Last Updated:  September 22, 2025

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1. Introduction

FINTOP, LLC (“FINTOP”, "we", "our", or "us") values your privacy. This Privacy Policy describes how we collect, use, disclose, and protect the personal information of visitors to our website ("Site"). This Privacy Policy applies to any individuals (“you” or “your organization”) who directly or indirectly invests, in funds or investment vehicles managed by us, or otherwise engage or interact with us, and to individuals accessing and using the Site. By using the Site, you consent to the practices described in this policy. Your use of the Site is subject at all times to our Terms of Use, which incorporates this Privacy Policy. Please note that the applicable privacy and data security laws and regulations of some countries will provide for special or deviating rules in relation to the processing of your personal data.

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2. Personal Information We Collect

FINTOP collects personal information directly from you and automatically when you use our Site. For purposes of this policy, “personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to an individual or household.  This does not include aggregated or de-identified information that is maintained in a form that cannot reasonably be used to infer information about, or otherwise be linked to, a particular individual or household.

 

The nature of the specific personal information we process will depend on our relationship with you and how you interact with us or use the Site. During our ordinary business activities, we may process various categories of personal information including but not limited to:

 

• Identifying Information: This may include information used to identify a specific individual, such as: given name(s), preferred name(s), nickname(s), academic grades or other titles, date of birth, age, place of birth, signature, nationality, passport or other national or government identity documents details, photographs, principal residential address, bills or correspondence showing address, identity risk assessment score and feedback.

• Contact Information: This may include postal address, telephone number, email address or other communication channel addresses.

• Personal Information: This may include marital status and Identifying and Contact Information about your spouse or partner, children, and dependents.

• Financial Information: This may include bank account details, credit card numbers, and income details, source of wealth information, source of funds details, money transfers including communications on bank transfers, information about assets or net worth, social security or national insurance number mandate details, investor profile data, investment preferences, risk appetite, restrictions and objectives, financial history, income, income requirements, liabilities and obligations, liquidity information, credit rating, investor classification, tax identification number, country of tax residence,  income verification data, financial details, and information needed for billing and payment processing purposes.

• Professional Information: This may include employer, employment status, position, job title and, where required or appropriate, employment history or information on qualifications.

• Interaction Information: This may include time, date and content of email, telephone or other communication, including communication for marketing purposes, marketing preferences and interaction, enquiries, disputes, investigations or other interaction with or activities concerning you, such as information regarding the use of any of our websites, fund data rooms or investor reporting portals, information or services requested by you, and records of any other interaction or communication with you.

• Automatically Collected Information: This may include personal information related to your use of our Site, including your IP address, any location information derived from your IP address, unique device identifier and device type, mobile network information, MAC address, domain, browser type, version, language, operating system and system settings, general location information and time zone, pages visited, browsing and click history, search history, time spent on the Site, and similar device and usage information collected via cookies or analytics tools or otherwise. We may also collect information from publicly available social media profiles and activity such as your LinkedIn profile.

• Sensitive Information: In certain circumstances, if so required by law, we may also collect, use, store and transfer sensitive data about you. In particular, as part of our due diligence processes, we may collect information as to: your political opinions and affiliations, if so required by law so that we can identify that you are, or are connected to, a politically exposed person; and your criminal records or alleged criminal activity, if so required by law as part of a background check.

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3. How We Collect Your Information

Depending on the nature of our relationship with you and your use of the Site, we may collect your personal information in various ways, including:

• Directly from you or your organization, including by completing subscription documents, investor questionnaires, applications or other forms (including, without limitation, any anti-money laundering, identification, and verification documentation), sending us emails or other written correspondence, via our website, fund data rooms and/or investor reporting portals (as applicable) or otherwise providing us with personal information in the course of our business relationship.

• Indirectly from third parties or other sources, including from your nominated financial institution or other representative (i.e., a broker or solicitor acting on your behalf), our affiliates, fund administrators, tax authorities, governmental agencies and supervisory authorities, fraud prevention and detection agencies, public records, anti-money laundering (“AML”), know-your-client (“KYC”) or other due diligence providers, credit reference agencies, background check agencies or from a counterparty involved in an investment or other business relationship with you.

• Through automated data collection tools, including Cookies, as defined in this Privacy Policy, and other analytics or tracking technology which may be used to collect certain data when you visit the Site or third party sites we direct you to in order to view our investor information or other electronic information about our products and services.

 

4. How We Use Your Information

Depending on the nature of our relationship with you, we may process personal information for the following purposes:

• Managing and Performing our Business Relationship: To enter into, perform, manage and administer your business relationship with us, e.g. by performing transactions and orders, selling or buying assets related to you or your organization, processing payments, executing transactions, managing payments, fees and charges and collecting and recovering debts owed to us, engaging vendors, service providers and suppliers and performing relevant contracts, performing accounting, auditing, billing and collection activities or providing you with any other services or things you may have requested, processing and responding to any enquiries you have submitted to us, receiving and handling complaints, requests or reports from you, engaging with governmental or regulatory bodies or other competent authorities, and notifying you about changes to our terms or this Privacy Policy.

