COTwo Advisors Privacy Policy

Last Updated: June 13, 2025

COTwo Advisors, LLC serves as the sponsor for COTwo Advisors Physical European Carbon Allowance Trust (the “Trust”), hereinafter referred to collectively as “COtwo Advisors,” (or “we,” “us” or, “our”). This privacy policy explains the personal information we collect, process, and disclose in connection with your interaction with our website or other direct contact with us. Throughout this policy, “you” refers to the individual that is using the website or services of COTwo Advisors.

We reserve the right to change, amend, or update this Privacy Policy. If we decide to change our Privacy Policy, we will post the revised Privacy Policy on this website or in a manner through which we regularly interact with you.

Personal Information We Collect

The personal information we have collected about you over the past 12 months includes information within the below categories of data. Note that the categories listed below derive from the categories listed by California state law. It does not necessarily mean that California privacy law applies.

  
      Category
      Purpose of Collection
      Source of Personal Information
    

  
      Identifiers such as a real
name, alias, postal address,
unique personal identifier,
online identifier, Internet
Protocol address, email
address, account name,
driver’s license number or
other similar identifiers.
      To communicate with you in
the event you contact us
      Directly from you when you
provide it to us
    

      Information that identifies,
relates to, describes, or is
capable of being associated
with, a particular individual,
for example, your name,
signature, physical
characteristics or description,
address, or telephone number.
      To communicate with you in
the event you contact us
      Directly from you when you
provide it to us
    

      Internet or other electronic
network activity information,
including, but not limited to,
browsing history, search
history, and information
regarding a consumer’s interaction with an internet
website, application, or
advertisement.
      To analyze user clicks and
usage of the website to
improve user experience and
maximize usage of our
services.
      Information provided through
your interaction with our
website.
    

Information We Collect Automatically
We collect information about your visits to the website and the application when you land on any of our web pages through cookies and similar tracking technology. Cookies are small data files that a website you visit may save on your computer or handheld device that usually include an anonymous unique identifier. Our website may use cookies for user authentication, keeping track of your preferences, promotional campaigns, tracking our audience size and traffic patterns, gathering analytics, and user data.

You may turn off cookies at any time by changing settings on your browser or via the cookie consent manager on our website.

Google Analytics
We use a tool called “Google Analytics” to collect information about the use of this site. Google Analytics collects information such as how often users visit this site, what pages they visit when they do so, and what other sites they used prior to coming to this site. We use the information we receive from Google Analytics only to improve this site. Google Analytics collects only the IP address assigned to you on the date that you visit this site, rather than your name or other identifying information. We do not combine the information collected using Google Analytics with personally identifiable information.

Google’s ability to use and share information collected by Google Analytics about your visits to this site is restricted by the Google Analytics Terms of Use and the Google Privacy Policy.
Google has developed the Google Analytics opt-out browser add-on for the Google Analytics JavaScript (ga.js, analytics.js, dc.js). If you want to opt out of Google Analytics, you can download and install the add-on for your web browser here: https://tools.google.com/dlpage/gaoptout.

How We Share Information
COTwo Advisors has not sold or shared personal information in the past 12 months.

In the past 12 months, COTwo Advisors may have disclosed any of the above categories of personal information:

Pursuant to an individual’s consent
Under a written contract with a service provider for a business purpose
To comply with any court order, law, or legal process, including a response to a government or regulatory request
To protect the rights, property, or safety of our investors or others
To measure the performance of our website and improve its performance

We may also disclose personal information to fulfill our obligations in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of COTwo Advisors’ assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding.

We do not sell or rent investor information of the Trust. We only disclose non-public personal information collected about Trust investors as permitted by law. For example, we may disclose non-public personal information about Trust investors:

To companies that act as service providers in connection with the administration and servicing of the Trust, which may include attorneys, accountants, auditors, and other professionals, the maintenance of shareholder accounts, and the servicing or processing of transactions of the Trust
To government entities, in response to subpoenas, court orders, judicial process, or to comply with laws or regulations
To protect against fraud, unauthorized transactions (such as money laundering), claims or other liabilities, or to collect unpaid debts
When shareholders direct us to do so or consent to the disclosure, including authorization to disclose such information to persons acting in a fiduciary or representative capacity on behalf of the investor

We do not collect, use, or disclose sensitive personal information beyond what is reasonably necessary to provide our services.

Your Rights
Subject to certain exceptions and depending on your residency, you may be entitled to the following rights:

Right to Know – You may request that we disclose the specific pieces of personal information we have collected about you, the categories of information collected, sources, purposes, and third parties we’ve disclosed it to.
Right to Deletion – You may request we delete your personal information, with exceptions (e.g., legal obligations, service continuity, or pending claims).
Right to Correction – You may request we correct inaccurate personal information, again subject to certain legal exceptions.

You also have a right to receive nondiscriminatory treatment for exercising these rights.

To exercise these rights, submit a verifiable consumer request at: https://www.cotwoadvisors.com/contact.

Only you or a legally authorized agent may make such a request. The request must:

Provide sufficient information for us to verify your identity (we may ask you to match two or three data points)
Clearly describe your request so we can properly evaluate and respond

We will not fulfill requests if we cannot verify your identity. We will only use the provided data to verify your request.

We aim to respond within 45 calendar days. If more time is needed (up to another 45 days), we will notify you and explain why.

How Long We Keep Your Personal Information
We retain personal data only as long as necessary for the purposes for which it was collected. COTwo Advisors may retain data as needed to comply with legal obligations or resolve disputes. When no longer needed, data is destroyed, deleted, or anonymized. Data will not be destroyed during regulatory retention periods or ongoing investigations.

How We Secure Personal Information
COTwo Advisors uses measures to protect personal information from loss, misuse, unauthorized access, or disclosure. These include restricting access, working only with secure third parties, and maintaining strong physical, technical, and administrative safeguards. We limit access to personal data to employees with a need to know as part of their job duties.

Children’s Personal Information
We do not knowingly collect information from anyone under 18. If we receive such data inadvertently, we will delete it. We also do not knowingly sell or share information of those under 16. If you believe we’ve collected such information from your child, please contact us.

How to Contact Us
If you have questions about this privacy policy, please contact us at https://www.cotwoadvisors.com/contact or call toll-free at (866) 990-6442.