Viking Privacy Notice

Last updated: April 2026

This Privacy Notice sets forth the policies of Viking Global Investors LP (together with its affiliates, “Viking”) and the funds to which Viking provides administrative or investment management services with respect to the collection, use, storage, and disclosure (collectively, “processing”) of non-public and other Sensitive Personal Information (as defined below). These policies apply to individuals only and may be modified at any time. You should check this website periodically for updates. This Privacy Notice does not apply to Viking employees.

1. Purpose of this Privacy Notice

This Notice describes the types of Personal Information that Viking may collect or process, how we may use and disclose that Personal Information, and how you may exercise any rights you may have regarding our processing of your Personal Information. This Notice applies to Personal Information collected or processed by us through our website (“Online Services”), when you request services from us, or we provide services to you (“Services”), in situations where you interact with us, when we undertake employment or recruitment activities, or anywhere this Notice is posted or referenced.

• If you provide us with Personal Information of anyone other than yourself, please note that you are responsible for complying with all applicable privacy and data protection laws prior to providing that information to us (including obtaining consent, if required).
• Please review this Notice carefully. To the extent permitted by applicable law, by providing us your Personal Information or otherwise interacting with us, you are agreeing to this Notice.

Please note that this Notice is distinct from the Gramm-Leach-Bliley Act (GLBA) Notice, which describes how nonpublic personal information (NPI) is collected, used, and shared; and describes the right to opt out of sharing with nonaffiliated third parties. Viking collects, uses, and discloses any NPI it receives in accordance with its GLBA Notice.

2. Information We Collect

“Personal Information” is any information—as electronically or otherwise recorded—that can be used to identify a person or that we can link directly to an individual, such as name, address, email address, telephone number, or credit card number, as applicable. Personal Information can include information that indirectly identifies a person, such as a unique number assigned to an individual, even absent other identifying information.

Personal Information may include information considered sensitive in some jurisdictions, such as biometric information, genetic information, medical and health information, financial account information, geolocation, ethnic or racial origin, information concerning your sex life or your sexual orientation, and other information. Data that could be considered Sensitive Personal Information is highlighted with a tilde (~) in the summary charts below. We only collect and processes Sensitive Personal Information for the purposes stated herein and do not use such data to infer characteristics about you. If required to do so, we will obtain your consent prior to processing your Sensitive Personal Information.

We will process any Personal Information we collect in accordance with applicable law and as described in this Notice (unless a separate policy or notice governs). In some circumstances, if you do not provide us with your Personal Information, certain services may be unavailable to you.

Below is a summary of how we collect, process, and use Personal Information and the potential recipients of your Personal Information, and how we have done so in the preceding 12 months.

*The legal bases we rely upon include those enumerated in Articles 6 and 9 of the European Union’s General Data Protection Regulation (GDPR), depending on the type of Personal Information. To the extent we process Personal Information for our legitimate interests, those interests include the processing purposes listed in the “Why we process the data” column.

**In limited circumstances, recipients may include, (1) in the event of a sale, assignment, or transfer, to the buyer, assignee, or transferee; and (2) government or regulatory officials, law enforcement, courts, public authorities, or others when permitted by this Policy or required by law.

***Please see our Cookie Notice for more information on how we use cookies and similar technologies.

^We will not attempt to reidentify you or anyone else from anonymized or deidentified data, and if we disclose it to third parties, we will require that they commit to not attempting to reidentify you or anyone else from the deidentified data.

For the purposes discussed in this Privacy Notice, we may combine the information that we collect through the Services with information that we receive from other sources, both online and offline, and use such combined information in accordance with this Privacy Notice.

In the past 12 months, we have not sold or shared for cross-contextual advertising purposes Personal Information to third parties.

3. Data Retention

The Personal Information we do or will collect as described herein, including Sensitive Personal Information, will be retained until we determine it is no longer necessary to satisfy the purposes for which it was collected and our legal obligations. As described above, these purposes include our business operations and complying with reporting, legal and accounting obligations. In determining how long to retain information, we consider the amount, nature and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of the Personal Information, the purposes for which we process the Personal Information and whether we can achieve those purposes in other ways, the applicable legal requirements, and our legitimate interests.

