Privacy Policy

2.1 IDENTITY DATA

• Full legal name (first, middle, last) and any aliases or former names;
• Date of birth (individuals) or date and jurisdiction of formation (entities);
• Government-issued identification numbers, including Social Security number ("SSN"), taxpayer identification number ("TIN"), passport number, and driver's license number;
• For entity investors: entity legal name, type of entity, jurisdiction of organization, organizational documents, certificate of good standing, certificate of incumbency, and employer identification number ("EIN");
• Beneficial ownership information for entities; and
• Photographs or digital images of government-issued identification documents submitted for KYC verification.

Apple Privacy Label: Name, User ID, Physical Address. Google Data Safety: Personal info (Name, Email address, Personal identifiers).

2.2 CONTACT DATA

• Current residential address or principal business address;
• Mailing address (if different from residential/business address);
• Primary and secondary telephone numbers (including mobile);
• Primary and secondary email addresses; and
• Preferred method of communication (email, telephone, mail).

Apple Privacy Label: Email Address, Phone Number, Physical Address. Google Data Safety: Personal info (Address, Phone number, Email address).

2.3 FINANCIAL DATA

• Annual income and net worth information provided in the Investor Questionnaire for accredited investor determination;
• Investment experience (years) and investment objectives;
• Bank account information, including institution name, account number, routing number, and SWIFT/BIC codes;
• Wire transfer instructions and confirmation records;
• Brokerage account statements, bank statements, tax returns, W-2 forms, and 1099 forms submitted for accredited investor verification under Rule 506(c);
• Third-party verification letters from licensed attorneys, CPAs, or registered broker-dealers;
• Capital account balances, contribution amounts and dates, redemption amounts and dates, and historical account activity;
• Management fee and performance allocation amounts charged to the investor's capital account; and
• NAV per Interest calculations and period-over-period return data.

Apple Privacy Label: Financial Info (Payment Info, Other Financial Info). Google Data Safety: Financial info (Purchase history, Other financial info).

2.4 TAX AND REGULATORY DATA

• IRS Form W-9 for U.S. persons;
• IRS Form W-8BEN for non-U.S. individuals; IRS Form W-8BEN-E for non-U.S. entities;
• ERISA status and Benefit Plan Investor classification;
• FATCA classification and documentation;
• Schedule K-1 data, including allocable shares of Fund income, gain, loss, deduction, and credit; and
• State tax withholding elections and applicable state filing nexus information.

2.5 COMPLIANCE AND DUE DILIGENCE DATA

• Results of identity verification checks conducted against government databases and commercial verification services;
• OFAC Specially Designated Nationals and Blocked Persons List screening results;
• EU consolidated sanctions list and other applicable international sanctions list screening results;
• Politically Exposed Person ("PEP") status disclosures;
• Source of funds and source of wealth documentation and representations;
• Enhanced due diligence records for high-risk investors; and
• Bad Actor disqualification certifications under Rule 506(d).

2.6 TECHNICAL DATA

• Internet Protocol (IP) address and approximate geolocation derived from IP address;
• Device type, device identifier, operating system name and version, and browser type and version;
• Screen resolution and language preferences;
• Session tokens and authentication credentials (encrypted); and
• Referral URL (the page from which you navigated to the Platform).

2.7 USAGE DATA

• Login and logout timestamps;
• Pages and sections of the investor portal accessed, including frequency and duration;
• Documents viewed, downloaded, or printed through the investor portal;
• Search queries entered within the Platform; and
• Error logs and crash reports generated during Platform use.

2.8 COMMUNICATIONS DATA

• Emails, messages, and correspondence sent to or received from the Manager;
• Records of telephone conversations (date, time, duration, and summary notes — calls are not recorded without consent);
• Meeting notes and records of in-person discussions; and
• Feedback, complaints, and inquiries submitted through the Platform or by other means.

4.1 SUBSCRIPTION AND ONBOARDING

• Processing subscription applications and determining eligibility for admission as a Member;
• Verifying accredited investor status through documentation review or third-party verification, as required under Rule 506(c);
• Conducting KYC identity verification and AML screening, including OFAC and sanctions list checks;
• Collecting and validating tax documentation (W-9, W-8BEN, W-8BEN-E); and
• Executing the Subscription Agreement and admitting the investor as a Member.

