ExodusPoint Global Privacy Notice

Effective November 1, 2021

This Global Privacy Notice describes the policies and procedures followed by ExodusPoint Capital Management, LP or any of its affiliates (together, “ExodusPoint”, “we”, “our”, or “us”) regarding the collection, use, and disclosure of your personal information when you visit our website or otherwise interact with ExodusPoint. For the purposes of European and UK data protection laws, ExodusPoint is the data controller of your personal information. Please note that when using the website, this Global Privacy Notice should be read in conjunction with our Terms of Use and is incorporated into our Terms of Use.

If you are an individual investor in the United States, your privacy rights are described in our GLBA Notice.

Collection of Personal Information. When you visit the website, receive services from us or otherwise interact with ExodusPoint, we may collect and process the following data about you:




Use of your Personal Information. We may use the personal information you give us to carry out the following purposes:

Purpose

Lawful Basis

To contact you and to respond to your requests, inquiries and other communications

We have a legitimate interest to respond to your requests and inquiries for ongoing business administration

To deliver services to you

To manage and perform our contract with you

For employment recruitment purposes


We have a legitimate interest to consider an applicant for a role or vacancy in accordance with our employment recruitment process and contractual obligations and/or to take pre-contractual steps (such as background screening or vetting or reference checks)


For business administration, including statistical analysis

We have a legitimate interest to properly manage and administer our relationship with you and to ensure that we are as effective and efficient as we can be

To personalize your visit to the website and to assist you while you use the website

We have a legitimate interest to properly manage and administer our relationship with you and to ensure that we are as effective and efficient as we can be

To improve the website by helping us understand who uses the website

We have a legitimate interest to properly manage and administer our relationship with you and to ensure that we are as effective and efficient as we can be

In connection with corporate sales or other restructuring events

We have a legitimate interest to process your data in connection with the sale or reorganization of all or part of our business or its assets

For fraud prevention and detection and to comply with applicable laws, regulations or codes of practice including complying with any obligations derived from anti-money laundering and counter-terrorism legislation

To comply with our legal obligations and our legitimate interests


You have a right to object to the processing of your personal information where that processing is carried out for our legitimate interest; however, this right is not absolute and may be overridden where there is a compelling need for processing.

Sharing Your Personal Information. We may use selected third parties to provide us with services or technical support for the website who may have access to your personal information.





Rights of Individuals in Europe and the United Kingdom (and certain other jurisdictions). If you are in the European Economic Area or the United Kingdom (“UK”) you may have certain data privacy rights that may be subject to limitations and/or restrictions. These rights include the right to: (i) request access to and rectification and erasure of your personal information; (ii) obtain restriction of processing or to object to processing of your personal information and (iii) ask for a copy of your personal information be provided to you, or a third party in a digital format. You also have the right to lodge a complaint about the processing of your personal information with your local data protection authority. All your rights are subject to applicable exemptions and restrictions under applicable laws. For questions and to submit a rights requests, please contact us as described below under “Contact Us.”


California Privacy Rights. Under California law California residents are entitled to ask us for a notice describing which categories of personal customer information we share with third parties or corporate affiliates for those third parties or corporate affiliates’ direct marketing purposes. That notice will identify the categories of information shared and will include a list of the third parties and affiliates with which it was shared, along with their names and addresses. If you are a California resident and would like a copy of this notice, please submit a request to us via PRIVACY@EXODUSPOINT.COM. Please allow thirty (30) days for a response.

To the extent applicable, California law also provides California residents with the following rights with respect to their personal information:

When California residents exercise these rights and submit a request, ExodusPoint will verify their identity by asking them for information such as their email address, telephone number and/or information about their account with us. We will endeavor to honor requests unless such a request conflicts with certain lawful exemptions under California law, including where necessary to comply with other legal obligations. Please note that ExodusPoint is only required to honor such requests twice in a twelve (12) month-long period.

Exercise of these rights will have no adverse effect on the price and quality of our services to you.

For the twelve (12) month period prior to the date of this Privacy Notice, we have not sold any personal information; nor do we have any plans to do so in the future.

Japan Privacy Rights. When we are requested by you in accordance with procedures we have specified:

When we are requested by you to stop using your personal information on the basis that such information was collected improperly or is being used for purposes other than those specified without your consent, we will review the facts relating to such request without delay. If we find a valid reason for such request, we will cease the use of such personal information. We will receive and respond efficiently and appropriately to any inquiries and complaints concerning our handling of personal information. Please refer to the Contact Us section below. All your rights are subject to applicable exemptions and restrictions under applicable laws.

Hong Kong Privacy Rights. We will use and share your personal information with our affiliates for marketing purposes only after obtaining consent from you. If you do not want us to use or share information with our affiliates for marketing purposes, please contact us using the information below.

To the extent applicable law allows and subject to applicable exemptions and restrictions, you may request access to, and correction of, your personal information by contacting us using the information below.

Singapore Privacy Rights. When you visit the website, receive services from us or otherwise interact with ExodusPoint and voluntarily give your personal information, we will deem that you have given consent for us to collect and process such information in line with this Privacy Notice. If you wish to withdraw consent or notify us that you do not consent, please contact us using the information below. All your rights are subject to applicable exemptions and restrictions under applicable laws.

International Data Transfer—Consent.

Security. ExodusPoint maintains physical, electronic and procedural safeguards reasonably designed to protect your information against loss, misuse, damage or modification and unauthorized access or disclosure. ExodusPoint can make no guarantee that these procedures will prevent all unauthorized access, and as a result, personal information submitted through or contained on the website may be vulnerable to unauthorized disclosure to unknown third parties.

Data Quality, Storage and Access. While we endeavor to ensure that all information we hold about you is accurate, complete and up to date, you can help us in this regard by promptly notifying us if there are any changes to your personal information.

Retention. Notwithstanding anything herein to the contrary, ExodusPoint may retain your personal information as necessary for the provision of the services, for internal analytical purposes or to comply with its legal obligations, resolve disputes and enforce agreements. The criteria used to determine the retention periods include: (i) how long the personal data is needed to provide the services and operate the business; (ii) the type of personal data collected and (iii) whether we are subject to a legal, contractual or similar obligation to retain the data (e.g., mandatory data retention laws, government orders to preserve data relevant to an investigation or data that must be retained for the purposes of litigation or disputes).

Children’s Privacy. We do not collect or maintain information through our website from those whom we actually know are under the age of 18, and no part of our website is targeted to attract anyone under 18.

Cookies. The website may use “cookies,” which may automatically collect certain information and data. “Cookies” are small pieces of data sent to your computer browser from our web server and stored on your computer’s hard drive. The data identifies you as a unique user and facilitates your ongoing access to and use of the website. Cookies may also help us diagnose problems with our server and the website. If you do not want us to use cookies when you use the website, you can adjust your internet browser settings to not accept cookies. Your web browser’s help function should tell you how to do this. The cookies currently used are listed below but may be updated from time to time:

Revisions to this Privacy Notice. We may revise or supplement this Privacy Notice from time to time. If we make any substantial changes in the way we use or share your personal information, we will notify you by posting a notice on our website before the change becomes effective. We encourage you to refer to this Privacy Notice on an ongoing basis so that you understand our current privacy practices.

Contact Us. If you have any questions or comments about our Privacy Notice, or if you are located in California, Europe, Hong Kong, Japan, or Singapore and wish to exercise your rights as described above, please feel free to contact us at PRIVACY@EXODUSPOINT.COM.

6