Privacy Policy

Last updated: August 1, 2026

Cinctive Capital Management LP and its affiliates and the funds and accounts sponsored or managed by them, including Cinctive Global Fund LP, Cinctive Global Fund Ltd., Cinctive Global Master Fund Ltd. (collectively, the “Adviser,” “Cinctive,” “we,” “us,” or “our”) are committed to protecting the confidentiality and security of information that we collect about individuals. This Cinctive Capital Privacy Notice (this “Privacy Notice”) describes our data collection and privacy practices with respect to the Personal Information we collect online and offline, including in the course of providing investment fund offerings to our investors and prospective investors (“Investors”) and in connection with the investment funds and accounts to which the Adviser acts as an investment manager (the “Funds”). By accessing this website and our services, you agree to the collection and use of Personal Information as described in this Privacy Notice and in our Terms and Conditions at https://www.cinctive.com/legal-disclaimer.

“Personal Information” as used herein means non-public information that is reasonably capable of being linked to or associated with an individual.

Unless otherwise stated in a supplemental notice, Cinctive is the controller of your Personal Information.

Types of Personal Information We Collect

We collect, and in the 12 months prior to the date of this Privacy Notice, we may have collected, and will continue to collect, all of the following categories of Personal Information about Investors and individuals, including our employees and job applicants (collectively, “Employees”), and business partners or commercial customers (collectively “B2B Contacts”) with which we interact, as applicable:

Contact information and other personal identifiers, such as name, signature, postal and email address, phone number, account name, Social Security number, tax ID number, drivers’ license and passport information.

Demographic and protected class information: about Employees, including age, sex, gender identity or expression, disability, citizenship status, marital status, national origin, religion, requests for family care, medical or parental leave, or disability status.

Internet or other electronic activity information: information about your computer, mobile device, browser, and cookie information.

Financial information: bank account or credit card information to process or receive payments.

Educational and professional background information: from Employees or Investors, degrees or certifications obtained, educational institutions attended, work and/or military histories; from B2B Contacts, records regarding your work (e.g., location, job title, seniority, etc.).

Audio & Video information: recordings of calls made to customer support; security camera footage if you visit one of our physical office locations.

Sources of Personal Information

We may collect Personal Information directly from an Investor, Employee, or B2B Contact directly, through the Funds’ administrator(s), including administrator employees, affiliates, agents or contractors, through an Investor’s agent (including the Investor’s financial adviser), or any other third-party who communicates with the Funds or the Adviser on an Investor’s, Employee’s, or B2B Contact’s behalf. The Adviser may also gather Personal Information about an Investor from subscription documents, transactions, interactive discussions (from which Personal Information about Employees or B2B Contacts may also be collected), and from time to time, banking references or consumer reporting agencies.

Purposes for Collection

We collect Personal Information to undertake the following data processing activities for Investors and individuals, including Employees and B2B contacts as specified:

administer human resources functions for Employees such as performance reviews and appraisals, sick leave, training, internal organizational charts, internal communications, and termination or retirement issues;
administer payroll, benefits, insurance, and other benefits-related functions for Employees;
manage communications including authorizing, granting and administering Employee access to or use of our systems, facilities, devices and records;
to investigate and resolve complaints, grievances or misconduct;
preparing for and acting in relation to inquiries, investigations or proceedings, by governmental, administrative, judicial or regulatory authorities, including civil litigation;
network and system security and access-related issues, including by protecting the company by monitoring internet access and use and emails transmitted;
managing customer relationship information, including records of products and services provided;
health and safety purposes;
defending legal claims; and
any other purposes relating to carrying out our business.

Legal Basis for Processing

When required by law, we will ensure there is a legal basis for the processing of your Personal Information. In most cases, our legal basis will depend on the Personal Information concerned and the specific context in which we collect it. The processing of your Personal Information will take place based on one (or more) of the following legal bases where and to the extent they exist or are permitted by applicable law:

Conclusion or performance of a contract: the processing is necessary for the performance of a contract we have with you, or to take steps (at your request) period to, and in anticipation of contractual obligations;

Legal obligations: the processing is necessary to comply with our legal obligations, including compliance with applicable laws, regulations, governmental and quasi-governmental requests, court orders or subpoenas;

Consent: the processing is based on your consent to the processing of your Personal Information for one or more specific purposes (e.g., marketing);

Legitimate interests: the processing is necessary to meet our legitimate interests, for e.g., to develop and improve our services for the benefits of our customers, so long as those legitimate interests are not overridden by your fundamental rights or interests;

Public information: personal information that has been made public lawfully

Disclosures of Personal Information

The Adviser and the Funds do not share any Personal Information about Investors with non-affiliated third-parties, except as necessary or appropriate in connection with the processing and administration of the Fund's investments, in connection with the Adviser’s and the Funds’ general business operations, or as otherwise required or permitted by law.