4.2 FUND ADMINISTRATION

• Maintaining individual capital accounts and recording contributions, redemptions, allocations, and expenses;
• Calculating the Fund's NAV and each Member's NAV per Interest on applicable valuation dates;
• Processing quarterly redemption requests, including verification of lock-up expiration and notice requirements;
• Calculating and applying the 2% annual management fee and 20% performance allocation subject to the high-water mark;
• Preparing and distributing quarterly account statements; and
• Coordinating with Interactive Brokers LLC for trade settlement, custody, and account reconciliation.

4.3 TAX REPORTING

• Preparing and filing the Fund's annual Form 1065 (U.S. Return of Partnership Income) with the IRS;
• Preparing and distributing individual Schedule K-1s to each Member;
• Calculating and applying U.S. withholding tax on allocations to non-U.S. Members, including FATCA withholding;
• Filing state partnership tax returns and processing state withholding for non-resident Members; and
• Providing estimated tax information to Members in advance of K-1 delivery where practicable.

4.4 INVESTOR COMMUNICATIONS

• Distributing quarterly or periodic investment letters discussing portfolio performance, market developments, and the Manager's outlook;
• Sending operational notices, including subscription confirmations, redemption confirmations, gate or suspension notifications, and amendments to Fund documents;
• Responding to investor inquiries, feedback, and information requests; and
• Delivering annual financial statements (audited, when available) within 90 to 120 days after fiscal year-end.

4.5 REGULATORY COMPLIANCE

• Filing Form D with the SEC and Blue Sky notice filings in applicable states;
• Maintaining the Fund's compliance with Section 3(c)(1) of the Investment Company Act (monitoring the 100 beneficial owner limit);
• Monitoring compliance with ERISA plan asset thresholds (maintaining Benefit Plan Investor participation below 25%);
• Responding to regulatory examinations, audits, subpoenas, court orders, and government inquiries; and
• Filing Schedule 13D/13G and Form 13F with the SEC if applicable ownership or AUM thresholds are reached.

4.6 PLATFORM SECURITY AND OPERATIONS

• Authenticating user identity and managing access credentials for the investor portal;
• Monitoring for unauthorized access attempts, suspicious activity, and potential security incidents;
• Maintaining system logs for audit trail and forensic analysis in the event of a security breach;
• Diagnosing and resolving technical issues, errors, and performance problems; and
• Improving the functionality, security, and user experience of the Platform based on aggregated usage patterns.

7.1 TECHNICAL SAFEGUARDS

• Encryption of all personal information in transit using Transport Layer Security (TLS) 1.2 or higher;
• Encryption of sensitive personal information at rest using AES-256 encryption or equivalent;
• Multi-factor authentication ("MFA") required for all access to the investor portal and internal administrative systems;
• Secure password policies requiring minimum length, complexity, and periodic rotation;
• Firewall protection, intrusion detection systems, and continuous network monitoring;
• Regular vulnerability assessments and penetration testing of Platform infrastructure; and
• Automated session timeout and forced re-authentication after periods of inactivity.

7.2 ADMINISTRATIVE SAFEGUARDS

• Role-based access controls ("RBAC") restricting access to personal information to authorized personnel on a strict need-to-know basis;
• Employee and contractor training on data privacy, information security, phishing awareness, and incident response procedures;
• Written information security policies and procedures reviewed and updated at least annually;
• Background checks for personnel with access to sensitive personal information; and
• Incident response plan with defined procedures for detection, containment, investigation, notification, and remediation.

7.3 PHYSICAL SAFEGUARDS

• Secure physical storage of paper documents containing personal information in locked, access-controlled facilities;
• Controlled physical access to offices and facilities where personal information is processed; and
• Secure disposal of physical media through cross-cut shredding or certified destruction services.

8.1 WHAT WE USE

The Platform uses only the following categories of cookies:

8.2 WHAT WE DO NOT USE

• Advertising cookies, pixels, or tags of any kind;
• Third-party analytics services (such as Google Analytics, Mixpanel, or Amplitude);
• Cross-site tracking technologies;
• Browser fingerprinting;
• Social media tracking pixels or share buttons; or
• Any technology that enables behavioral profiling, retargeting, or cross-context advertising.

8.3 YOUR COOKIE CHOICES

Because the Platform uses only essential session, authentication, and security cookies, there is no opt-out mechanism for these cookies — they are strictly necessary for the secure operation of the investor portal. The Platform does not respond to Do Not Track ("DNT") browser signals because no tracking occurs.