• Fund Administration: If you or your organization are an investor in a fund managed or owned by us, to administer and manage such investment, including holding your information on the ownership register, using your contact details to send you notices of meetings and investor communications and using your financial information (e.g. bank account details) to make payment of redemption or distribution monies.

• Direct Marketing and Customer Relationship Management: To send you marketing information about products investment opportunities or services that we think may be of interest to you, invite you to conferences and events and handle your registration and attendance, update you on other news about us, conduct market research, surveys, and similar inquiries to help us understand trends, client and website visitor needs and to improve and enhance our products, services, systems, processes and technologies.
  You may opt out of direct marketing at any time by electing to unsubscribe in any direct marketing communication received from us or notifying us at the contact details set out below.  If you are a new investor, we will begin sharing your personal data with our affiliates for direct marketing purposes 30 days from the date of your initial investment in or commitment to a fund. When you are no longer our investor, we may continue to share personal information with our affiliates for direct marketing purposes, unless and until you elect to unsubscribe from any such communications.

• To Operate, Improve, and Maintain our Business: We use your personal information to operate, improve, and maintain our business and services, including our Site. We use personal information to enhance your user experience and to help us diagnose technical and service problems and administer our Site or respond to inquiries or provide support to users, customers, and clients. We also use personal information to compile and provide information about FINTOP, our investment strategies and services, and to enhance and inform our decision making, including but not limited to considering and implement mergers, acquisitions, reorganizations, bankruptcies, financings, investments, commercial agreements, and other business transactions, as well as inform tasks related to the administration of our general business, accounting, auditing, compliance, recordkeeping, legal and other internal functions.

• To Create Aggregated Data: We may create aggregated, de-identified or anonymized data from the personal information we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified or anonymized data and disclose it with third parties for our lawful business purposes, including to analyze, build and improve the Site and promote our business, provided that we will not disclose such data in a manner that could identify you.

• Security: To maintain and protect the security of our premises and facilities, IT systems, databases, websites or other digital infrastructure, including preventing and detecting security incidents, improving data security and protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity, service, testing and maintenance of our systems.

• Disputes and Enforcement: To establish, exercise and defend legal claims, investigate and resolve disputes and enforce our website terms of use and other agreements.

• Compliance: To ensure, monitor and audit compliance with our legal and regulatory obligations and our internal policies and procedures, such as performing our anti-money laundering checks, sanction and anti-terrorism screening, conflict of interest checks and other due diligence checks, international tax reporting requirements, record keeping, disclosures to tax or other regulatory authorities, enforcing and complying with legal judgements, and auditing relating to interactions, transactions and other compliance activities.

• Prevention and Detection: To prevent and detect crime, including fraud or criminal activity and misuses of our products or services.

 

Your personal information will always be processed in accordance with applicable privacy and data security laws and regulations and may be processed with your consent, upon your instruction, where necessary for the performance of the investment or other contract with you; to comply with our statutory obligations; to protect our or a third party’s legitimate interests, or as otherwise permitted by applicable privacy and data security laws and regulations.

 

You are typically not under a specific legal obligation to provide us with your personal information. However, unless we inform you that providing your personal information is optional, we will typically require your information to provide you or your organization with the requested products and services. If you do not provide such information, we may not be able to provide those products and services. Where personal information is required to satisfy a statutory obligation (including compliance with applicable AML, KYC or sanctions requirements) or a contractual requirement, failure to provide such information may result in your or your organization’s subscription in a fund being rejected or compulsorily redeemed or withdrawn, as applicable. Where there is suspicion of unlawful activity, failure to provide personal information may result in the submission of a report to the relevant law enforcement agency or supervisory authority.

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5. Sharing and Disclosure

We do not sell your personal information. We may disclose the personal information we collect with the following types of entities:

• Our affiliates, subsidiaries, vendors, and service providers. We may disclose personal information to our affiliates and subsidiaries, such as our investment fund affiliates, as well as service providers, vendors and others for business purposes and to perform functions on our behalf (such as those who process credit cards and payments, host, manage and service our data, provide technical support or logistics services, secure our Site, distribute emails, perform research and analysis, and administer certain services and features on our Site, as well as legal, financial and other professional advisors, accountants, fund administrators, prime brokers and executing brokers, lenders, custodians, auditors, counterparties, marketing and communications agencies, placement agents, client-facing application software, archiving services, business management software, telecommunications services and information technology services).

