Important Disclosure Information

180 Degree Capital Corp. (“180 Degree Capital,” the “Company,” and “we”) is a non-diversified closed-end management investment company (“closed-end fund” or “CEF”) registered under the Investment Company Act. We operate as an internally managed investment company whereby our officers and employees, under the general supervision of our Board of Directors, conduct our operations. We are publicly traded on NASDAQ under the symbol TURN. As of May 2020, 180 Degree Capital is also registered with the SEC as an investment adviser subject to the Investment Advisers Act.

Investments in privately held companies and micro-capitalization stocks are subject to greater volatility and liquidity risks than those in larger, more established companies. There may be no market for privately held securities and, thus, no assurance that an appreciated investment can be sold while it is profitable. Similarly, trading in micro-cap stocks may be light or intermittent, limiting the ability of the strategy to either exit appreciated positions at a profit or exit falling positions to mitigate losses. Recommendations by the Company regarding these small companies may result in 180 Degree Capital owning or advising a significant portion of a company’s outstanding stock, which may subject holdings to restrictions on transfer and/or other lock-up provisions that limit the ability to sell positions in an orderly fashion. Further, the information available for review by the Company may be more limited than the information available for larger public companies, which can contribute to higher volatility and greater risk of loss of principal.

Emphasis on turnaround investing indicates the presence or prevalence of portfolio companies that have not attained profitability. Other risks associate with the investment strategy include lack of management depth and limited or no history of operations among portfolio companies. Because of the speculative nature of our investments and the lack of a liquid market for and restrictions on transfers of privately held investments, there is greater risk of loss relative to traditional marketable investment securities.

This website and the contents of it are for information purposes only and is not intended as an offer, recommendation or solicitation for the sale of any financial product or service or as a determination that any investment product or strategy is suitable for a specific investor. Investors should seek financial advice regarding the suitability of any investment product or investment strategy based on the investor’s objectives, financial situation and particular needs. Any expressed opinions, estimates and projections constitute the judgment of 180 Degree Capital and are subject to change without notice.

The investments or investment strategies discussed herein may not be suitable for every investor. There is no assurance that any investment strategy will be successful. Any past performance contained in 180’s website is not an indication or guarantee of future performance.

Privacy Policy

180 Degree Capital Corp. (“the Company” or “we” or “us” or “our”) values your privacy rights. Please take a moment to review our policies and practices described below. By visiting our website, you consent to these policies and practices.

WHAT INFORMATION DO WE COLLECT?
We collect your IP address when you access this website.

We will collect certain personally identifiable information (“PII”) about you if you contact us through our website (using the Contact Us page) and submit such information. For example, we will ask for and collect your name, company name, address, city, state, zip/postal code, country, email address, phone number, fax number, and any other information that you choose to provide to us in your subject line and message. We also collect your PII, including, without limitation, your e-mail address, if you subscribe to our e-mail alerts or online newsletters.

We collect general non-personal information about you when you visit our website, such as whether you have accessed the page before and the time of your last visit. We accomplish this through a cookie placed on your computer (see below for a description of how cookies function).

HOW IS YOUR INFORMATION USED?
We consider the PII we collect from you to be confidential. If you submit your e-mail address or other PII to us via our website while requesting information or contacting someone at the Company, we will use this information only to the extent necessary to respond to your request(s) and as discussed below.

We use the information collected about site visits, including IP address, the pages you view, information you search for, the average time spent on our websites, and statistical information about website visits, to better understand our audience and its interests, and to increase the functionality and user-friendliness of our site.

To the extent permitted by law, any information collected over our website or concerning its use (personal and non-personal) may be disclosed to government authorities or third parties pursuant to a legal request, subpoena, or other legal process. We may also use or disclose your information as permitted by law to collect debts, fight fraud or protect the rights or property of the Company, our website, its users, or third parties, or when we otherwise believe in good faith that the law requires it. If you are visiting the site from a member state of the European Union or another country with strict data protection or privacy laws you should be aware that this site is hosted in the United States, which does not have similar laws in place.

HOW DO WE USE COOKIES?
We may use technologies such as cookies to learn about your visit. A cookie is a piece of information that is sent to your browser from a web server and stored on your computer’s hard drive. A cookie allows us to determine that a visit has occurred within our site, as well as which pages were viewed.

When you access our website, we place a cookie on your computer. This cookie is not used to identify you and will not collect personal information.

You can decide if and how your computer will accept cookies by configuring the preferences option within your web browser. If you choose to decline cookies, however, some of the functionality of this website might be impaired. Please see our cookie policy for more information.

TO WHAT THIRD PARTIES DO WE DISCLOSE YOUR PERSONALLY IDENTIFIABLE INFORMATION?
We might share your PII with our affiliated companies and with our business partners or others who work for us such as service providers, vendors, contractors and agents (collectively “Service Providers”) to enable them to perform services for us. However, we require that our Service Providers not sell, transfer or use your PII for any other purposes, or use any of the information we share about you for their or any third-party’s marketing purposes. We might also disclose your PII to third parties as described in this Privacy Policy under “How Is Your Information Used?” and “What If There Is a Change in Corporate Control?”

HOW DO WE PROTECT PERSONALLY IDENTIFIABLE INFORMATION COLLECTED ON THIS SITE?
We have established certain reasonable electronic and administrative safeguards to protect the PII in our possession from loss, misuse, and unauthorized access, disclosure, alteration and destruction. Nevertheless, due to the inherent nature of the Internet as an open global communications vehicle, we cannot guarantee that information, during transmission through the Internet or while stored on our system or otherwise in our care, will be absolutely safe from unauthorized intrusion by third parties, such as hackers.

LINKS TO THIRD-PARTY SITES
Our websites might contain links to other sites. We are not responsible for the content or privacy policies of those other sites. You should consult those sites’ privacy policies.

WHAT IF THERE IS A CHANGE IN CORPORATE CONTROL?
In the event of a corporate change in control resulting from, for example, a sale to, or merger with, another entity, or in the event of a sale of assets, the Company reserves the right to transfer your personal information to the new party in control or the party acquiring assets.

CHANGES TO THIS PRIVACY POLICY
We reserve the right, in our sole discretion, to modify, alter or otherwise update this policy at any time and you agree to be bound by such modifications, alterations or updates. We will notify you of material changes to this privacy policy by posting the revised policy with the date it was revised on this page. Your continued use of our website constitutes your agreement to this privacy statement and any updates. We encourage you to periodically review this privacy statement to stay informed about how we are protecting the PII we collect.

HOW CAN YOU CONTACT US?
If you would like to contact us about this policy or our website, you may e-mail us at ir@180degreecapital.com.

This Policy is effective January 1, 2019