PRIVACY POLICY of the website www.bostonam.us / www.bostonassetmanager.us pursuant to the United States of America law

• DATA CONTROLLER Following consultation of the site www.bostonam.us , personal data may be processed, or data relating to identified or identifiable persons. The Data Controller is Boston Funds LLC , with registered office in 11 Wall St, New York, NY 10005, United States mail: info@bostonam.us Data Protection Officer – gprd@bostonam.us

• PURPOSE OF THE TREATMENT The site processes personal data for the purposes of publication, information and institutional communication, participation of citizens, as well as the provision of services of competence, based on the relative provisions of law or regulation or whenever the processing of data is necessary for the execution of a task of public interest.

• PLACE OF TREATMENT The treatments connected to the web services of this site take place at the headquarters of the company Boston Asset Manager (Argentina) and are only handled by technical staff of the offices authorized to process. In case of need, the data can be processed by the staff of the company that takes care of the maintenance of the technological part of the site. Boston Asset Manager S.A. based in Av. Corrientes 316 , Ciudad Autonoma de Buenos Aires, Argentina, as a provider of the website, may have access to the data acquired through the online services offered by the website for the sole purpose of technical assistance and / or maintenance, in compliance with the information provided by the owner.

• TYPE OF DATA PROCESSED The following types of data are processed: § Navigation data The computer systems and software procedures used to operate this website acquire, during their normal operation, some personal data, the transmission of which is implicit in the use of Internet communication protocols. This information is not collected to be associated with identified interested parties, but which, by their very nature, could, through processing and association with data held by third parties, allow users to be identified. This category of data includes IP addresses or domain names of the computers used by users who connect to the site, the addresses in URI notation of the requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server and other parameters relating to the operating system and the user’s computer environment. These data are used for the sole purpose of obtaining anonymous statistical information on the use of the site, to check its correct functioning and are deleted immediately after processing. The data could be used to ascertain responsibility in case of hypothetical computer crimes against the site.

Data provided voluntarily by the user The optional, explicit and voluntary sending of e-mails to the addresses indicated on this site involves the subsequent acquisition of the sender’s address, necessary to respond to requests, and any other personal data included in the message. Specific summary information will be progressively reported or displayed on the pages of the site prepared for particular services on request. § Cookies In compliance with the provision of the Privacy Guarantor, it is specified that the site uses some cookies to make its services easy to navigate and efficiently use the web pages. The cookies used also allow us to improve the service provided to users, making the use of the same more effective and / or enabling certain features. By analyzing them in detail, our cookies allow you to: • store the preferences entered; • avoid re-entering the same information several times during the visit such as username and password; • analyze the use of the services and content provided by bostonam.it to optimize the browsing experience and the services offered. For the complete information, please refer to the cookie policy at the following link: //www.bostonam.us/cookies-policy

• PROCESSING METHODS Personal data are processed with automated tools for the time strictly necessary to achieve the purposes for which they were collected. Specific security measures are observed to prevent the loss of data, illicit or incorrect use and unauthorized access.

• RIGHTS OF THE INTERESTED PARTIES Users can exercise certain rights with reference to the data processed by the Data Controller. In particular, the User has the right to: – Revoke consent at any time. The User can revoke the consent to the processing of their Personal Data previously expressed. – Oppose the processing of your Data. The User can object to the processing of their Data when it takes place on a legal basis other than consent. – Access your Data. The User has the right to obtain information on the Data processed by the Data Controller, on certain aspects of the processing and to receive a copy of the Data processed. -Verify and request rectification. The User can verify the correctness of their Data and request its updating or correction. – Obtain the limitation of the treatment. When certain conditions are met, the User may request the limitation of the processing of their Data. In this case, the Data Controller will not process the Data for any other purpose than their conservation. – Obtain the cancellation or removal of your Personal Data. When certain conditions are met, the User can request the cancellation of their Data by the Owner. – Receive your Data or have them transferred to another holder.

The User has the right to receive their Data in a structured format, commonly used and readable by automatic device and, where technically feasible, to obtain its transfer without hindrance to another holder. – Propose a complaint. The User may lodge a complaint with the competent personal data protection supervisory authority or take legal action. – How to exercise your rights. To exercise the rights, Users can direct a request to the contact details of the Data Controller indicated in this document. Requests are filed free of charge and processed by the Data Controller as soon as possible, in any case within one month.

• DATA PROTECTION OFFICER AND PRIVACY COMMUNICATIONS The DPO (Data Protection Officer) is the Lic. Mauro A. Martinez e-mail: maurom@bostonam.us

Last revision 19/07/2022