For example, Personal Information about Investors may be disclosed as necessary and in a manner required by applicable law, rules or regulations to process an Investor's subscription to a Fund, to the extent required in connection with an investment or transaction the Adviser proposes to make, or to the Adviser’s service providers that are subject to appropriate contractual obligations to maintain the confidentiality and security of the Adviser’s or the Funds’ records. Personal Information may also be disclosed to the extent an Investor specifically authorizes the disclosure, and for other purposes required or permitted by law, such as where reasonably necessary to prevent fraud, unauthorized transactions or liability, to prevent, detect or respond to data security vulnerabilities or incidents, or to respond to judicial process or subpoena.

From time to time the Adviser or a Fund may disclose Personal Information in a manner required by applicable law, rules or regulations to (i) a non-affiliated third-party that provides various services, including promotional services, on behalf of the Adviser or a Fund or (ii) a non-affiliated third-party financial institution, such as a prime broker, in connection with joint promotions by the Adviser or a Fund and the third-party. In such cases, it is the Adviser’s policy to enter into a contractual agreement with the recipient that (a) prohibits it from disclosing or using Investor Personal Information other than to carry out the services provided by the third party pursuant to the parties’ contract and (b) requires the recipient to maintain the security and confidentiality of the information in accordance with applicable laws, rules and regulations.

Adviser may disclose Personal Information about Employees or B2B Contacts to service providers to facilitate an employment relationship, to provide requested products or services, or to promote products or services or employment opportunities to a B2B Contact or Employee, respectively.

The following chart describes the categories of Personal Information that we disclosed to third parties for a business purpose in the 12 months prior to the date of this Privacy Notice:

The Adviser may disclose to the following third-parties an Investor’s Personal Information: fund administrator(s); outside legal counsel; consultants; accountants; auditors; regulators; and disaster recovery sites of the Adviser and the administrator(s). Except as described above or otherwise permitted by law, the Adviser will not disclose an Investor’s Personal Information to non-affiliated parties, unless the Investor has been given a notice of the possibility of such disclosure and a reasonable opportunity to “opt-out” of the disclosure of that information. The Adviser annually notifies Investors that are current Investors of this Privacy Notice.

We may have disclosed and may continue to disclose, employee Personal Information (including contact information, protected class information, educational and professional information) to payment processors and benefits providers, and may share job applicant Personal Information (including contact information) with credit reporting agencies and other entities that provide background checks.

When you are no longer an Investor, we may continue to share information about you as described in this notice. Please note that Cinctive has not sold your Personal Information in the 12 months prior to the date of this Privacy Notice.

Minors

Our website is not directed to individuals under the age of 18. Cinctive does not sell the Personal Information of minors, including minors under age 16.

Security

We implement and maintain reasonable safeguards to protect the security, confidentiality and integrity of Personal Information. This includes the implementation of reasonable administrative, technical and physical safeguards appropriate to the size of our business and the nature of the Personal Information we collect. While we take measures to safeguard Personal Information, such safeguards may not always be able to prevent all breaches of security.

Retention

We only keep your Personal Information for as long as necessary to fulfill purposes we collected it for, after which it will be deleted or archived unless we are required to keep it to comply with our legal obligations or for another legitimate and lawful purpose. To determine the appropriate retention period for Personal Information, we consider several factors, including: terms of our agreement with you, our legitimate interest, our legal obligations, and the amount and nature of your Personal Information. In some cases, we may anonymize your Personal Information so that you are no longer identifiable, in which case we may use the resulting information without further notice to you.

Accessibility

We are committed to ensuring that our communications are accessible to people with disabilities. To make accessibility-related requests or report barriers, please contact us at 833-224-5450 or compliance@cinctive.com.

