Privacy Policy

Overview

This policy sets out how Privatus Capital Ltd. and its affiliated entities, and their respective officers, employees and agents ("we", "our", "us") handle your personal information in accordance with applicable laws, including the British Virgin Islands Data Protection Act 2021.

In addition to this policy, our website Terms of Use govern your use of our site and incorporate this privacy policy.

The offering documents and subscription forms of funds managed by us (Privatus Capital funds), each domiciled in the British Virgin Islands, set out how the relevant fund collects, processes and maintains personal data of investors pursuant to the BVI Data Protection Act 2021. To the extent there is a conflict between this privacy policy and any privacy notice specific to a Privatus Capital fund applicable to you in your capacity as an investor, the relevant fund-specific privacy notice prevails.

Why do we collect personal information?

We collect your personal information to:

• provide or assist in providing products or services to you;
• manage those products or services or your investment in them;
• facilitate communications, reports, updates, or investor relations activity;
• offer information about our products or services;
• perform associated or incidental business functions;
• consider and process employment or contractor applications;
• protect our legal and commercial interests; and
• comply with laws and regulations, including anti-money laundering, counter-terrorism, and financial-crime legislation.

If you do not provide the information we request, or choose not to identify yourself, we may be unable to provide certain products, services, or information.

What personal information do we collect?

We collect information about you and your interactions with us, including:

If you provide information about another individual, you must ensure you are permitted to do so and that they have consented to our handling of their data as set out in this policy.

How do we use your information?

We may use your personal information to:

• support your interactions with us;
• provide requested information, services or products;
• maintain accuracy and relevance of our records;
• onboard you as a client, investor or employee;
• facilitate investment transactions and due diligence;
• operate, manage and improve our business;
• enforce our rights or protect the rights of third parties;
• comply with laws, regulations, and internal policies;
• manage business transitions such as reorganizations, acquisitions or financings.

We may also use your information to send product updates, newsletters, or marketing materials where legally permitted. You may unsubscribe at any time.

For employment applicants, information is used for assessing suitability, conducting checks, and complying with legal obligations.

Disclosure of Personal Information

We may share your information with third parties and affiliated entities, including:

• fund service providers (administrators, custodians, registries, trustees);
• financial institutions and payment providers;
• technology and cloud service providers;
• legal, tax, audit and professional advisers;
• distributors, intermediaries or agents;
• background check and identity-verification providers;
• regulators, government bodies, or law enforcement as required;
• potential buyers or investors in our business (in diligence or transactions).

You consent to such disclosures without requiring separate, case-by-case approval.

Cross-Border Transfers

Your information may be transferred to or stored in jurisdictions including the British Virgin Islands, United States, Canada, Singapore, Trinidad and Tobago, the Cayman Islands, the European Union, or others where our service providers operate.

Different jurisdictions may have different levels of data protection. By providing your information, you consent to these transfers and acknowledge we are not required to ensure overseas recipients comply with the privacy laws of your country.

Storage and Security

Your information may be held in physical or electronic form, either at our premises or via our service providers. We take reasonable steps to protect your information from misuse, loss, unauthorized access, modification or disclosure.

However, the internet is not a fully secure medium. To the maximum extent permitted by law, we exclude liability arising from data transmission issues, unauthorized third-party access, or breaches occurring outside our reasonable control.

Website Information

When you visit www.privatuscapital.io or related portals, we or our service providers may collect information about your visit as described above.

We may use cookies, clear gifs, web beacons and similar technology. You may configure your browser to reject cookies, but certain functionality may not work. For full details on the cookies and tracking technologies we use, please see our Cookie Policy.

If our website contains links to third-party sites, those sites are not covered by this policy. You should review their privacy policies separately.

Accessing or Updating Your Information

If you wish to access or correct the personal information we hold about you, or make a complaint about our handling of your information, contact us at:

contact@privatuscapital.io

We may require identity verification and may charge a reasonable fee to cover administrative costs. In limited circumstances permitted by law, we may decline requests and will explain the reasons.

If you believe your information has been subject to a data breach, please notify us immediately.

Changes to This Policy

We may update this privacy policy from time to time. Any material changes will be posted on our website.

This policy was last updated on 1 August 2025.