Privacy Policy

Effective Date: July 1, 2025

Alliance Global Capital Fund, LP (referred to as “we,” “us,” or “our”) is committed to protecting your privacy. This Privacy Policy explains how we collect, use, share, and safeguard personal information on our website and through related online services (the “Site”). It also describes your rights regarding your personal information and how you can contact us with any questions or requests. By using our Site, you agree to the practices described in this Privacy Policy.

Information Collection

Personal Information You Provide: We collect personal information that you voluntarily provide to us through our Site, such as when you fill out forms, subscribe to our newsletter, create or use an investor portal account, or contact us for inquiries. This information may include your name, email address, phone number, mailing address, login credentials (for account holders), and any other information you choose to provide (for example, information you submit in a contact form or investor registration form). If you are an investor or seeking to invest, we may also collect additional details required for regulatory or legal purposes (such as identity verification information or financial details) through secure channels or our investor portal.

Information Collected Automatically: When you visit or interact with our Site, we automatically collect certain information about your device and usage of the Site. This may include your IP address, browser type, device type, operating system, referring/exit pages, and dates/times of access. We also collect information about your interactions with the Site, such as the pages you view, links clicked, and other actions taken. This data is collected through cookies and other tracking technologies (described below) and helps us understand how users use our Site, personalize your experience, and improve our services.

Use of Information

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

  • Providing and Improving Services: To operate, maintain, and improve our website, products, and services. For example, we use your information to process your requests or transactions, to facilitate your access to the investor portal, and to respond to inquiries or support requests.
  • Communications: To communicate with you about our fund, services, and updates. We may send administrative emails (for example, account or policy updates) and, with your consent or as permitted by law, marketing communications such as newsletters or event invitations. You can opt-out of marketing emails as described below.
  • Analytics and Personalization: To analyze Site usage and performance so we can understand how visitors access and use the Site. This helps us personalize content and features, and improve user experience. For instance, we may use insights from analytics to optimize our webpages or tailor our communications.
  • Security and Fraud Prevention: To protect the integrity and security of our Site, business, and users. We may use information to verify identity, detect and prevent fraud, unauthorized access, or other illegal activities, and enforce our terms and policies.
  • Legal and Regulatory Compliance: To comply with applicable laws, regulations, and legal obligations. As a U.S.-based investment firm, we may use personal information to fulfill our regulatory requirements (including those of the Securities and Exchange Commission (SEC) and other financial regulators) and to respond to lawful requests by public authorities or court orders.
  • Other Business Purposes: To carry out other legitimate business purposes, such as internal record-keeping, auditing, reporting, and to perform functions described to you at the time of collection or with your consent.

Cookies and Tracking

Our Site uses cookies and similar tracking technologies to enhance your experience, understand user activity, and for security and analytics purposes.

What Cookies Are: Cookies are small text files placed on your computer or device when you visit a website. They allow the website to recognize your browser and remember certain information (such as user preferences or login status). We use both session cookies (which expire when you close your browser) and persistent cookies (which remain on your device for a set period or until deleted).

How We Use Cookies: We use cookies and related technologies for a variety of functions:

  • Essential Cookies: These cookies are necessary for the Site to function properly. For example, if our Site has user login or investor portal features, essential cookies help authenticate users and maintain your logged-in session.
  • Analytics Cookies: We use third-party analytics services, such as Google Analytics, to collect information about how visitors use the Site. Analytics cookies gather data on pages visited, time spent on pages, browser and device information, and website traffic patterns. This information is aggregated and does not directly identify individuals; it helps us improve the Site’s performance and content. (Learn more about Google Analytics on Google’s site. You can opt out of Google Analytics data collection by installing the Google Analytics Opt-out Browser Add-on.)
  • Preference and Functionality Cookies: These cookies allow our Site to remember choices you make (such as language or region selection) and provide enhanced, more personalized features.

We may also use other tracking technologies like web beacons (clear GIFs) or pixel tags in our emails or on the Site to track whether you have opened emails or interacted with certain content. This helps us gauge the effectiveness of our communications and marketing campaigns.

Third-Party Tracking and Do-Not-Track: Third parties (such as analytics providers or embedded content providers) may set their own cookies and similar technologies on our Site to collect information about your online activities over time and across different websites. For example, our Site may include content or scripts from service providers that collect usage data (for instance, a map feature or a social media sharing button might record your interaction). We do not control these third-party tracking technologies, and their use is governed by the privacy policies of the third parties. Currently, our Site does not respond to “Do Not Track” (DNT) signals or similar browser preferences, due to the lack of an industry standard. You can configure your browser settings to decline cookies or alert you when cookies are being placed. However, if you disable or reject certain cookies, parts of the Site (especially login or interactive features) may not function fully.