Changes to Our Privacy Notice

The Adviser reserves the right to modify this Privacy Notice at any time and the date of the Privacy Notice will reflect the date of the most recent updates. If such changes occur, the Adviser will notify current Investors by posting the updated Privacy Notice to this webpage. Please note that this Privacy Notice supersedes all prior Privacy Notices, including any prior notices that may be included in an Offering Memorandum.

Complaints

If you have any concerns or complaints about the way your Personal Information is processed, please contact compliance@cinctive.com. You may also have a right to complain to a data protection or other competent authority with jurisdiction over privacy and data protection law in the country you live or work, or in the country where you believe an issue in relation to the processing of your Personal Information has arisen.

RIGHTS FOR INDIVIDUALS IN CALIFORNIA

Individuals who are residents of California have certain consumer rights under applicable California privacy laws but which may be subject to certain limitations and/or restrictions, including certain exceptions relating to Personal Information subject to financial privacy laws. If you are a California resident, under California law you may have the following rights with respect to certain data:

California Consumer Privacy Act

Right to request disclosure of information we collect or disclose about you. You can submit a request to us for the following data regarding the Personal Information we have collected about you in the 12 months prior to our receipt of your request (a “request to know”):

The categories of Personal Information we have collected.
The categories of sources from which we collected the Personal Information.
The business or commercial purposes for which we collected the Personal Information.
The categories of third parties with which we disclosed the Personal Information.
The categories of Personal Information we disclosed for a business purpose, and for each category identified, the categories of third parties to whom we disclosed that particular category of Personal Information.
The specific pieces of Personal Information we collected.

Right to request the deletion of Personal Information we have collected from you. Upon request, we will delete the Personal Information we have collected about you, except for situations where specific information is necessary for us to provide you with a product or service that you requested; perform a contract we entered into with you; maintain the functionality or security of our systems; or comply with or exercise rights provided by the law.

The law also permits us to retain specific information for our exclusively internal use, but only in ways that are compatible with the context in which you provided the information to us or that are reasonably aligned with your expectations based on your relationship with us.

How can you make a request to exercise your rights? To submit requests to know or delete you may contact us at 833-224-5450 or compliance@cinctive.com.

A consumer may use an authorized agent to submit a request on the consumer’s behalf. When using an authorized agent, Cinctive requires that you provide the authorized agent written permission to do so and verify their own identity and agent status with Cinctive. If you would like to designate an authorized agent to make a request on your behalf, please email compliance@cinctive.com. If you require this notice in an alternative accessible format, please email compliance@cinctive.com.

When you make a request to know or delete your Personal Information, we will take steps to verify your identity. These steps may include asking you for Personal Information, such as your name, address, or other information we maintain about you. If we are unable to verify your identity with the degree of certainty required, we will not be able to respond to the request. We will notify you to explain the basis of the denial. For requests to know and requests to delete, Cinctive will confirm receipt of the request within 10 business days and provide information about how the business will process the request, and Cinctive will respond within 45 days with an option to extend an additional 45 days provided Cinctive gives you notice and explanation. If you wish to exercise any of your rights under this section, you may submit your request through any of these methods: (i) email compliance@cinctive.com; or (ii) call 833-224-5450. If you have the capability to call collect, you may do so.

Shine the Light

California's "Shine the Light" law, Civil Code section 1798.83, requires certain businesses to respond to requests from California residents asking about the business' practices related to disclosing Personal Information to third parties for the third parties' direct marketing purposes. We do not disclose Personal Information to third parties for such purposes.

Do Not Track

We do not track or allow others to track our website visitors’ online activity over time and across third-party websites or online services. Our website does not respond to do not track signals.

How to Contact Us

For questions or other communications regarding this Privacy Notice, we can be contacted at 833-224-5450, or by email to compliance@cinctive.com.

ALL UAE AND ADGM PARTIES

Please see the separate privacy notice on the following pages.

