Privacy Policy

test (“we,” “us,” or the “Firm”) operates this private investor portal (the “Portal”) for prospective and existing limited partners and other authorized users. This Privacy Policy explains what information we collect, how we use and protect it, and the choices you have. We collect only what we need to provide the Portal and to meet our legal and compliance obligations.

Information we collect

• Identity and contact information you provide during onboarding, such as your name, email address, phone number, and mailing address.
• Investor and eligibility information, including accredited-investor or qualified-purchaser status, subscription details, and tax identifiers where required.
• Identity verification and compliance data collected to meet our know-your-customer (KYC) and sanctions-screening obligations, which may include a government-issued identification document and a photo, processed by our identity-verification provider.
• Financial and bank account information that you provide, or that we obtain with your authorization when you connect a bank account to fund your investment through our bank-linking provider.
• Electronic signature records. When you sign a document electronically, we record evidence of the signing, including your name and email, the version of the disclosure you accepted, the authentication method used, the date and time, your IP address and approximate location, technical information about your device and session, and cryptographic fingerprints of the document. We retain the signed document and this evidence as a permanent, tamper-evident record.
• Usage and security data, such as sign-in events, device and browser information, IP address, approximate location derived from your IP address, and records of the documents you access, download, and sign. Documents delivered to you are watermarked with your identity.
• Cookies and similar technologies. We use a strictly necessary cookie to keep you signed in securely. We do not use advertising or third-party tracking cookies.

How we use your information

• To operate the Portal and provide you access to fund materials, reports, and communications.
• To verify your identity and eligibility and to meet anti-money-laundering, sanctions, tax, and other legal and regulatory obligations.
• To administer subscriptions, capital contributions and funding, distributions, and investor relations.
• To secure the Portal, authenticate you, prevent fraud, and maintain an audit trail of security-relevant activity.

How we share information

We share information only as needed with service providers acting on our behalf, including our fund administrator, auditors, tax preparers, and legal counsel, and providers of identity verification, communications, bank linking and payments, electronic signature, and cloud hosting and storage. We also share information where required by law or regulation, or to protect our rights and the security of the Portal. We do not sell your personal information, and we do not use it for advertising.

International processing

Your information may be processed and stored on servers located in the United States and in other countries where we or our service providers operate. We take steps designed to ensure your information remains protected wherever it is processed.

Data security

We use administrative, technical, and physical safeguards designed to protect your information, including encryption in transit, encryption of sensitive stored credentials, access controls, multi-factor authentication, and logging. No system is perfectly secure, and we cannot guarantee absolute security.

Data retention

We retain information for as long as needed to provide the Portal and to satisfy our legal, regulatory, tax, and recordkeeping obligations. Executed agreements, electronic signature records and their audit trails, identity-verification and sanctions-screening results, and subscription, funding, and transaction records are retained on a long-term basis — in many cases permanently, or for the full period our legal, regulatory, and recordkeeping obligations require — and are maintained in a tamper-evident, append-only form that is not designed to be altered or erased. Activity and access logs are kept for a limited retention period and then removed. Where we no longer have a legal obligation or business need to retain information, we delete or de-identify it.

Your choices and rights

Depending on your jurisdiction, you may have rights to access, correct, delete, or restrict the use of your personal information. These rights are subject to our legal, regulatory, and recordkeeping obligations: in particular, we cannot delete executed agreements, electronic signature evidence, or compliance and transaction records that we are required to retain, and we will preserve any information that is subject to a legal hold. Contact us using the details below to make a request, and we will respond as required by applicable law.

Changes to this policy

We may update this Privacy Policy from time to time. When we do, we will post the updated version here and revise the date or notice as appropriate.

Contact

For privacy questions or requests, contact test investor relations through the contact option on the sign-in page.