories of third parties to whom we disclose your Personal Information for business purposes;
• the right to request specific pieces of your Personal Information that we hold;
• the right to request the deletion of your Personal Information, subject to several exceptions;
• the right to opt out of the sale of your Personal Information;
• the right to request that we correct inaccurate Personal Information that we have about you;
• the right to request that we limit the use and disclosure of Sensitive Personal Information collected about you; and
• the right to not be unlawfully discriminated against for exercising these rights.

We will not discriminate against you for exercising your rights under the CCPA. We may take reasonable steps to verify your identity before fulfilling your request to know or delete. For example, we may seek to establish your identity by matching information that you submit alongside your request with information that we have on our records. We may also ask for supplemental information as needed to establish your identity.

Exercising Your Rights Under the CCPA: California resident users of our website and services or consultants, as well as authorized agents seeking to submit requests on behalf of California residents, may exercise the rights described below by contacting us at privacy@capulaglobal.com or by calling us at +1 (646) 874-5400.

You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our Service Providers to delete) your Personal Information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our Service Provider(s) to:

• Fulfil our employment, contractual, or business relationship with you, including administering payroll, benefits, compensation, tax reporting, workforce management, or other employment-related obligations.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug systems or processes to identify and repair errors that impair intended functionality.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et seq.).
• Enable internal uses that are reasonably aligned with your expectations based on your relationship with us.
• Comply with a legal obligation, including employment, tax, regulatory, recordkeeping, or litigation hold requirements.
• Establish, exercise, or defend legal claims.

Response Timing and Procedures:

We endeavour to respond to a verifiable request within 45 days of receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding receipt of the request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to a verifiable request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Changes to this CCPA Notice

We reserve the right to update and/or supplement this CCPA Notice at any time, and we will make an updated copy of such CCPA Notice available to you.