Privacy & Cookie Policy

Last updated: March 2026

This Privacy and Cookie Policy (this “Policy”) describes the ways in which Northern Merritt Funds, a marketing name of Meridian Hill Partners, a Delaware general partnership (“Northern Merritt,” “we,” “us,” or “our”), collects, uses, and discloses information about you, including personally identifiable information, in connection with your use of the Northern Merritt Investor Portal (the “Portal” or “System”) and the services we provide to you through it. Throughout this Policy, “you” refers to the individual or entity that accesses the System. By using the System, you consent to the use of your information as set forth in this Policy.

1. This Policy

Scope. We operate the System to provide investor administration and communication services to our authorized investors and personnel (the “Services”). The System is a private, restricted platform available only by credentials we issue; it is not a public website and is not intended for the general public. In the course of providing the Services, we collect “Personal Information,” which means any information relating to an identified or identifiable natural person. We act as the controller of the Personal Information collected through the System.

Changes to this Policy. We reserve the right to update this Policy from time to time by posting a new Policy on this page, and in some cases, where changes are material, we may also contact you by electronic mail or post a notice within the System. You are advised to review this Policy regularly. Your continued use of the System after changes are posted constitutes acceptance of those changes.

2. Collection of Information

Information that You Provide. We collect information that you voluntarily provide, including when an account is created for you on the System or when you use the Services. Such information may include your name, email address, and postal address. We may also collect information that you provide when you correspond with us directly.

Information We Maintain About Your Account. To provide the Services, we maintain information about your investment account, including your investor number, account registration, product and series details, balances, transactions, statements, and the secure messages associated with your account.

Automatically Collected Information. We may automatically collect certain technical information from your device when you use the System, such as your Internet Protocol (IP) address, your web browser type and version, your operating system, and sign-in activity. We use this information to operate and secure the System.

Information about Legal and Other Materials. We may collect information concerning your receipt of communications, access to materials, and approval, acceptance, or execution of agreements, consents, or other statements made through the System, including this Policy and any Terms of Use.

Cookies. We may collect certain information using “cookies,” which are small text files saved on your device. See the Cookie Policy in Section 5 below for details.

Cross-Site Tracking. We do not use technical measures in the System to track your activities across third-party websites or online services.

Reviewing and Correcting Information. Because the System uses credentials we issue, there is no self-service registration or password reset. You may review certain information on your profile page, and you may update or correct your contact information and other Personal Information by sending a written request to Investor Services at the contact details in Section 9.

3. Use and Disclosure of Information

We may collect, use, share, and otherwise process your Personal Information for a number of purposes, including, but not limited to:

Providing the Services. We use your Personal Information to authenticate you, to provide the Services and related information, to provide you with required notices, and to operate the System.

Communications. We use your contact information to send you account and Service-related communications and required notices. We do not sell or share your Personal Information with other companies for their own marketing.

Security. We may use and share your Personal Information as necessary to pursue our legitimate interests in the security of the System and Services, including detecting, preventing, and responding to fraud, violations of our Terms of Use, violations of law, or other misuse of the System, and when we believe in good faith that disclosure is necessary to protect our rights, the rights of other users, the integrity of the System, or the safety of any person.

Service Providers. We engage third-party service providers (such as cloud hosting, infrastructure, and security providers) to assist in operating the System. These providers are authorized to use your Personal Information only as necessary to provide services to us and under obligations of confidentiality.

Other Disclosure. We may disclose Personal Information about you to others: (a) with your valid consent; (b) to comply with a valid subpoena, legal order, court order, legal process, or other legal obligation; (c) to enforce our terms and conditions or policies; or (d) as necessary to pursue available legal remedies or defend legal claims. We may also transfer your Personal Information to an affiliate or a third party in the event of any reorganization, merger, acquisition, sale, joint venture, assignment, transfer, or other disposition of all or a portion of our business or assets, provided that any recipient will not be permitted to process your Personal Information other than as described in this Policy without notice and, where required, your consent.

4. Storage

Jurisdiction. Information collected through the System will be stored in, processed in, and subject to the laws of the United States. By using the System, you consent to such transfer to, storage in, and processing within the United States.

Security. We are committed to protecting your information from unauthorized access, use, or disclosure. We maintain administrative, technical, and physical safeguards designed to protect the information collected through the System, including encryption of data in transit using Transport Layer Security (TLS), hashed storage of passwords, role-based access controls, and audit logging. However, no information or communication system can be completely secure, so we cannot guarantee the absolute security of your information, and we are not responsible for the security of information you transmit over networks we do not control.

Retention. We will not retain data longer than is necessary to fulfill the purposes for which it was collected or as required by applicable laws or regulations. Subject to applicable law, you may request that the data we hold about you be accessed, corrected, blocked, or deleted.

5. Cookie Policy

This section describes how we use cookies (“Cookies”). Cookies are small pieces of data stored on your device when you visit a page. The provision of data via Cookies is voluntary except for those Cookies that are necessary for the performance of the System.

Use. We use a strictly necessary Cookie to authenticate you and keep you signed in, and to support the security and core functionality of the System. We do not use advertising Cookies or third-party tracking Cookies, and we do not embed third-party content (such as video players, chat widgets, or social media) that set their own Cookies.

Managing Cookies. You can review your preferences at any time through Cookie Settings. You can also control or delete Cookies through your browser settings — for general information, see aboutcookies.org. If you block the strictly necessary Cookie, you will not be able to sign in to the System.

6. Notice to California Residents (CCPA/CPRA)

Verified California residents have the right to: request disclosure of our personal information collection and sharing practices during the prior 12 months; request a copy of the personal information we have collected about them; request that we delete their personal information (subject to exceptions); request that we correct inaccurate personal information; request that we limit the use and disclosure of sensitive personal information; and request that we not sell or share their personal information. For purposes of this Section, “personal information” has the meaning given in the California Consumer Privacy Act, as amended (“CCPA”), and does not include de-identified or aggregated information or information excluded from the CCPA’s scope.

Do Not Sell or Share. We do not sell, share, or disclose your personal information to third parties for monetary or other valuable consideration. If we ever enter into arrangements that fall within the definition of a “sale” or “share” under the CCPA, we will update this Policy first.

Making a Request. California residents may submit a request by contacting us at the details in Section 9. We will ask for information that allows us to reasonably verify your identity and will use that information only for that purpose. We will acknowledge your request within 10 days and endeavor to respond within 45 days (we may extend by an additional 45 days with notice). You may use an authorized agent who provides written permission and verifies your identity with us. We will not discriminate against you for exercising any of these rights.

The categories of personal information we may collect, the sources, our purposes, and the categories of recipients are summarized below:

7. Children’s Information

The System is intended for authorized investors and is not directed to, nor do we knowingly collect information from, individuals under the age of 18. If you become aware that a minor has provided information, please contact us immediately using the details below.

8. Other Agreements

You may from time to time enter into binding legal agreements relating to certain Services available through the System, which may have terms different from those of this Policy. In the event of any inconsistency, the terms of such other agreement shall control with respect to those Services.

9. Contact Information

If you have any questions about this Policy or the collection or use of information about you, please contact us at northfunds@northernmerrittfunds.com. Northern Merritt Funds is a marketing name of Meridian Hill Partners, a general partnership organized in the State of Delaware.