The purposes for which we process information (as well as the other factors listed above) may dictate different retention periods for the same types of information. For example, we may keep inquiries sent to us through the website for as long as needed to fulfill the request made.

4. Cookies and Tracking Technologies

To the extent permitted by law, including with your consent where required, we may engage in the following activities:

• We may use your contact details to contact you to determine whether you would like us to send you marketing emails. If you do not wish to receive such marketing emails, you may opt out by declining to receive such emails when registering, in our subsequent communications by following opt-out or unsubscribe instructions included in the email, by contacting us, or at other information collection points.
• We also perform statistical analyses of the users of our Online Services to improve the functionality, content, design, and navigation of our services.

This website may use certain tracking technologies, including “cookies,” which from time to time automatically collect certain information and data. “Cookies” are small pieces of data sent to your computer browser from our web server and stored on your computer’s hard drive. The data identifies you as a unique user and facilitates your ongoing access to and use of this website. Cookies also help us diagnose problems with our server and analyze how visitors use our website.

You may be able to set your web browser to refuse certain types of cookies, or to alert you when certain types of cookies are being used. Some browsers offer similar settings for HTML5 local storage and other technologies. However, if you block or otherwise reject cookies or similar technologies, certain websites (including this website) may not function as expected. Without refusing cookies through your browser, you can also opt out of Google Analytics by installing a Google Analytics Opt-out Browser Add-on for each web browser you use.

You may be able to opt out of or revoke your consent to, as applicable, receiving web-based personalized advertisements from companies who are members of the Network Advertising Initiative by going to http://optout.networkadvertising.org/?c=1 or participate in the Digital Advertising Alliance Self-Regulatory Program by going to http://www.aboutads.info/.

In addition, if you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to automatically decline cookies or be given the choice of declining or accepting the transfer to your computer of a particular cookie (or cookies) from a particular site. Visit http://www.allaboutcookies.org/manage-cookies/index.html for more information. If, however, you do not accept these cookies, you may experience some inconvenience in your use of our online services.

Certain web browsers and other programs may transmit “opt-out” signals, also called a Global Privacy Control (or GPC) signals (“GPC Signals”), to websites with which the browser communicates. You may need to change your web browser’s settings or add an application to your web browser to enable your browser to send a GPC Signal. Our online services may recognize GPC Signals for visitors differently, based on the location of the visitor when they access our online services. For visitors that access our online services from jurisdictions that have laws requiring recognition of GPC Signals, we will recognize and apply the GPC Signal to inactivate targeted advertising and social media cookies; it will not inactivate required cookies, functional cookies, and analytics cookies. For others, our online services may or may not recognize and apply the GPC Signal.

To turn on GPCs on your browser, go to your browser, open the Privacy or Security Settings, locate the GPC or other Opt Out Preference Signal setting in your browser extension and turn it on. If your browser does not have this option, you will need to implement a browser extension that can send these signals.

Some of our email communications may contain images that allow us and our service providers to perform email marketing analytics. We, however, will not place cookies on your device as a result of this process. Our analytics look to capture information about your engagement with our emails. We do not use this information to build profiles for advertising purposes or for automated decision-making. We do not sell, share, or otherwise make this data accessible to third parties outside of our service provider that performs analytics on our behalf. You may limit or prevent our email analytics by (a) disabling automatic image loading in your email client; (b) enabling privacy protection features in your email client that prevent senders from knowing when emails are opened and mask your IP address; and/or (c) by unsubscribing from our email communications.

5. Links to Other Online Services

Our Online Services may contain links to other websites, applications, products, or services that are not owned or operated by us. You should carefully review the privacy policies and practices of other websites, products, and services as we cannot control and are not responsible for privacy policies, notices, or practices of third-party websites, applications, products, and services.

