FACTS

WHAT DOES SOVIERO ASSET MANAGEMENT, LP (THE “INVESTMENT MANAGER”) DO WITH YOUR PERSONAL INFORMATION?

Why?

Financial companies choose how they share your personal information.  Federal law gives consumers 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.

What?

The types of personal information we collect and share depend on the product or service you have with us.  This information can include:

•      Social Security number                   •     Income

•      Account balances                              •     Investment experience

•      Transaction history                          •     Wire Transfer Instructions

•      Name, address and any other additional information disclosed to us in a Subscription Agreement

When you are no longer our customer, we continue to share your information as described in this notice.

How?

All financial companies need to share customers’ personal information to run their everyday business.  In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons the Investment Manager chooses to share; and whether you can limit this sharing.

Reasons we can share your personal information

Does the Investment Manager share?

Can you limit this sharing?

For our everyday business purposes—

such as to process your transactions, maintain
your account(s) or respond to court orders and legal investigations

Yes

No

For our everyday business purposes—

to report to credit bureaus

No

We don’t share

For our marketing purposes—

to offer our products and services to you

No

We don’t share

For joint marketing with other financial companies

No

We don’t share

For our affiliates’ everyday business purposes— information about your transactions and experiences

Yes

No

For our affiliates’ everyday business purposes— information about your creditworthiness

No

We don’t share

For nonaffiliates to market to you

No

We don’t share

Questions?

Call the Investment Manager’s Chief Operating Officer at 212-324-1431.

Who we are

Who is providing this notice?

The Investment Manager

What we do

How does the Investment Manager protect my 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.

How does the Investment Manager collect my personal information?

We collect your personal information, for example, when you

•     Open an account

•     Give us your income information

•     Give us your contact information

•     Make deposits or withdrawals from your account

•     Fill out and return a Subscription Agreement

Why can’t I limit all sharing?

Federal law gives you the right to limit only

§      sharing for affiliates’ everyday business purposes—information about your creditworthiness

§      affiliates from using your information to market to you

§      sharing for nonaffiliates to market to you

State laws and individual companies may give you additional rights to limit sharing.

Definitions

Affiliates

Companies related by common ownership or control.  They can be financial and nonfinancial companies.

§ The Investment Manager and Soviero Advisors, LLC are affiliated financial companies.

§ The Investment Manager is the investment manager of Soviero Partners, LP, Soviero Offshore Fund, Ltd. and Soviero Master Fund, LP.

§ Soviero Advisors, LLC is the general partner of Soviero Partners, LP and Soviero Master Fund, LP.

Nonaffiliates

Companies not related by common ownership or control.  They can be financial and nonfinancial companies.

§    The Investment Manager does not share with nonaffiliates so that they can market to you.

Joint marketing

A formal agreement between nonaffiliated financial companies that together market financial products or services to you.

§    The Investment Manager does not jointly market.

Other important information

As described above, we may disclose information we collect from you in connection with our everyday business purposes.  Examples of our everyday business purposes include but are not limited to: account opening with a broker or custodian, processing transactions, auditing purposes and responding to, or making filings with, any regulatory authorities, court orders or legal investigations.