PRIVACY NOTICE

Dated as of March 2025

Overbrook Management Corporation (“We” or the “Company”) have adopted this policy with recognition that protecting the privacy and security of the personal information we obtain about our customers is an important responsibility. We also know that you expect us to service you in an accurate and efficient manner. To do so, we must collect and maintain certain personal information about you. This notice describes the types of non-public personal information we may collect about you, your right to opt out, the purposes for which we use the information, the circumstances in which we may share the information, and the steps that we take to safeguard the information to protect your privacy.   

What we do with your Personal Information

WHAT INFORMATION WE COLLECT

We collect certain nonpublic personal identifying information about you. This information can include: address, social security number, tax identification, account numbers, income, and information that you provide on applications or other forms as well as communications (electronic, telephone, written or in person) with you or your authorized representatives (such as your attorney, accountant, etc.).

We also collect information about your brokerage accounts and transactions (such as purchases, sales, account balances, inquiries, etc.).

WHAT INFORMATION WE USE AND SHARE

All financial companies need to share customers’ personal information to run their everyday business. We do not disclose the nonpublic personal information we collect about our customers to anyone except:

(i) in furtherance of the Company’s business relationship with them and then only to those persons necessary to effect the transactions and provide the services that they authorize (such as broker-dealers, custodians, third-party managers, etc.);

(ii) to your regulatory or persons assessing our compliance with industry standards (e.g., professional licensing authorities, etc.);

(iii) to firms that assist in servicing your account and have a need for such information, such as a broker, custodian, attorney, accountant, or auditor; or

(iv) as otherwise provided by law.

We are permitted by law to disclose nonpublic personal information about you to governmental agencies and other third parties in certain circumstances (such as third parties that perform administrative or marketing services on our behalf). These third parties are prohibited from using or share the information for any other purpose. If you decide at some point to either terminate our services or become an inactive customer, we will continue to adhere to our privacy policy, as may be amended from time to time.

Our policy is never to share, sell or distribute your phone number to any third party without your explicit consent, unless required by law.

HOW WE PROTECT YOUR INFORMATION

We restrict access to your nonpublic personal information to those employees who need to know that information to service your account. We maintain physical, electronic and procedural safeguards that comply with applicable federal or state standards to protect your nonpublic personal information.

CHANGES TO OUR PRIVACY POLICY 

The Company’s policy about obtaining and disclosing information may change from time to time. We will provide you notice of any material change to this policy before we implement the change.

OPT OUT RIGHT

Every client has the right to direct us to not disclose the nonpublic personal information about that client to a nonaffiliated third party. If a client would like to exercise its right to opt out of our privacy policy, each client must provide a written statement exercising that right. This right to opt out may be exercised at any time and will remain in effect until written notice revoking said right is received by us from the client.  However, in the event that we encounter circumstances where it is compelled by law to disclose the client’s non-public personal information, we must provide the client’s information even if the client has exercised its right to opt out.

QUESTIONS

If you have any questions concerning this privacy policy, please contact us at (212) 661-8170.

Please contact us at  investorrelations@overbrook.com or (212) 661-8170 pertaining to taking actions regarding opting out.