• Business partners and potential buyers (and their agents and advisors). We may disclose your personal information with actual or potential buyers (and their agents and advisors) in connection with any actual or proposed purchase, merger, acquisition, financing, reorganization, bankruptcy, receivership, sale of company assets or transition of service to another provider, provided that we inform the buyer or transferee that it must use your personal information only for the purposes disclosed in this Privacy Policy.

• Professional Agencies. With AML or KYC screening services, credit reference or background check agencies or other organizations where required by law or regulation to help us to conduct anti-money laundering and anti-terrorist financing and sanctions checks and to detect fraud and other potential criminal activity.

• Governmental and Regulatory Authorities and Law Enforcement. We may disclose personal information to other parties, including government entities and regulators, to the extent we determine necessary, including to: (i) comply with a government request or applicable law and to respond to legal process; (ii) prevent illegal uses of our Site or violations of our Site’s Terms of Use and our policies; (iii) defend ourselves against third party claims; and (iv) assist in fraud prevention or investigation (e.g., counterfeiting). 

• As required by Law. To any other person or organization where that is required under applicable law or regulation and permitted under applicable privacy and data security laws and regulations.

• With your consent. We may disclose your personal information to any other third party where you have provided your consent.

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6. Children’s Privacy

FINTOP does not knowingly collect or solicit personal information from children under the age of 13 years. If you are a child under the age of 13, please do not attempt to register for or otherwise use the Site or send us any personal information. If we learn we have collected personal information from a child under 13 years of age, we will delete that information as quickly as possible. If you believe that a child under 13 years of age may have provided personal information to us, please contact us at colleen@fintopcapital.com.

 

7. Cookies and Tracking Technologies

We use cookies and similar technologies to enhance user experience, analyze traffic, and understand usage patterns. You can control cookies through your browser settings. Please note that we do not necessarily recognize or respond to any signal which your browser might transmit through the “Do Not Track” feature your browser might have. If you wish to disable cookies on our Platform, you should not rely on any “Do Not Track” feature your browser might have.

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8. Data Security and Retention

Personal information held by us will be kept confidential and protected in accordance with under applicable privacy and data security laws and regulations and our internal policies and procedures. We use commercially reasonable efforts to ensure that personal information is kept secure, including a variety of technical, administrative, and organizational security measures, including encryption and authentication tools in certain circumstances, that are intended to protect your personal information. Please be aware that despite our efforts, no data security measures can guarantee security, and that no method of transmission over the internet is 100% secure. You can help keep your data safe by taking reasonable steps to protect your personal information against unauthorized disclosure or misuse.

 

We retain your personal information for as long as necessary to provide you with access to our Site or to perform our business or commercial purposes for collecting your personal information. When establishing a retention period for specific categories of data, we consider who we collected the data from, our need for the personal information, why we collected the personal information, and the sensitivity of the personal information. In some cases we retain personal information for longer, for example if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally. For example, we retain your device/IP data for as long as we need it to ensure that our systems are working appropriately, effectively, and efficiently.

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9. Third-Party Links

Our Site may contain links to third-party websites. A link to a third party’s website does not mean that we endorse it or that we are affiliated with it. We do not exercise control over third-party websites. You access such third-party websites or content at your own risk. You should always read the privacy policy of a third-party website before providing any information to that website. We are not responsible for the privacy practices or content of third-party websites.

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10. Your Rights and Choices

Depending on your jurisdiction, you may have rights under applicable data protection laws to:

• Access, correct, or delete your personal data

• Object to or restrict processing

• Withdraw consent (where applicable)

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To exercise these rights, please contact us at colleen@fintopcapital.com.

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11. International Transfers

If you are visiting our Site from outside the United States, your information may be transferred to and processed in the U.S., where privacy laws may differ. Additionally, because of the international nature of our business, your personal data may be transferred to countries outside of the country where you reside or where we provide services to you or your organization. As such other countries may not have the same level of data protection, we will comply with any requirements under applicable privacy and data security laws and regulations and apply appropriate safeguards reasonably designed to ensure the security and integrity of your personal information, regardless of where it is processed. Where required we will enter into data transfer agreements in accordance with applicable privacy and data security laws and regulations.

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12. Updates to This Policy

Applicable law and our practices change over time. If we decide to update our Privacy Policy, we will post the changes on our Site. If we materially change the way in which we process your personal information, we will provide you with prior notice, including via email to the address we have on file, or where legally required, request your consent prior to implementing such changes. We strongly encourage you to read our Privacy Policy and keep yourself informed of our practices. If you use the Site after any changes to the Privacy Policy have been posted, that means you agree to be bound by all of the changes.

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13. Contact Us

If you have any questions about this Privacy Policy or our privacy practices, please contact:

 

FINTOP, LLC

1621 Ensley Blvd, Nashville TN 37210

colleen@fintopcapital.com

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