CASDIN CAPITAL, LLC
PRIVACY NOTICE

Introduction

Your privacy is very important to us. This notice (this “Privacy Notice”) is provided by Casdin Capital, LLC (collectively with its affiliates, “Casdin Capital,” “we” or “us”), and sets forth our policies for the collection, use, storage, sharing, disclosure (collectively, “processing”) and protection of personal data of individuals who disclose such information to us, including current, prospective and former investors with Casdin Capital. References to “you” or an “investor” in this Privacy Notice mean any individual who discloses personal data to us, including an investor who is an individual and any individual connected with an investor who is a legal person, as applicable.

Who to Contact About This Privacy Notice

This Privacy Notice is being provided in accordance with the applicable requirements under the privacy and data protection laws that apply in the jurisdictions where we operate (collectively, the “Data Protection Laws”). Casdin Capital and its affiliates are considered to be data controllers in respect of any personal information we hold about you for the purposes of certain Data Protection Laws. This means that Casdin Capital determines the purposes and the means of the processing of your personal information.

Please contact us at Randy@casdincapital.com, or 212-554-4966 or by writing to the following address: 1350 Avenue of the Americas, 26th Floor, New York NY 10019 with any questions about this Privacy Notice or requests with regards to the personal data we hold.

Please note that Casdin Capital’s service providers work under a range of professional and legal obligations that require them to process personal data (e.g., anti-money laundering legislation). In order to meet the requirements of such obligations, they, from time to time, would not be acting on our instructions but instead in accordance with their own respective professional or legal obligations and therefore as data controllers in their own right with respect to such processing. For more specific information or requests in relation to the processing of personal data by Casdin Capital’s service providers, you may also contact the relevant service provider directly at the address specified in materials provided to you by Casdin Capital or by visiting their websites.

The Types of Personal Data We May Hold

The categories of personal data we may collect include names, residential or business addresses, or other contact details, signature, nationality, tax identification or passport number, date of birth, place of birth, photographs, copies of identification documents, bank account details, information about assets or net worth, credit history, information on investment activities, or other personal information, such as certain special categories of personal data (including, where relevant, information on political affiliations, ethnic origin, or criminal convictions), as specified under the applicable Data Protection Laws, that may be contained in the relevant materials, documents, or obtained through background searches.

How We Collect Personal Data

We may collect personal data about you through: (i) information provided directly to us by you, or another person on your behalf; or (ii) information that we obtain in relation to any transactions between you and us.

We also may receive your personal information from third parties or other sources, such as our affiliates, our service providers, publicly accessible databases or registers, tax authorities, governmental agencies and supervisory authorities, credit agencies, fraud prevention and detection agencies, or other publicly accessible sources, such as the Internet.

How We May Use Personal Information

We may use the personal information we collect for one or more of the following purposes:

• Providing you with information about our products and services;
• Administering the relationship between you and us (including subscription acceptance, communications and providing performance and other reporting);
• One or more of the following business purposes:
  • Performing services (for us or our service provider) such as account servicing, processing orders and payments, and analytics;
  • Legal compliance (including anti-money laundering, fraud prevention, tax reporting, sanctions compliance, or responding to requests for information from supervisory authorities, or law enforcement agencies);
  • Detecting and protecting against security incidents, fraud, and illegal activity;
  • Debugging;
  • Internal research for technological improvement;
  • Internal operations;
  • Activities to maintain and improve our services; and
  • Short-term, transient use, provided that the personal information is not disclosed to another third party and is not used to build a profile about a consumer.
• For our employees and contractors, in connection with your roles and responsibilities:
  • Providing you with services and tools to use in connection with your employment or engagement, such as email service and information technologies;
  • Responding to your requests;
  • Maintaining compliance with our policies and procedures;
  • Paying you and administering your employment benefits (if applicable), including those provided to other individuals like family members;
  • Conducting background searches; and
  • Responding to emergencies or safety concerns, such as by maintaining and using your emergency contact information or travel information.
• For our job applicants, to process, evaluate and communicate with you about your application, including to check references or your background, and communicate with you about other jobs that may interest you.

We will use one of the permitted grounds under the applicable Data Protection Laws to process your personal information. Such grounds include, for example, circumstances where:

• processing is necessary to perform our obligations in connection with operating our business;
• we are required to comply with a legal or regulatory obligation applicable to us; or
• we, or a third party on our behalf, have determined that it is necessary for our legitimate interests to collect and use your personal information, such as if we believe that you have a reasonable expectation for us or a third party to collect or use your personal information for such purpose.

What Are The Consequences Of Failing To Provide Personal Information

Where personal data is required to satisfy a statutory obligation (including compliance with applicable anti-money laundering or sanctions requirements) or a contractual requirement, failure to provide such information may result in us refusing to engage in transactions with you or to continue to do business with you. Where there is suspicion of unlawful activity, failure to provide personal data may result in the submission of a report to the relevant law enforcement agency or supervisory authority.

How We May Share Personal Data

We may disclose information about you to our affiliates, service providers, or other third parties to accept your subscription, administer and maintain your account(s), or otherwise perform our contractual obligations. We may also need to share your personal information with regulatory, tax or law enforcement authorities to comply with applicable legal or regulatory requirements, respond to court orders, or in the context of regulatory requests for information, administrative proceedings, or investigations. We will also release information about you if you direct us to do so.

