Stieven Capital Advisors, L.P. –Privacy Notice
PRIVACY NOTICE
December, 2025
Introduction
Your privacy is very important to us. This notice (this “Privacy Notice”) is provided by Stieven Capital Advisors, L.P., (the “Investment Manager”, “we” or “us”), and sets forth our policies for the collection, use, storage, sharing, disclosure (collectively, “processing”) and protection of personal data relating to current, prospective and former clients and investors, as applicable.
References to “you” or an “investor” in this Privacy Notice mean any investor who is an individual, or 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”). The Investment Manager is 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 the Investment Manager determines the purposes and the means of the processing of your personal information.
Please contact our Compliance Officer at (314) 779-2420 or by writing to the following address 12412 Powerscourt Drive, Suite 250, St. Louis, MO 63131 with any questions about this Privacy Notice or requests with regards to the personal data we hold.
Please note that the certain third parties, including administrators and prime brokers, 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 the service providers, you may also contact the relevant service provider directly at the address specified in the offering memoranda 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, the Administrator, 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 process your personal data for the purposes of administering the relationship between you and us (including subscription acceptance, communications and reporting), marketing of our products and services, monitoring and analyzing our activities, and complying with applicable legal or regulatory requirements (including anti-money laundering, fraud prevention, tax reporting, sanctions compliance, or responding to requests for information from supervisory authorities, or law enforcement agencies).
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:
(i) processing is necessary to perform our obligations under the Fund Documents;
(ii) we are required to comply with a legal or regulatory obligation applicable to us; or
(iii) 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 the Investment Manager being unable to accept your subscription. 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 prime brokers, 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.
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. 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 the 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 contacting us at (314) 779-2420. 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.
We do not share your information with non-affiliates for them to market their own services to you. We may disclose information you provide to us to companies that perform marketing services on our behalf, such as any placement agent retained by us.
CALIFORNIA PRIVACY NOTICE
December, 2025
CALIFORNIA RESIDENTS ONLY
This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS supplements the information contained in the Privacy Policy and applies solely to users who reside in the State of California (“you”). We adopt this notice to comply with the amended California Consumer Privacy Act of 2018 (“CCPA”), The California Privacy Rights Act (the “CPRA”) and other California privacy laws. Any terms defined in the CCPA and/or the CPRA have the same meaning when used in this notice.
Categories of Personal Information that SCA Collects
During SCA’s communication with you via texts, calls, emails we might collect the below mentioned categories of personal information. This information might also be collected if you visit our website. Note that the categories listed below are defined by California state law. Inclusion of a category in the list below indicates only that, depending on the services we provide you, we may collect some information within that category. It does not necessarily mean that we collect all information listed in a particular category.
A) Identifiers: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.
B) Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)): A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.
C) Protected classification characteristics under California or federal law: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
D) Commercial information: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
E) Internet or other similar network activity: Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
F) Geolocation data: Physical location or movements.
G) Professional or employment-related information: Current or past job history or performance evaluations.
H) Inferences drawn from other personal information: Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Note: This is not an exhaustive list. Please see more details here - https://oag.ca.gov/privacy/ccpa#:~:text=The%20California%20Consumer%20Privacy%20Act,how%20to%20implement%20the%20law
How SCA Uses the Information We Collect
SCA may use the information we collect from you to:
provide services to you;
bill/invoice you;
complete corporate transactions;
manage any accounts that you may have with us;
validate your identity;
send personalized marketing messages via email, post and telephone to you. Where required by applicable law, we will send these messages with your consent, and you have the right to opt out of receiving marketing by contacting us;
serve relevant advertising on our site and third-party sites related to our products and services which are personalized to your interests;
provide you with notice of product releases, special events, trainings, promotions or other matters relevant to you;
respond to your inquiries;
improve the services you receive from us;
solicit your feedback;
prevent you from having to re-enter personal information about you on future visits to our websites or subsequent use of our applications;
process your payments and purchases;
operate, evaluate and improve our business (including developing new products and services; enhancing and improving our services; managing our communications; performing data analytics; and performing accounting, auditing and other internal functions);
provide technical support/ answer your questions via Zoom calls;
detect and prevent fraud and other unauthorized activity and enforce our terms of use; and
comply with applicable legal requirements, relevant industry standards and our policies.
SCA will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
How Long SCA Keeps Personal Information
At a minimum, SCA will keep personal information about you for as long as we have a relationship with you, for example as long as you are a customer (and for a reasonable period thereafter). When determining how long to retain personal information after we no longer have a relationship with you, we take into account how long our customers usually want to continue hearing from us, our legal and regulatory obligations the expectations of regulators, as well as the length of time information is needed for internal audit purposes and to exercise or defend our legal rights.
Retention in case of queries – SCA may retain your personal information for a reasonable period in case of follow up queries from you.
Retention in case of claims – SCA may retain your personal information for the period in which you might legally bring claims against us (this means we will retain it in line with relevant limitation periods, which are applicable to your jurisdiction).
Retention in accordance with legal and regulatory requirements – SCA will consider whether we need to retain your personal information after the period of retention in the case of queries or claims because of a legal or regulatory requirement.
Retention permitted under applicable law – SCA will continue to retain personal information where necessary to provide our services to you and the retention of such personal information is necessary for the purposes of pursuing our legitimate interests or where it is necessary for public interest purposes.
SCA reviews our retention periods for Personal Information on a regular basis, and all data is retained in compliance with applicable data protection law. SCA will only permanently retain certain basic Personal Information, for limited purposes. This is in relation to retaining basic contact details, to keep a record that you were a customer, in case you return in future, or where you have asked us not to contact you again.
Your Rights
Subject to SCA’s regulatory and legal obligations, you may be entitled to certain rights, which can include:
where our use of your personal information requires consent, you may withdraw this consent at any time;
you may request access to your personal information we hold about you and obtain information about how we process it; depending on the applicable privacy laws, you may be entitled to request the categories and specific pieces of personal information that we have collected about you, the categories of sources from which the personal information was collected, the purposes of collecting the personal information, the categories of third parties we have shared the personal information with, and the categories of personal information that have been shared with third parties for a business purpose;
you may update, correct or amend the personal information we hold about you if it is wrong;
you may ask us to change, restrict or stop the way in which we communicate with you or process personal information about you;
you may ask us to delete your personal information;
you have rights in relation to automated decision making, including profiling which has a legal effect, or which causes a significant effect;
you may ask us to move, copy or transfer your personal information;
you may object to our processing of your personal information; and
you may opt out of the sale of personal information—however, for purposes of California law, we do not sell your personal information to third parties, nor do we intend to, as those terms are defined by California privacy law; in addition, we have contracts with our service providers to prohibit any sale of the personal information we provide them, but if you have any concerns that our third parties might be selling your information, please contact us.