Your Choices for Cookies: Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. You may also clear or delete existing cookies through your browser settings. Additionally, to opt out of Google Analytics, you can use the tool mentioned above. Keep in mind that disabling cookies may affect your user experience on our Site.

Sharing of Information

We do not sell your personal information to third parties for their own marketing or commercial purposes. We only share your information in the following circumstances and with appropriate safeguards:

  • Service Providers: We share personal information with trusted third-party service providers who perform services on our behalf. These service providers assist us with various business operations, such as website hosting, data storage, email delivery, analytics, customer service, marketing, or operating our investor portal and other features. We only provide these companies the information they need to perform their specific services, and we require them to protect your information and use it only for the purposes we specify.
  • Affiliates: We may share personal information with our affiliated companies (for example, companies under common ownership or control) as needed for business, operational, or administrative purposes. Any such affiliate will handle your information in accordance with this Privacy Policy or with practices at least as protective.
  • Legal Compliance and Protection: We may disclose personal information if required to do so by law or legal process, or if we have a good-faith belief that such action is necessary to (i) comply with applicable laws, regulations, subpoenas, or court orders; (ii) respond to requests from government authorities or regulators (including the SEC or other supervisory bodies); (iii) protect our rights, property, and safety or that of our investors, users, or others; or (iv) investigate and help prevent security threats, fraud, or other malicious activity. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction.
  • Business Transfers: In the event of a contemplated or actual merger, acquisition, joint venture, financing, reorganization, bankruptcy, receivership, or sale of all or part of our business or assets, personal information may be disclosed or transferred to the prospective or actual purchaser or other relevant third parties. We will ensure any such third party is bound to respect your personal information in a manner consistent with this Privacy Policy.
  • With Your Consent or At Your Direction: We may share your information with other parties if you request or direct us to do so, or otherwise with your explicit consent. For example, if you ask us to introduce you to a partner organization or if you use a feature on the Site that requires sharing information with a third party, we will do so with your permission.

Aside from the purposes described above, we do not share personal information with unaffiliated third parties for their own direct marketing. In other words, we will not disclose your contact details to outside companies for their independent marketing or promotional use without your consent.

User Rights

You have certain rights and choices regarding your personal information. We strive to honor these rights and provide you with control over your data, in accordance with applicable U.S. laws such as the California Consumer Privacy Act (CCPA) and other privacy regulations.

Access and Correction: You have the right to request information about the personal data we hold about you and to request access to or a copy of that information. You also have the right to request that we correct or update any inaccurate or outdated personal information. If you maintain an account on our Site or investor portal, you may be able to log in and update some of your personal details directly. Otherwise, you can contact us as described in the “Contact Information” section below to exercise these rights.

Deletion: You can request that we delete personal information we have collected from you, subject to certain exceptions. For example, we may need to retain certain information for legal compliance (such as record-keeping obligations for investors or transactions), to complete transactions you have requested, to detect or prevent fraud, or for internal business purposes consistent with the context in which the information was provided. If deletion is required, we will take reasonable steps to erase your personal data (or de-identify it in accordance with applicable law).

California Privacy Rights: If you are a resident of California, you are entitled to specific rights under the CCPA (as amended by the CPRA). These include the rights listed above (to know/access, correct, and delete your personal information) as well as:

  • Right to Know What is Collected and Disclosed: The right to request details about the categories of personal information we have collected about you, the categories of sources of that information, the business or commercial purpose for collection, the categories of third parties with whom we share personal information, and specific pieces of personal information we hold about you. You also have the right to request a report of what personal information has been disclosed for a business purpose, and if applicable, what personal information has been “sold” or “shared” (as those terms are defined by California law) and to whom.
  • Right to Opt Out of Sale or Sharing: We do not sell personal information for monetary consideration. In the event our use of certain analytics or advertising cookies is interpreted as a “sale” or “sharing” of personal information under California law, you have the right to opt out. You may exercise this right by contacting us or by using any “Do Not Sell or Share My Personal Information” link or mechanism that may be available on our Site. Once we receive and confirm a verifiable opt-out request, we will refrain from selling or sharing your personal information as requested (unless you later provide consent to do so).
  • Right to Limit Use of Sensitive Information: We generally do not collect sensitive personal information (such as Social Security numbers or precise geolocation) through our Site except as required for investor onboarding or compliance. If we ever collect any sensitive personal information for reasons beyond what is necessary to provide services, California residents would have the right to limit our use or disclosure of such information to only those purposes allowed by law.
  • Non-Discrimination: We will not discriminate against you for exercising any of your privacy rights. If you choose to exercise your rights under the CCPA (for example, by opting out of data sharing or requesting deletion), we will not deny you services, charge you a different price, or provide a different quality of services just because you exercised your rights. In certain cases, however, exercising deletion or limiting use of some information may limit our ability to provide certain services (for instance, we cannot provide an investor account without certain necessary information).