It may also be necessary, under anti-money laundering and similar laws, to disclose information about you to facilitate the establishment of trading relationships with executing brokers or other trading counterparties.

We may also disclose information about you, or your transactions and experiences with us, to our affiliates or service providers for our everyday business purposes, such as administration of our business, record-keeping, maintaining security of our information technology systems, reporting and monitoring of our activities, investor relations activities, and compliance with applicable legal and regulatory requirements. The service providers we provide personal information to include, but are not limited to: administrators, brokers, auditors, law firms and consultants. SMS opt-in and phone numbers for the purpose of SMS will not be shared with third parties and affiliates for marketing purposes. We also may disclose your information in connection with a potential business transfer.

Retention Periods and Security Measures

We will not retain personal data for longer than is necessary in relation to the purpose for which it is collected, subject to the applicable Data Protection Laws. Personal data will be retained for the duration of your relationship with us and for a minimum of five years after the termination of such relationship. We may retain personal data for a longer period for the purpose of marketing our products and services or compliance with applicable law. From time to time, we will review the purpose for which personal data has been collected and decide whether to retain it or to delete if it no longer serves any purpose to us.

To protect your personal information from unauthorized access and use, we apply organizational and technical security measures in accordance with applicable Data Protection Laws. These measures include computer safeguards and secured files and buildings.

We will notify you of any material personal data breaches affecting you in accordance with the requirements of applicable Data Protection Laws.

Additional Information under the U.S. Gramm-Leach-Bliley Act 1999 (Reg S-P) and Fair Credit Reporting Act (Reg S-AM)

For purposes of U.S. federal law, this Privacy Notice applies to current and former investors who are individuals or Individual Retirement Accounts. We are providing this additional information under U.S. federal law.

We may disclose information about our investors, prospective investors or former investors to affiliates (i.e., financial and non-financial companies related by common ownership or control) or non-affiliates (i.e., financial or non-financial companies not related by common ownership or control) for our everyday business purposes, such as to process your transactions, maintain your account(s) or respond to court orders and legal investigations. Thus, it may be necessary or appropriate, under anti-money laundering and similar laws, to disclose information about our investors in order to accept subscriptions from them. We will also release information about you if you direct us to do so.

We may share your information with our affiliates for direct marketing purposes, such as offers of products and services to you by us or our affiliates. You may prevent this type of sharing by calling us at 212-554-4962. If you are a new investor, we can begin sharing your information with our affiliates for direct marketing purposes 30 days from the date we sent this Privacy Notice. When you are no longer our investor, we may continue to share your information with our affiliates for such purposes.

You may contact us at any time to limit our sharing of your personal information. If you limit sharing for an account you hold jointly with someone else, your choices will apply to everyone on your account. U.S. state laws may give you additional rights to limit sharing.

NOTICE FOR CALIFORNIA RESIDENTS

Last updated: January 11, 2022

This notice contains disclosures required by the California Consumer Privacy Act (“CCPA”), is only relevant to residents of California, and applies only to the collection or other use of “personal information” that is subject to the CCPA. Consumers with disabilities may access this notice in a alternative format by contacting Randy@casdincapital.com, or by calling 212-554-4966.

Information We Collect

In the past 12 months, we have collected the following categories of personal information about California consumers:

We collect personal information from the following categories of sources:

• Your communications with us;
• Service providers, including, but not limited to: administrators, brokers, auditors, law firms and consultants;
• Affiliates not under the Casdin Capital brand;
• Nonprofit organizations; and
• Government entities.

Please see the section above titled “How We May Use Personal Information” for further information regarding how we use the personal information of California consumers.

Additionally, please see the section above titled “How We May Share Personal Data” for further information regarding how we share the personal information of California consumers.

In the past 12 months, we have not sold any personal information we collect to third parties, and we have shared the categories of personal information we collect only as set forth above.

Rights of California Consumers

The CCPA provides a California consumer the following rights, subject to certain exceptions and limitations:

• The right to request (a) the categories and specific pieces of personal information we collect, use, disclose, and sell about you, (b) the categories of sources from which we collected your personal information, (c) our purposes for collecting or selling your personal information, (d) the categories of your personal information (if any) that we have either sold or disclosed for a business purpose, and (e) the categories of third parties with which we have shared personal information;
• For certain categories of personal information, the right to request a list of what personal information (if any) we disclosed to third parties for their own direct marketing purposes in the past 12 months and the names and addresses of those third parties;
• The right to request that we delete the personal information we have collected from you or maintain about you;
• The right to opt out of our sale(s) (if any) of your personal information; and
• The right not to receive discriminatory treatment for the exercise of the privacy rights conferred by the CCPA.

You may submit requests relating to your exercise of rights under the CCPA to us:

• via phone: 212-554-4962;
• submitting a request online using the following online form: https://casdincapital.com/contact-us/; or
• via email: info@casdincapital.com

We may need to request additional information from you to verify your identity or understand the scope of your request. In verifying requests, we will require you to provide, at a minimum your telephone number or mailing address. If we are unable to verify your identity, we will need to deny your request.

You may designate an authorized agent to make a CCPA request on your behalf by mailing two forms of identification showing your first name, last name, and current address, and a signed authorization allowing an agent to request information on your behalf.