UAE AND ADGM Privacy Notice

(last updated August 2026)

Cinctive Capital Management LP and its affiliates (collectively, the “Adviser,” “Cinctive,” “we,” “us,” or “our”), specifically including the branch office located in the Abu Dhabi Global Market (the “ADGM Branch”), are committed to protecting the confidentiality and security of information that we collect about individuals. This Privacy Notice for the ADGM Branch (“ADGM Privacy Notice”) describes our data collection and privacy practices with respect to the Personal Information we collect online and offline, including in the course of providing investment fund offerings to our investors and prospective investors (“Investors”) and in connection with the investment funds and accounts to which the Adviser acts as an investment manager (the “Funds”). By accessing this website and our services, you acknowledge that you have been given notice of our collection and use of your Personal Information as described in this Privacy Notice and in our Terms and Conditions.

“Personal Information” as used herein means non-public information that is reasonably capable of being linked to or associated with an individual.

Unless otherwise stated in a supplemental notice, Cinctive is the controller of your Personal Information. If you are an employee of one of Cinctive’s affiliates, such as the ADGM Branch, that affiliate will be the controller with regard to any personal information that you provide as part of your recruitment and/or employment by that affiliate. With regard to know-your-customer checks of Investors, Cinctive acts as a processor and maintains its own privacy notice (see above).

Types of Personal Information We Collect

We may collect the following types of Personal Information about Investors, employees and job applicants (collectively, “Employees”), and representatives of business partners or commercial customers (collectively, “B2B Contacts”) with whom we interact, as applicable. See Annex 1 for a more detailed list of possible information types.

Contact information and other personal identifiers: including name, signature, postal and email address, phone number, account name, Social Security number, tax ID number, drivers’ license, and passport information.
Demographic and protected class information: including age, sex, gender identity or expression, disability, citizenship status, marital status, national origin, religion, requests for family care, medical or parental leave, or disability status. Where Investors provide documentation to support KYC checks, we may also collect information about nationality and religion to the extent present on such documents.
Internet or other electronic activity information: including usage of computers, mobile devices, browsers, and cookies.
Financial information: including bank account or credit card information to process or receive payments.
Educational and professional background information: from Investors and Employees, including degrees or certifications obtained, educational institutions attended, work and/or military histories; from B2B Contacts, including records of location, job title, and seniority.
Audio & Video information: including recordings of meetings where such recording is advised in advance.

Sources of Personal Information

We may collect Personal Information directly from an Investor, Employee, or B2B Contact through the Funds’ administrator(s), including administrator employees, affiliates, agents, or contractors; through an Investor’s agent (including the Investor’s financial adviser); through the ADGM Branch and other affiliates; or through any other third-party who communicates with the Funds or the Adviser on behalf of an Investor, Employee, or B2B Contact. The Adviser may also gather Personal Information about an Investor from subscription documents, transactions, interactive discussions (from which Personal Information about Employees or B2B Contacts may also be collected), and from time to time, banking references or consumer reporting agencies.

Purposes for Collection

We collect Personal Information to undertake the following data processing activities for Investors and individuals, including Employees and B2B Contacts. See Annex 2 for a more detailed list of possible purposes.

To administer human resources functions for Employees such as performance reviews and appraisals, sick leave, training, internal organizational charts, internal communications, and termination or retirement issues;
To administer payroll, benefits, insurance, and other benefits-related functions for Employees;
To manage communications including authorizing, granting and administering Employee access to or use of our systems, facilities, devices, and records;
To investigate and resolve complaints, grievances, or misconduct;
To prepare for and act in relation to inquiries, investigations, or proceedings by governmental, administrative, judicial, or regulatory authorities, including civil litigation;
To address issues related to network and system security and access, including by protecting the company by monitoring internet access and use and emails transmitted;
To manage customer relationship information, including records of products and services provided;
To defend legal claims;
For health and safety purposes; and
For any other purposes related to carrying out our business.

Legal Basis for Processing

Conclusion or performance of a contract: the processing is necessary for the performance of a contract we have with you, or for taking steps (at your request) prior to and in anticipation of contractual obligations.

Legal obligations: the processing is necessary to comply with our legal obligations, including compliance with applicable laws, regulations, governmental and quasi-governmental requests, court orders, or subpoenas.

Consent: the processing is based on your consent to the processing of your Personal Information for one or more specific purposes (e.g., marketing).

Legitimate interests: the processing is necessary to meet our legitimate interests (e.g., to develop and improve our services for the benefit of our customers), so long as those legitimate interests are not overridden by your fundamental rights or interests.