6. How We Protect Your Information

We maintain technical, organizational, and administrative safeguards to protect your Personal Information. The entities performing services for us are directed to protect your Personal Information and to only use such information in connection with the services we have contracted with them to perform.  However, as is the case with all websites, applications, products, and services, we are not able to guarantee security for data collected through our Online Services. In addition, it is your responsibility to safeguard any passwords, ID numbers, or similar individual information associated with your use of the Online Services.

From time to time, we may review the purpose for which Personal Information has been collected and decide whether to retain or delete such information if we are permitted to do so under applicable law.

7. Children

We do not knowingly collect, solicit or disclose Personal Information from anyone under the age of 16.

8. Transfer of Personal Information Across National Borders

Please be aware that Personal Information we collect and process may be transferred and maintained outside your state, province, country, or other jurisdiction where the privacy laws may not be as protective as those in your location, including the United States. We have put in place lawful transfer mechanisms and adequate safeguards, in accordance with applicable legal requirements, to protect your Personal Information.

9. Your Rights Regarding Your Personal Information

Depending on where you live, you may have the following rights with respect to some or all of your Personal Information:

• The right to request: (a) the categories and specific pieces of Personal Information we collect about you; (b) the categories of sources from which we collect your Personal Information; (c) our business or commercial purposes for collecting, selling or sharing your Personal Information; (d) the categories of Personal Information disclosed for a business purpose and the categories of persons to whom it was disclosed; (e) the categories of your Personal Information (if any) that we have either sold, shared, or disclosed (including under GDPR Article 15 and other relevant laws).
• The right to request that we correct or delete your Personal Information, subject to certain exceptions (including under GDPR Articles 16 and 17 and other relevant laws).
• The right to restrict, block, or limit our use of your Sensitive Personal Information to only use that is necessary to perform the services expected or provide the goods reasonably expected (including under GDPR Articles 18, 21, and 22 and to object to or opt out of the sale or sharing of your Personal Information under other relevant laws).
• The right not to receive discriminatory treatment for exercising your rights.
• The right under certain circumstances to request information from us regarding the manner in which we share certain categories of Personal Information (as defined in the Shine the Light law) with third parties for their direct marketing purposes. We do not share your Personal Information with third parties for their own direct marketing purposes.
• The right to provide your Personal Information directly to another, i.e., a right to data portability (including under GDPR Article 20 and other relevant laws).
• The right to opt out of the use of automated decision-making technology when processing your Personal Information.
• The right to appeal the denial of a request.
• The right to lodge a complaint with the data protection authority in your jurisdiction.

You may submit requests relating to these rights to us via phone at 1 (203) 863-5000 or email at [email protected].

You may only make a verifiable request for access or data portability twice within a 12-month period. All verifiable requests must provide (1) enough information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative and (2) sufficient detail that allows us to properly evaluate and respond to it.

We endeavor to respond to a verifiable request within 45 days of its receipt. If we require more time, we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option.

10. Notice for Cayman Islands Fund Investors

If you are an individual (including, for purposes of this section of the Privacy Notice only, an individual associated with an investor in a Viking fund) and the fund in which you are invested is organized in the Cayman Islands (including any master fund in which you are indirectly invested), such fund and Viking are considered to be data controllers in respect of any Personal Information we hold about you for the purposes of the Cayman Islands Data Protection Act (2021 Revised) (the “DPA”). This means that the fund and Viking (alone or jointly, as applicable) determine(s) the purposes and the means of the processing of your Personal Information. We may disclose your Personal Information with the fund’s services providers or others who are located outside the Cayman Islands. It may also be necessary to disclose your information with the Cayman Islands Monetary Authority or the Tax Information Authority, which may, in turn, exchange this information with foreign tax authorities, regulatory or law enforcement agencies. Any transfer of your Personal Information by us or our service providers outside the Cayman Islands will be carried out in accordance with the DPA.

Contact Us

If you have any questions about this Privacy Notice or wish to exercise your rights, you may contact us at 1 (203) 863-5000 or email at [email protected].