Effective Date: June 6th, 2025

Last Updated: June 1st, 2025

Polygon Capital Management (“Company”, “we”, “us”, or “our”) is committed to protecting your privacy. This Privacy Policy describes how we collect, use, disclose, and safeguard your information when you visit our website or otherwise interact with us, including through any services we provide (collectively, the “Services”).

By using our Services, you consent to the practices described in this Privacy Policy. If you do not agree with the terms, please do not access or use our Services.

1. Information We Collect

We may collect the following categories of personal information:

A. Information You Provide to Us Directly

• Name, email address, phone number, and mailing address
• Employment and financial information (for clients or prospective clients)
• Account-related data, such as investment goals, risk tolerance, and portfolio information
• Any other personal information you provide via forms, emails, or other communication

B. Information We Collect Automatically

• IP address, browser type, operating system, and access times
• Usage data, such as pages visited, links clicked, and referring URLs
• Cookies and similar tracking technologies (see Section 6)

C. Information from Third Parties

• We may receive information from business partners, service providers, and public databases, subject to applicable legal requirements.

2. How We Use Your Information

We may use the information we collect for the following purposes:

• To provide and manage our Services
• To communicate with you, including responding to inquiries and sending updates
• To comply with legal and regulatory obligations
• To detect, prevent, or investigate fraud, security breaches, or other harmful activity
• To improve and customize the user experience
• For marketing and promotional purposes (where legally permitted)

3. Sharing of Information

We may share your personal information in the following circumstances:

• Service Providers: With vendors who assist us in operating our business (e.g., IT services, compliance support, custodians)
• Legal Compliance: When required by law, regulation, legal process, or governmental request
• Business Transfers: In connection with a merger, sale, or transfer of all or part of our business
• With Your Consent: In any other situation where you provide consent for sharing

We do not sell or rent your personal information to third parties for monetary consideration.

4. Data Security

We implement reasonable technical and organizational measures to protect your personal information from unauthorized access, use, or disclosure. However, no system can be completely secure, and we cannot guarantee the absolute security of your information.

5. Your Choices and Rights

Depending on your jurisdiction, you may have the right to:

• Access or correct your personal data
• Request deletion of your data
• Object to or restrict processing
• Withdraw consent, where processing is based on consent
• Lodge a complaint with a regulatory authority

To exercise any of these rights, please contact us using the information in Section 8.

6. Cookies and Tracking Technologies

We use cookies and similar technologies to collect usage data and enhance your experience on our website. You may disable cookies through your browser settings, though some features of the site may not function properly as a result.

7. Third-Party Links

Our Services may contain links to third-party websites or services. We are not responsible for the privacy practices or content of those third parties. We encourage you to read their privacy policies before providing them with your information.

8. Contact Us

If you have any questions about this Privacy Policy or our privacy practices, please contact us at:

Polygon Capital Management

1 West 72nd Street

New York City, NY, 10023

9. Changes to This Policy

We may update this Privacy Policy from time to time. When we do, we will revise the “Last Updated” date at the top. We encourage you to review this policy periodically to stay informed of how we are protecting your information.