Public information: the processing concerns only personal information that has been made public lawfully.

Vital interests: the processing is necessary to protect your vital interests or those of another natural person.

Disclosures of Personal Information

The Adviser and the Funds do not share any Personal Information about Investors with non-affiliated third parties, except as necessary or appropriate in connection with the processing and administration of the Funds’ investments, in connection with the general business operations of the Adviser and the Funds, or as otherwise required or permitted by law.

Personal Information about Investors may be disclosed as necessary and in a manner required by applicable law, rules, or regulations to process an Investor’s subscription to a Fund, to the extent required in connection with an investment or transaction the Adviser proposes to make, or to the Adviser’s service providers that are subject to appropriate contractual obligations to maintain the confidentiality and security of the Adviser’s or the Funds’ records. Personal Information may also be disclosed to the extent an Investor specifically authorizes the disclosure, as well as for other purposes required or permitted by law, such as where reasonably necessary to prevent fraud, unauthorized transactions, or liability; to prevent, detect, or respond to data security vulnerabilities or incidents; or to respond to judicial process or subpoena.

From time to time the Adviser or a Fund may disclose Personal Information in a manner required by applicable law, rules, or regulations to (i) a non-affiliated third party that provides various services, including promotional services, on behalf of the Adviser or a Fund, or (ii) a non-affiliated third party financial institution, such as a prime broker, in connection with joint promotions by the Adviser or a Fund and the third party. In such cases, it is the Adviser’s policy to enter into a contractual agreement with the recipient that (a) prohibits it from disclosing or using Investor Personal Information other than to carry out the services provided by the third party pursuant to the parties’ contract, and (b) requires the recipient to maintain the security and confidentiality of the information in accordance with applicable laws, rules, and regulations.

The following chart describes the categories of Personal Information that we have previously disclosed to third parties for a business purpose:

The Adviser may disclose to the following third parties an Investor’s Personal Information: the Fund administrator(s); outside legal counsel; consultants; accountants; auditors; regulators; and disaster recovery sites of the Adviser and the Fund administrator(s). Except with regard to the categories of third parties described above or as otherwise permitted by law, the Adviser will not disclose an Investor’s Personal Information to non-affiliated parties, unless the Investor has been given a notice of the possibility of such disclosure and a reasonable opportunity to “opt-out” of the disclosure of that information.

We may have disclosed, and may continue to disclose, Employees’ Personal Information (including contact information, protected class information, and educational and professional information) to payment processors and benefits providers; we also may share job applicants’ Personal Information (including contact information) with credit reporting agencies and other entities that provide background checks.

Transfer of Personal Information to other Countries or Jurisdictions

Information you give us may be transferred to other countries or jurisdictions outside the country or jurisdiction in which it is collected. In such circumstances, Cinctive will take such organizational, contractual, and legal measures as are required under applicable legislation or regulations to ensure that your Personal Information is processed only for the purposes mentioned above and that, where required, adequate levels of protection have been implemented in order to safeguard your Personal Information. These safeguards may include the entry into standard contractual clauses as imposed by the relevant supervisory authority.

Minors

Our website is not directed to individuals under the age of 18. Cinctive does not sell any Personal Information.

Security

We implement and maintain reasonable safeguards to protect the security, confidentiality, and integrity of Personal Information. This includes the implementation of reasonable administrative, technical, and physical safeguards appropriate to the size of our business and the nature of the Personal Information we collect. While we take measures to safeguard Personal Information, such safeguards may not always be able to prevent all breaches of security.

Retention

We only keep your Personal Information for as long as necessary to fulfil purposes for which we collected it, after which it will be deleted or archived unless we are required to keep it to comply with our legal obligations or for another legitimate and lawful purpose. To determine the appropriate retention period for Personal Information, we consider several factors, including the terms of our agreement with you, our legitimate interest, our legal obligations, and the amount and nature of your Personal Information. In some cases, we may anonymize your Personal Information so that you are no longer identifiable, in which case we may use the resulting information without further notice to you.

