Privacy Policy

1. Who We Are

Sea Point Capital Partners, LP is an alternative asset manager. For purposes of this Privacy Policy, Sea Point Capital is the data controller of personal information collected through the Site.

If you have questions about this Privacy Policy, contact us at compliance@seapoint.capital.

2. Information We Collect

We collect a limited amount of personal information through the Site, in the following categories:

Information you provide directly

• Contact information you enter into the contact form on our Site: your name, email address, and (where applicable) phone number, company or entity name, job title, and country of residence.
• Inquiry information you provide: the inquiry type you select, the message you write, and — for investor-related inquiries — high-level context about your investor profile and prior investment experience.
• Mailing list opt-in: where you opt in to receive updates from us, we record that opt-in.

Information collected automatically

• Technical data: IP address, browser type, operating system, device type, pages viewed, referring URL, and timestamps.
• Cookies and similar technologies: as described in our Cookie Policy.

Information we do not collect through the Site

We do not collect tax returns, W-2s, brokerage statements, CPA verification letters, government identification, or other accredited-investor verification or KYC/AML documents through the Site. Any such information that may be required in connection with an investment is collected separately by Sea Point Capital or its Fund Administrator outside of the Site, and is governed by separate notices and the applicable subscription documents.

3. How We Use Personal Information

We use the personal information we collect for the following purposes:

• Responding to inquiries you submit through the Site.
• Communicating with you, including following up on your inquiry and, where you have opted in, sending updates and research.
• Evaluating prospective relationships, including the nature, sophistication, and context of inquiries from prospective investors and their advisors.
• Operating, securing, and improving the Site, including analytics and performance monitoring (subject to your cookie choices).
• Complying with applicable law and responding to lawful requests.
• Detecting, preventing, and responding to fraud, abuse, and security incidents.

4. Legal Bases for Processing (EU / UK)

If you are located in the European Economic Area or the United Kingdom, the legal bases on which we process your personal information are:

• Legitimate interests, including responding to inquiries, evaluating prospective relationships, securing the Site, and conducting analytics, balanced against your rights and interests.
• Consent, for non-essential cookies, marketing communications, and mailing list subscriptions. You may withdraw consent at any time.
• Legal obligations, where processing is required to comply with applicable law.
• Pre-contractual steps, where you have asked us to take steps prior to entering into any potential agreement.

5. How We Share Personal Information

We share personal information only as follows:

• Service providers acting on our behalf to operate the Site or our business, such as hosting providers, analytics providers, email/communications providers, and IT and security vendors. These providers are bound by contractual obligations to handle data only as instructed and to implement appropriate safeguards.
• Professional advisors, including outside legal and compliance counsel, where reasonably necessary.
• Regulators, law enforcement, and courts, where required by law or where we believe in good faith that disclosure is necessary to comply with legal obligations or to protect our rights, our personnel, or the public.
• Successors in a corporate transaction, in connection with a merger, sale, reorganization, or similar transaction, subject to confidentiality protections.

We do not sell your personal information. We do not share your personal information for cross-context behavioral advertising.

6. International Transfers

Personal information we collect through the Site is processed primarily in the United States and may be processed in other jurisdictions where our service providers operate. Where required by applicable law, we use appropriate safeguards for international transfers, such as standard contractual clauses.

7. Retention

We retain personal information collected through the Site only for as long as is reasonably necessary for the purposes for which it was collected, to maintain appropriate business records, and to comply with applicable legal obligations. Inquiry records are typically retained for the duration of any prospective or actual business relationship and for a reasonable period thereafter. Mailing list opt-in records are retained while your subscription is active. Server and analytics logs are retained according to our internal data retention schedule. Specific retention periods vary by data category and may be longer where required by law.

8. Your Rights

Depending on where you live, you may have rights with respect to your personal information, including:

• The right to access personal information we hold about you.
• The right to request correction of inaccurate or incomplete information.
• The right to request deletion of your personal information, subject to legal exceptions.
• The right to object to or restrict certain processing.
• The right to data portability with respect to information you have provided.
• The right to withdraw consent for processing that is based on consent.
• The right to lodge a complaint with your local data protection authority (for EU/UK residents).
• The right to opt out of the "sale" or "sharing" of personal information as those terms are defined under California law (we do not sell or share personal information in this sense).

To exercise any of these rights, contact us at compliance@seapoint.capital. We may need to verify your identity before fulfilling your request. We will respond within the timeframes required by applicable law.

9. Cookies

We use cookies and similar technologies on the Site. For details, including the categories of cookies we use and how to manage your preferences, see our Cookie Policy.

10. Security

We maintain administrative, technical, and physical safeguards designed to protect personal information collected through the Site. These include encryption of data in transit (TLS), access controls, monitoring, and incident response procedures. No system is perfectly secure. If we become aware of a security incident that creates a material risk to your rights, we will notify affected individuals and regulators as required by applicable law.

11. Children

The Site is not directed to children, and we do not knowingly collect personal information from individuals under the age of 18. If you believe we have collected such information, contact compliance@seapoint.capital and we will take appropriate action.

12. Third-Party Links

The Site may contain links to third-party websites. We are not responsible for the privacy practices of third parties. Review their privacy notices before providing personal information.

13. Changes to this Policy

We may update this Privacy Policy from time to time. When we do, we will revise the "Last updated" date above. Material changes will be communicated through the Site or by other reasonable means.

14. Contact

For privacy inquiries or to exercise any of the rights described in this Privacy Policy, contact compliance@seapoint.capital.