Privacy Policy

Last Updated: January 26, 2026

1. Information We Collect

1.1 Personal Information

We collect personal information that you provide to us directly, including but not limited to:

• Name, address, email address, and telephone number
• Social Security number or tax identification number
• Date of birth and government-issued identification
• Financial information including income, net worth, assets, and investment experience
• Employment and professional information
• Bank account and wire transfer information
• Accredited investor status documentation

1.2 Automatically Collected Information

When you visit our website, we may automatically collect:

• IP address and device information
• Browser type and operating system
• Pages visited and time spent on our website
• Referring website addresses
• Cookies and similar tracking technologies

1.3 Information from Third Parties

We may obtain information from third parties, including:

• Background check and verification services
• Credit bureaus and financial institutions
• Publicly available databases
• Anti-money laundering and sanctions screening services

2. How We Use Your Information

We use the information we collect for the following purposes:

• Investment Management: To manage your investment account, process transactions, and provide investment services
• Regulatory Compliance: To comply with legal and regulatory requirements, including anti-money laundering (AML) and Know Your Customer (KYC) obligations
• Communication: To provide account statements, tax documents, performance reports, and other investor communications
• Due Diligence: To verify accredited investor status and conduct background checks as required
• Service Improvement: To improve our services, website functionality, and investor experience
• Marketing: To provide information about investment opportunities, subject to applicable regulations and your preferences
• Security: To protect against fraud, unauthorized access, and other security threats

3. Information Sharing and Disclosure

3.1 Service Providers

We may share your information with trusted third-party service providers who assist us in operating our business, including:

• Fund administrators and custodians
• Auditors and legal counsel
• Technology and cybersecurity providers
• Marketing and communication service providers

3.2 Legal and Regulatory Requirements

We may disclose your information when required by law, regulation, or legal process, including:

• Responses to subpoenas, court orders, or other legal processes
• Compliance with SEC, FINRA, CFTC, or other regulatory requirements
• Cooperation with law enforcement or government agencies
• Protection of our legal rights and interests

3.3 Business Transfers

In connection with any merger, acquisition, reorganization, or sale of assets, your information may be transferred to the acquiring entity, subject to confidentiality obligations.

3.4 With Your Consent

We may share your information with third parties when you have given us explicit consent to do so.

4. Data Security

We implement comprehensive security measures to protect your information, including:

• Encryption of data in transit and at rest
• Multi-factor authentication and access controls
• Regular security audits and vulnerability assessments
• Employee training on data protection and confidentiality
• Physical security measures for our offices and data centers
• Incident response and breach notification procedures

Despite our security measures, no method of transmission over the internet or electronic storage is completely secure. We cannot guarantee absolute security of your information.

5. Data Retention

We retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, comply with legal and regulatory requirements, resolve disputes, and enforce our agreements. Investment-related records are typically retained for a minimum of seven years after account closure, as required by securities regulations.

6. Your Privacy Rights

Depending on your jurisdiction, you may have the following rights regarding your personal information:

• Access: Request access to the personal information we hold about you
• Correction: Request correction of inaccurate or incomplete information
• Deletion: Request deletion of your information, subject to legal and regulatory retention requirements
• Restriction: Request restriction of processing under certain circumstances
• Portability: Request transfer of your information to another service provider
• Objection: Object to processing of your information for certain purposes
• Opt-Out: Opt out of marketing communications at any time

To exercise these rights, please contact us using the information provided below. Please note that we may need to verify your identity before processing your request, and certain requests may be subject to regulatory limitations.

7. California Privacy Rights

California residents have additional rights under the California Consumer Privacy Act (CCPA), including:

• The right to know what personal information is collected, used, shared, or sold
• The right to delete personal information held by businesses
• The right to opt-out of the sale of personal information
• The right to non-discrimination for exercising CCPA rights

Note: Clarity Capital Limited. does not sell personal information to third parties.

8. International Data Transfers

If you are accessing our services from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States. By using our services, you consent to the transfer of your information to the United States and other countries where we operate.

10. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to enhance your experience on our website. You can control cookie preferences through your browser settings. However, disabling cookies may limit your ability to use certain features of our website.

11. Third-Party Links

Our website may contain links to third-party websites. We are not responsible for the privacy practices of these external sites. We encourage you to review the privacy policies of any third-party websites you visit.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of material changes by posting the updated policy on our website with a new "Last Updated" date. Your continued use of our services after such changes constitutes acceptance of the updated Privacy Policy.

13. Regulatory Framework

As a registered investment adviser, we are subject to privacy regulations under:

• Regulation S-P (Privacy of Consumer Financial Information)
• Investment Advisers Act of 1940
• Gramm-Leach-Bliley Act (GLBA)
• State securities regulations