Accessibility

Changes to Our Privacy Notice

The Adviser reserves the right to modify this Privacy Notice at any time, and the date of the Privacy Notice will reflect the date of the most recent updates. If such changes occur, the Adviser will notify current Investors by posting the updated Privacy Notice to this webpage. Please note that this Privacy Notice supersedes all prior Privacy Notices, including any prior notices that may be included in an Offering Memorandum.

Complaints

If you have any concerns or complaints about the way your Personal Information is processed, please contact compliance@cinctive.com.

Individuals may also have the right to lodge a complaint about the processing of Personal Information with the appropriate data protection authority or other competent authority with jurisdiction over privacy and data protection law in the country you live or work, or in the country where you believe an issue has arisen in relation to the processing of your Personal Information.

Where the Abu Dhabi Global Market’s Office of Data Protection has oversight, you may lodge a complaint with the Commissioner of Data Protection’s Office:

The Office of Data Protection

Level 3, ADGM Building

ADGM Square, Al Maryah Island

P.O. Box 111999

Abu Dhabi, UAE

data.protection@adgm.com

Where the UAE Data Office has oversight, you may lodge a complaint with the UAE Minister of State for Artificial Intelligence, Digital Economy & Remote Work Applications Office (https://ai.gov.ae/ar/personal-data-protection-law/), who may receive complaints pending the operation of the UAE Data Office.

We encourage you to first raise any complaints directly with us.

Rights for Individuals in Other Jurisdictions

Individuals in certain jurisdictions may have certain data subject rights. These rights vary, but to the extent they apply, they may include all or some of the rights set out below. To understand what rights are available to you, please contact us directly.

The Right to Withdraw Consent: Where your consent is relied upon as the lawful ground for processing your Personal Information, you may have the right to withdraw your consent at any time. Any withdrawal of consent must:
- be in writing (either in hard copy or electronic form);
- communicated to compliance@cinctive.com; and
- clearly set out the processing activity pertaining to your withdrawn consent.

The withdrawal of consent will not affect the validity of the processing of Personal Information that occurred prior to the withdrawal of your consent. Depending on the nature of the processing for which consent is withdrawn, this may affect your ability to receive certain products, services, or functionality.

The Right to Access, Rectification, and Erasure: You may request certain details about how your Personal Information is being processed, including but not limited to the types of Personal Information being processed and whether decisions are made about you using automated processing or profiling. In some cases, you may also request that your Personal Information be corrected or erased.
The Right to Object: In some cases, you may object to any processing.
The Right to Restriction of Processing: In some cases, you may restrict the processing of your Personal Information.
The Right to Request Transfer of Personal Data/Portability of Personal Data: In some cases, you may have the right to receive your personal data in a machine-readable format, provided that it is technically feasible to do so and such disclosure will not infringe the rights of any other natural person.
The Right to Object to any Decision Based Solely on Automated Processing: You may object to any decision that is made based solely on automated processing, including profiling, which produces legal consequences upon you or other seriously impactful consequences. You may also require such decisions to be reviewed manually.

The rights described herein are not absolute and may vary depending on the jurisdiction(s) in which you and/or relevant entities are located. We reserve all rights available to us at law in this regard. Please note that, due to our commitment to not attempt to reidentify individuals for deidentified data, any requests will only cover your Personal Information. If you wish to exercise any of these rights, please contact us directly.

Automated Decision-Making and Profiling

We do not use your Personal Information in the context of automated decision-making or profiling.

Do Not Track

We do not track or allow others to track our website visitors’ online activity over time and across third-party websites or online services. Our website does not respond to do not track signals.

How to Contact Us

For questions or other communications regarding this Privacy Notice, contact us at 332.208.6800 or by email at compliance@cinctive.com.

Annex 1

WHAT PERSONAL INFORMATION DO WE COLLECT FROM YOU?

Cinctive collects personal information about you in various ways when you visit our website; interact with us in connection with our business; communicate with us; or provide your information in connection with Fund operations, Investor onboarding, compliance, due diligence, or our relationships with service providers, counterparties, or B2B Contacts.

