Legal

PRIVACY POLICY

Last Updated: April 15, 2025

This Privacy Policy explains how we collect, utilize, and maintain nonpublic personal information about our investors and others who access our websites and/or otherwise communicate with us, as required under U.S. federal legislation and other applicable law. This Privacy Notice applies only to investors who are individuals investing for personal, family or household purposes, and such other persons as may be required by law, and is subject to change.

We are committed to protecting your privacy and maintaining the confidentiality and security of your personal information. Therefore, we have prepared this Privacy Policy to help you understand how we handle the personal information about you that we collect and how we use that information.

Categories of Information We Collect and May Disclose

We use the personal information collected about you to provide you with better service or comply with laws and regulations. We may collect nonpublic personal information about you from the following sources:

• Applications, investor questionnaires, investment management or advisory agreements, subscription agreements or other forms (for example, name, address, Social Security number, assets, and income);
• Records of financial transactions in which you participated (such as purchases, sales, account balances, inquiries, etc.); and
• Other interactions with us or our affiliates (such as discussions or other contacts with our staff, via telephone, written correspondence, and electronic media).

We do not sell or rent investor information. We do not disclose nonpublic personal information we collect about you to nonaffiliated parties without your consent, except under situations below or as permitted by law:

To service providers in connection with the administration and servicing of investors, which may include attorneys, administrators, custodians, consultants, accountants, auditors, and other professionals. We may also share information in connection with the servicing or processing of investor transactions;

• To persons assessing our compliance with industry standards (e.g., professional licensing authorities, compliance consultants);
• To respond to a subpoena or court order, judicial process or regulatory inquiry;
• To protect against fraud, unauthorized transactions (such as money laundering), claims or other liabilities; and

Upon your authorization to disclose such information to persons acting in a fiduciary or representative capacity on your behalf.

If you prefer that we not disclose nonpublic personal information about you to nonaffiliated third parties or to affiliated entities, you may opt out of these disclosures by directing us not to make those disclosures (other than disclosures permitted by law) by providing written notice to the firm at compliance@legalist.com or at the following address: 58 W. PORTAL AVE., NO. 747, SAN FRANCISCO, CA 94127, ATTN: COMPLIANCE DEPARTMENT.

Under California Civil law, Californians are entitled to request information relating to whether a business has disclosed personal data to third parties for direct marketing purposes. Californians who wish to request further information about our compliance with this statute or who have questions, more generally, about this Privacy Policy and our privacy commitments and should contact us at the foregoing addresses.

In addition, individuals in certain other U.S. and non-U.S. jurisdictions may have certain data subject rights. These rights vary, but they may include the right to (i) request access to and rectification or erasure of personal data, (ii) restrict or object to the processing of personal data, and (iii) obtain a copy of personal data in a portable format. Individuals may also have the right to lodge a complaint about the processing of personal data with a data protection authority.  If you wish to exercise any of these rights, please email at the address above.

‍Security of Information

As a matter of policy, we require that all employees, financial professionals, and companies providing services on our behalf keep client information confidential.

We maintain physical and electronic safeguards to protect investor information. Third parties with whom we share investor information are provided such information on a “need to know” basis and must agree to follow appropriate standards of security and confidentiality.

The Privacy Policy applies to both current and former investors. We may disclose nonpublic personal information about an investor to the same extent as for a current investor.

To use and disclose your personal data as described above, personal data be transferred internationally, including from the European Economic Area to the United States and other countries that the European Union has deemed do not provide “adequate” protection for personal information. We apply the same standards of privacy protection (as set out in this Privacy Policy) regardless of the international transfer or processing of such data. By providing us your personal data and using our websites, you consent to such international transfers, as we deem appropriate, including transfers from the European Economic Area to the United States and other countries deemed not to provide “adequate” protections by the European Union.

Changes to this Privacy Policy

We reserve the right to change this Privacy Policy at any time. In such instances, we will notify investors of any material change to this policy before implementing the change.

Further Information

The examples contained within this notice are illustrations and are not intended to be exclusive. This notice complies with U.S. federal law regarding privacy. You may have additional rights under other foreign or domestic laws that may apply to you. If you have any questions about this notice, please contact us by telephone at +1-415-570-7878 or email at compliance@legalist.com.