Opting Out of Marketing Communications: If you subscribe to our newsletter or otherwise receive promotional communications from us, you can opt out at any time. To unsubscribe from marketing emails, simply click the “unsubscribe” link in any email you receive or contact us requesting removal. Please note that even if you opt out of marketing messages, we may still send you transactional or informational communications as needed (such as account notifications or responses to your inquiries).

How to Exercise Your Rights: To exercise any of your rights described above, please contact us using the information provided in the “Contact Information” section of this Policy. For certain requests (like access, deletion, or CCPA-related requests), we will need to verify your identity to ensure we are protecting your information from unauthorized access. This verification process may involve asking you to provide certain information or complete a verification step. If you have an authorized agent making a request on your behalf, we may require proof of the agent’s authorization and your identity. We will respond to privacy requests within the timeframes required by law.

Data Security

We take the security of your personal information seriously. Alliance Global Capital Fund, LP has implemented reasonable administrative, technical, and physical security measures designed to protect your personal data from unauthorized access, use, alteration, and disclosure. These measures include, for example, secure server environments, encryption of data where appropriate, firewall and access controls, and restricted access to personal data on a need-to-know basis for our employees and service providers.

While we strive to protect your information, please understand that no method of transmitting data over the internet or storing data electronically can be guaranteed to be 100% secure. We cannot ensure or warrant the absolute security of any information you transmit to us or that we store. You share and transmit information at your own risk. In the event of a data breach or security incident affecting your personal information, we will notify you and the appropriate authorities as required by applicable law and regulation (including SEC regulations and state breach notification laws).

We also encourage you to take precautions to protect your personal data when using the internet. For instance, keep your account login credentials confidential and do not share them with others. If you believe that your interaction with us or your account information is no longer secure (for example, if you feel that the security of your account has been compromised), please contact us immediately using the contact information below.

We will retain your personal information only for as long as necessary to fulfill the purposes for which it was collected, or as required by law or regulation. The retention period may vary depending on the nature of the data and the context under which it was collected. For example, for legal and compliance reasons, we may keep information about investors for a certain number of years as mandated by financial regulations. When we no longer have a legitimate need or legal obligation to retain your personal information, we will securely dispose of it or anonymize it.

Children’s Privacy

Our Site and services are intended for adults and business professionals, especially those interested in our investment fund. We do not knowingly collect or solicit personal information from children under the age of 13 (or under 16 in certain jurisdictions where additional protections apply), and our Site is not directed to minors. In accordance with the U.S. Children’s Online Privacy Protection Act (COPPA), if we learn that we have inadvertently collected personal data from a child under 13 without verifiable parental consent, we will delete that information as quickly as possible. If you believe that a minor may have provided us with personal information, please contact us so that we can take appropriate steps to remove the data from our records.

Policy Updates

We may update or revise this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or for other operational reasons. When we make changes to this Policy, we will update the “Effective Date” at the top of this page to indicate when the revisions take effect. If changes are significant or materially affect your privacy rights, we will take additional steps to notify you: for example, by posting a prominent notice on our website, and/or by sending an email notification to users who have provided us with an email address, prior to the change becoming effective, as required by applicable law.

We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your information. Your continued use of our Site or services after any changes to this Privacy Policy have been posted will signify your acceptance of the updated terms, to the extent permitted by law.

Contact Information

If you have any questions, comments, or concerns about this Privacy Policy or our privacy practices, or if you wish to exercise your rights regarding your personal information, please contact us. We are here to help and will respond to your inquiries in a timely manner.

Contact us at:

Mail: Privacy Officer, Alliance Global Capital Fund, LP, 1345 Avenue of the Americas, 33rd Floor, New York, NY 10105, USA

Please include your name and contact information and a detailed description of your request or question. If you are contacting us to exercise a privacy right (such as a data access or deletion request), please describe the nature of your request and the specific information in question, and we will guide you through any verification process and next steps.

Thank you for trusting Alliance Global Capital Fund, LP with your information. We value your privacy and are committed to safeguarding your personal data.

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