Such information may include some or all of the following Personal Information:

Personal Details

Your name, title, job title, employer or company name, business address, residential address where relevant, date of birth, email address, telephone number, nationality, and location.
Identification and verification information, including passport details, national ID details, tax identification numbers, and similar documentation, collected for onboarding, know-your-customer (“KYC”), anti-money laundering, sanctions, and compliance purposes.
Information relating to your role, authority, or relationship to an Investor, prospective Investor, counterparty, service provider, or other B2B Contact, including evidence of authority to act, signatory status, and ownership or control information.
Records of communications, meetings, and correspondence with our representatives, including emails, call logs, meeting notes, contact history, and other business communications.
Copies of signatures, initials, and execution details where required for agreements, subscription documents, side letters, confirmations, instructions, or signatory records.

Investor and Due Diligence Information

Information provided in subscription documents, investor questionnaires, KYC forms, anti-money laundering forms, tax forms, and related due diligence materials.
Information relating to the directors, officers, shareholders, ultimate beneficial owners, authorised signatories, representatives, and contact persons of Investors.
Source of funds, source of wealth, sanctions screening results, politically exposed person checks, and other compliance-related information, where required.
Information relating to investment experience, suitability, eligibility, classification, or status, where relevant and permitted by law.
Transaction and account-related information, including subscription amounts, redemption requests, transfer requests, distribution details, payment information, and banking instructions.

B2B Contact Information

Business contact details of B2B Contacts, including names, job titles, employer details, business telephone numbers, business email addresses, and office addresses.
Information relating to the services provided by, or relationship with, a B2B Contact, or the organisation they represent.
Due diligence, onboarding, and compliance information relating to B2B Contacts and their representatives.
Records of meetings, correspondence, instructions, negotiations, and other interactions with B2B Contacts.

Financial and Transaction Information

Bank account details, payment details, settlement instructions, and other financial information provided in connection with investments, distributions, subscriptions, redemptions, transfers, or service arrangements.
Records relating to transactions, holdings, allocations, distributions, payments, and other investment or operational activity.
Tax residency information, tax identification numbers, and related declarations where required for legal, regulatory, or reporting purposes.

Online and Technical Information

When using our website or communication systems, we or our third-party service providers may collect:
- date and time of access;
- browser type and version;
- device type and operating system;
- IP address;
- pages viewed and navigation paths; and
- referring website addresses or technical login information.
Information relating to your use of our website, portals, email communications, and other digital systems, including interaction, access, and security-related information.
Cookie, analytics, and similar technical data, where permitted and subject to applicable settings and requirements.

Compliance and Risk Management Information

Information obtained from public sources, regulatory filings, sanctions databases, watchlists, corporate registries, litigation searches, and other compliance or due diligence sources.
Information relating to legal or regulatory status, restrictions, investigations, adverse media results, or other risk indicators, where relevant to our compliance obligations or legitimate business needs.
Internal assessments, risk ratings and records created as part of compliance reviews, onboarding reviews, due diligence, or governance processes.

Special Categories of Personal Information

We do not actively seek to collect special categories of Personal Information or sensitive Personal Information, but we may process limited sensitive information where this is contained in documents provided to us or otherwise necessary for compliance purposes. This may include:

nationality or place of birth, where visible on identification documents collected for verification or compliance purposes;
information which may reveal political exposure or connections, where this arises in the course of sanctions, anti-money laundering, or politically exposed person screening; and
biometric identifiers such as photographic images contained in identity documents, but only to the extent necessary for verification or compliance procedures.

Annex 2

HOW CINCTIVE MAY USE YOUR PERSONAL DATA

Client, Investor, and B2B Contact Relations

To communicate with current, prospective, and former Investors, shareholders, fund participants, counterparties, service providers, and other B2B Contacts.
To respond to enquiries, requests for information, due diligence questionnaires, and complaints.
To provide updates, reports, notices, statements, and other communications that we are legally or contractually required to provide.
To manage communications with representatives, authorised signatories, directors, shareholders, beneficial owners, and other relevant contacts of Investors and B2B Contacts.
To liaise with prime brokers, custodians, fund administrators, auditors, legal advisers, banks, and other professional counterparties in connection with our investment management activities.
To manage relationships with vendors, consultants, and other business partners.
To contact prospective Investors and other relevant B2B Contacts in connection with lawful business development activities.

