Mill City Loan Holdings, LLC Website Privacy Policy and User Agreement

Thank you for visiting the Website (the “Website”) of Mill City Loan Holdings, LLC and its affiliated investment advisors (collectively, “Mill City” or “we”). By downloading, accessing or using this Website, you signify your consent to the following terms and conditions of use, without limitation or qualification. If you do not agree to these terms, do not use this Website.

Mill City may collect and use information relating to your use of the Website, in accordance with the terms and conditions of this Website Privacy Policy and User Agreement (collectively, this “Policy”). This Policy concerns only the Website and does not concern your interaction with Mill City in any matter other than your use of the Website. This Policy does not address our privacy practices with respect to any “nonpublic personal information” or “personal data” (together, “Personal Information”) we may collect from you as an investor in funds or accounts that we sponsor or manage or as persons with whom we otherwise conduct business. We address these practices in separate notices as required by applicable law and regulation.

Mill City may change this Policy from time to time, and any modifications will be effective immediately upon posting, unless Mill City indicates otherwise.

Privacy Policy

Collection and Disclosure of Information

The Website is not configured in a manner that requires you to provide us with Personal Information in order to obtain access to certain information or materials. Therefore, Mill City does not, in the ordinary course, obtain Personal Information about you via the Website.

However, when you enter and browse the Website, Mill City may collect information about your use of the Website and the devices you use. This may include, but is not limited to:

• how often you access the Website;
• the browser you use to access the Website;
• the Websites you access before and after accessing the Website; and
• connection information, such as IP addresses.

The Website may also use cookies to log your behavioral information. Cookies may be held by our third-party Website provider.

Security of Information

In the event Mill City collects any Personal Information about you, it will take appropriate precautions to protect your information from loss, misuse or alteration. Mill City maintains physical, electronic, and procedural safeguards that comply with applicable law and regulation to guard your information. You should recognize, however, that there is no such thing as “perfect security” on the Internet, and third parties may unlawfully intercept or access transmissions or private communications.

Correcting or Updating Personal Information

In the event Mill City collects any Personal Information about you and your Personal Information changes, Mill City will correct, update, or remove any information you have previously provided to it upon your request. You may change your Personal Information at any time by sending Mill City an e-mail at [email protected].   Mill City may retain a copy of the prior information for its records.

Personal Information

In the event Mill City collects any Personal Information about you, in certain cases, you may have rights in relation to your Personal Information under applicable laws and regulations relating to privacy, data protection, breach notification, or the processing of Personal Information (collectively “Applicable Privacy Laws”). As noted above, Mill City does not, in the ordinary course, obtain Personal Information about you via the Website.

Uses of Personal Information

If Personal Information is collected through your use of the Website, Mill City may use your Personal Information for some or all of the following purposes:

• on the basis of its legitimate business interests in managing its business operations and information technology resources (for example, to enhance the Website functionality);
• on the basis of its legitimate interests in protecting Mill City, its employees, clients, trading partners and others; and
• to address legal requirements (including laws designed to protect the integrity of the financial sector).

Disclosures of Personal Information

In the event Personal Information is collected through your use of this Website, Mill City may share your Personal Information in some or all of the following ways:

• within the Mill City group;
• with other entities that assist Mill City in carrying out the processing described above, including professional advisors, technology providers (including third-party Website providers) and other service providers;
• with regulatory bodies and governmental authorities; and

Rights and Choices

In the event Personal Information is collected through your use of this Website, where Applicable Privacy Laws apply, by law you may have the right to:

• In certain cases, object to Mill City’ processing of your Personal Information.
• Request access to your Personal Information.
• Request correction of the Personal Information that Mill City holds about you. This enables you to have any incomplete or inaccurate information Mill City holds about you corrected.
• Request erasure of your Personal Information.
• Request the restriction of processing of your Personal Information.
• Request the transfer of your Personal Information to another party in a machine-readable, commonly used and structured format.

If you want to exercise any of these rights, then please contact Mill City using the contact details below. The various rights are not absolute and each is subject to certain exceptions or qualifications. For example, if you wish to object to processing, Mill City may need to discuss with you whether its use of your Personal Information needs to continue for other lawful purposes, such as fulfilment of a legal or contractual requirement.

Mill City will respond to your request within one month of receipt of your request. In some cases Mill City may not be able to fulfil your request to exercise the right before this date, and may need to request more time. Where Mill City cannot provide a full response to you for any reason, Mill City will let you know about this in its initial reply to your request.

Where these rights apply, you will not normally have to pay a fee to access your Personal Information (or to exercise any of the other rights described above). In some cases, Mill City may charge a reasonable fee if your request for access is clearly unfounded or excessive, or if you request multiple copies of the information. Alternatively, Mill City may refuse to comply with the request in such circumstances.

Mill City may need to request specific information from you to confirm your identity and ensure your right to access the Personal Information (or to exercise any of your other rights). This is another appropriate security measure to ensure that Personal Information is not disclosed to any person who has no right to receive it.

Contacting Mill City

To exercise any rights under Applicable Privacy Laws or to provide Mill City with complaints, concerns or questions, please contact Mill City at [email protected].