1. Introduction and Scope

This Privacy Policy describes how Asto Consumer Partners LP, a Delaware limited partnership and the investment manager of the Astō funds (“Astō,” “we,” “us,” or “our”), collects, uses, and discloses personal information when you visit astoconsumer.com (the “Site”), use the investor portal accessible through the Site (the “Portal”), or otherwise interact with us online.

If you are an investor or prospective investor in a private fund managed by Astō, including Asto Consumer Partners Fund LP (each, a “Fund”), nonpublic personal information that we collect about you in that capacity is governed by our Privacy Notice delivered pursuant to Regulation S-P, which is provided with the Fund’s subscription materials and is available upon request. That notice supplements this Privacy Policy and controls with respect to such information in the event of any conflict.

2. Information We Collect

Information you provide to us. We collect personal information that you voluntarily provide, including your name, email address, telephone number, employer, and title when you contact us (including at info@astoconsumer.com or ir@astoconsumer.com), request information, or submit a pitch or inquiry; your email address when you subscribe to our newsletter; the information you submit when registering for or using the Portal; and any other information you choose to provide in correspondence with us.

Information collected automatically. When you visit the Site, our web servers automatically log certain technical information about your device and usage, including IP address, browser type, operating system, referring URLs, pages viewed, and the dates and times of access.

Information from other sources. We may receive personal information from our service providers, including the administrator of the Funds and FIS (the host of the Portal), from publicly available sources, and from third parties you have authorized to share information with us.

3. Cookies and Online Tracking Technologies

The Site uses only first-party cookies and similar technologies that are strictly necessary for the Site to function and to maintain secure sessions. We do not use analytics, advertising, retargeting, session-replay, or cross-context behavioral advertising technologies on the Site, and we do not permit third parties to collect personal information from the Site for their own purposes. You can manage or delete cookies through your browser settings; disabling certain cookies may impair Site functionality.

Because we do not sell personal information, do not share personal information for cross-context behavioral advertising, and do not engage in targeted advertising, opt-out preference signals such as the Global Privacy Control do not apply to the Site as currently operated. The Site does not respond to “Do Not Track” browser signals.

4. How We Use Personal Information

We use personal information to operate, maintain, and secure the Site and the Portal; to respond to your inquiries and requests; to administer relationships with investors and prospective investors in the Funds; to send the newsletter and other communications you have requested (you may unsubscribe at any time using the link in each message or by contacting us); to detect, investigate, and prevent security incidents and fraudulent or unlawful activity; to comply with legal, regulatory, and contractual obligations; and to protect our rights and the rights of others.

5. How We Disclose Personal Information

We do not sell personal information, and we do not share personal information with third parties for their own marketing purposes. We may disclose personal information:

• to service providers that perform services on our behalf, including website hosting and development, information technology, fund administration, and Portal services (including FIS), subject to limitations on their use of the information;
• to our affiliates, including the general partner entities of the Funds and Christopher & Co., LLC, for the purposes described in this Privacy Policy;
• to our attorneys, accountants, auditors, and other professional advisers;
• to governmental and regulatory authorities, and otherwise as required by applicable law, subpoena, or legal process, or to protect our rights or the rights, property, or safety of others;
• in connection with an actual or contemplated corporate transaction, such as a merger, acquisition, financing, or sale of assets, subject to customary confidentiality protections; and
• with your consent or at your direction.

6. Data Retention

We retain personal information for as long as reasonably necessary to fulfill the purposes described in this Privacy Policy, taking into account the nature and sensitivity of the information, our legal and regulatory obligations (including books-and-records requirements applicable to registered investment advisers), and the establishment, exercise, or defense of legal claims.

7. Security

We maintain administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, use, and disclosure, appropriate to the nature of the information. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

8. Third-Party Websites

The Site contains links to websites operated by third parties, including portfolio companies of the Funds, LinkedIn, and the FIS-hosted Portal, which is operated on FIS’s systems and subject to FIS’s own terms and privacy practices in addition to ours. We are not responsible for the privacy practices or content of third-party websites, and this Privacy Policy does not apply to them. We encourage you to review the privacy policies of any third-party website you visit.

9. Children’s Privacy

The Site is not directed to, and we do not knowingly collect personal information from, individuals under the age of 18. If you believe a minor has provided personal information to us through the Site, please contact us at the address below and we will delete it.

10. State Privacy Rights

California. If you are a California resident, the California Consumer Privacy Act, as amended by the California Privacy Rights Act (the “CCPA”), may give you rights with respect to certain personal information. The CCPA does not apply to personal information collected, processed, or disclosed subject to the Gramm-Leach-Bliley Act and its implementing regulations, including Regulation S-P. Accordingly, personal information we collect about investors and prospective investors in connection with the Funds is generally exempt from the CCPA. With respect to personal information that is subject to the CCPA (such as certain Site visitor information), California residents have the right to know what personal information we collect, use, and disclose; to request deletion or correction of personal information; to opt out of the sale or sharing of personal information (we do not sell personal information and do not share personal information for cross-context behavioral advertising); and not to be discriminated against for exercising these rights. To exercise these rights, contact us as described in Section 12. We will verify your identity before responding and will respond within the timeframes required by law. You may designate an authorized agent to submit requests on your behalf.

Residents of other states with comprehensive privacy laws may have similar rights, subject to applicable exemptions for information collected under federal financial privacy law.

11. Visitors From Outside the United States

The Site is operated from the United States and is intended for United States residents. If you access the Site from outside the United States, you understand that your information will be transferred to, stored, and processed in the United States, where privacy laws may differ from those of your jurisdiction.

12. Contact Us; Changes

If you have questions about this Privacy Policy or our privacy practices, or wish to exercise any rights described above, contact us at info@astoconsumer.com; or Astō Consumer Partners, Attn: Chief Compliance Officer, 600 W. 5th Street, Suite 1200, Austin, TX 78701. We may update this Privacy Policy from time to time. The updated policy will be posted on this page with a revised “Last Updated” date, and material changes will be communicated as required by applicable law. Your continued use of the Site after an update constitutes acceptance of the revised policy.