Onboarding, KYC, and Due Diligence

To verify identity in line with know your customer, anti-money laundering, sanctions, counter-terrorist financing, and related regulatory requirements.
To conduct due diligence before entering into relationships with Investors, service providers, counterparties, or other B2B Contacts.
To collect and maintain accurate records of authorised contacts, signatories, directors, officers, shareholders, beneficial owners, and representatives of Investors and B2B Contacts.
To respond to onboarding, KYC, and due diligence requests from fund administrators, custodians, banks, brokers, auditors, legal advisers, and institutional counterparties.
To carry out legal, regulatory, financial, and operational diligence in relation to Investors, counterparties, service providers, and B2B Contacts.
To screen against sanctions lists, politically exposed person databases, and other compliance sources where required.

Relationship Management and Investment Operations

To administer and manage fund documents, subscription documents, redemption requests, transfer requests, side letters, managed account arrangements, and other investment-related documentation.
To process subscriptions, redemptions, transfers, allocations, distributions, capital calls, payments, and related transactions.
To maintain registers, records, and internal documentation relating to Investors, counterparties, service providers, and B2B Contacts.
To manage communications with authorised representatives and designated contacts.
To manage corporate approvals, governance processes, and regulatory filings relating to Cinctive entities and branches.
To administer and perform contracts with service providers, consultants, and other business partners.
To manage accounts payable and receivable, invoicing, banking instructions, and financial controls.
To maintain books, records, and audit trails required for our investment management and operational activities.

Digital Platforms and Communications

To operate and maintain our website, portals, email systems, and other digital communications channels.
To administer and support the operation of our digital platforms, including troubleshooting, testing, analytics, research, system administration, and security monitoring.
To ensure our website and digital content are presented effectively for your device, browser, and operating system.
To monitor usage, access, and interactions for functionality, security, fraud prevention, and service improvement purposes.
To communicate by email, telephone, video conference, and other electronic means in connection with our business and regulatory activities.
To maintain contact databases and communication records.
To work with service providers who supply the technical infrastructure supporting our digital systems and communications, acting on our behalf and under our instructions.

Regulatory and Legal Compliance

To comply with applicable laws and regulations, including those relating to financial services, anti-money laundering, sanctions, tax reporting, market conduct, books and records, and corporate governance.
To comply with the requirements of relevant regulators and supervisory authorities, including where applicable the U.S. Securities and Exchange Commission, the Commodity Futures Trading Commission, the Abu Dhabi Global Market Financial Services Regulatory Authority, and other applicable authorities.
To respond to lawful requests from regulators, governmental bodies, courts, auditors, and law enforcement agencies.
To maintain compliance records, insider or restricted lists where applicable, and other internal controls required by law or regulation.
To detect, prevent and investigate fraud, misconduct, conflicts of interest, cyber incidents and other unlawful or improper activity.
To comply with applicable tax, accounting, and reporting obligations, including Investor classification and reporting requirements.
To carry out risk management, compliance testing, internal audits, and investigations.
To establish, exercise, or defend legal claims and to protect our rights, property, and business.

Marketing and Business Development

To send communications about our business, investment capabilities, market views, and other relevant updates, where permitted by law.
To manage marketing preferences, subscriptions, opt-ins, and opt-outs.
To invite relevant individuals to meetings, calls, or other business-related engagements.
To conduct business development analysis and relationship management activities.
To assess interest in our products and services and improve the relevance of our communications.
To maintain records of interactions with prospective Investors and other market participants.

Third-Party Service Providers

To share Personal Information, where necessary, with service providers such as fund administrators, custodians, prime brokers, executing brokers, banks, technology providers, cloud or hosting providers, compliance vendors, auditors, legal advisers, consultants and other professional advisers.
To ensure that third-party handling of Personal Data is subject to appropriate security and contractual safeguards.
To manage contractual, operational, and compliance relationships with professional service providers and infrastructure providers.
To coordinate with counterparties, advisers, and service providers in connection with fund operations, onboarding, reporting, and other business activities.

Reporting and Analytics

To analyse aggregated and, where appropriate, anonymised data for business planning, operational improvement, and strategic decision-making.
To generate internal management information, risk reports, compliance reports, and regulatory submissions.
To prepare Investor, operational, financial, and regulatory reports.
To support investment analysis, performance assessment, and operational oversight.
To improve our systems, controls, communications, and services.
To maintain audit trails, logs, and other records used for governance, oversight, and business continuity purposes.