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PRIVACY POLICY

Last Updated and Effective Date: January 14, 2026

1. INTRODUCTION AND SCOPE

This Privacy Policy describes how Rozario Global Management LLC (doing business as "Rozario Global") and its affiliates (collectively, “Rozario Global,” “we,” “our,” or “us”) treat personal information, including personal information collected on the websites where this Privacy Policy is located (the “Site”) or other platforms that direct to this Privacy Policy.

Important Note regarding Investor Data: This Privacy Policy applies to the use of our public-facing Site. It does not apply to current investors in Rozario Global funds. The collection, use, and disclosure of personal information for investors are governed by our Investor Privacy Notice and the specific subscription documents provided at the time of investment.

By using the Site, you acknowledge that you have read and understood this Privacy Policy.

2. WE COLLECT PERSONAL INFORMATION FROM AND ABOUT YOU

We collect personal information to operate our business, recruit talent, and comply with regulatory obligations. We collect this data from you directly, passively through your use of the Site, and from third parties.

A. Personal Identifiers

Data Collected: Name, address, phone number, email address, IP address, and log-in credentials (for password-protected investor portals).

Sources: Directly from you (forms, emails), recruiting agencies, and background check providers.

B. Professional or Employment Information

Data Collected: Employment history, CV/resume data, educational background, and professional references.

Sources: Job applications, LinkedIn, recruiters, and reference checks.

C. Internet or Other Electronic Network Activity

Data Collected: Browsing history, search history, interaction with our Site, device type, operating system, and duration of visit.

Sources: Cookies, web beacons, and server logs.

D. Commercial Information

Data Collected: Inquiries regarding investment strategies or specific requests for information.

Sources: Direct communication from you.

E. Geolocation Information

Data Collected: General location data derived from your IP address.

3. HOW WE USE YOUR INFORMATION

We process personal information only where we have a lawful basis to do so, including legitimate business interests, contractual necessity, or legal compliance.

  • Regulatory Compliance & Security (The ERA Mandate): As an SEC Exempt Reporting Adviser, we use personal information to comply with applicable legal and regulatory requirements (e.g., Anti-Money Laundering (AML) and Know Your Customer (KYC) regulations), to respond to court orders, and to cooperate with law enforcement or regulatory inquiries.
  • Service Provision: To provide you with access to the Site, including the secure Investor Portal.
  • Recruiting: To evaluate candidates for employment or partnership opportunities.
  • Security & Fraud Prevention: To detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and prosecute those responsible for that activity.
  • Business Operations: For internal research, technical debugging, and auditing.

4. SHARING OF PERSONAL INFORMATION

We do not sell your personal information. However, we may share your information with the following categories of third parties for business purposes:

  • Rozario Global Affiliates: We may share information within the Rozario Global corporate family for operational efficiency.
  • Service Providers: We disclose information to third-party vendors, consultants, and other service providers who perform functions on our behalf (e.g., IT support, cloud hosting, background checks, legal counsel, and fund administrators).
  • Legal & Regulatory Authorities: We will disclose information if we believe in good faith that such disclosure is necessary to (a) comply with relevant laws or to respond to subpoenas or warrants served on us; (b) protect or defend the rights, property, or safety of Rozario Global or any third party; or (c) assist in an investigation of fraud or other illegal activity.
  • Business Transfers: In the event of a merger, acquisition, reorganization, bankruptcy, or other sale of all or a portion of our assets, user information may be among the assets transferred.

5. INTERNATIONAL DATA TRANSFERS

Rozario Global is headquartered in the United States. If you are accessing the Site from outside the United States, please be aware that your information may be transferred to, stored, and processed in the U.S. where our servers are located. The data protection laws in the U.S. may differ from those of your country of residence.

By using the Site, you consent to the transfer of your information to the United States and the use and disclosure of your information as described in this Privacy Policy.

6. SECURITY MEASURES (LIMITATION OF LIABILITY)

We employ "Standard of Care" security measures designed to protect your personal information. However, no electronic transmission or storage of information can be guaranteed to be 100% secure.

You acknowledge that: (a) there are security and privacy limitations of the Internet which are beyond our control; and (b) the security, integrity, and privacy of any and all information and data exchanged between you and us through this Site cannot be guaranteed.

7. RIGHTS FOR INDIVIDUALS IN EUROPE (EEA) AND THE UK

If you are located in the European Economic Area (“EEA”) or the United Kingdom (“UK”), you have specific rights under the GDPR and UK GDPR, including:

  • Right of Access: To request copies of your personal data.
  • Right to Rectification: To correct inaccurate data.
  • Right to Erasure: To request that we delete your data ("Right to be Forgotten").
  • Right to Restriction: To limit the way we use your data.

Controller: For the purposes of EEA and UK data protection laws, Rozario Global Management LLC is the data controller.
Contact: To exercise these rights, please contact us at [email protected] (or your designated privacy email).

8. RIGHTS FOR INDIVIDUALS IN CALIFORNIA (CCPA/CPRA)

If you are a California resident, the California Consumer Privacy Act (CCPA) provides you with specific rights regarding your personal information.

A. No Sale or Sharing: Rozario Global does not sell your personal information. We do not "share" your personal information for cross-context behavioral advertising.

B. Your Rights:
  • Right to Know: You may request that we disclose what personal information we collect, use, disclose, and sell.
  • Right to Delete: You may request the deletion of your personal information, subject to certain legal exceptions (e.g., data required for regulatory record-keeping).
  • Right to Correct: You may request that we correct inaccurate personal information.
  • Non-Discrimination: We will not discriminate against you for exercising your privacy rights.

C. Verification: To protect your privacy, we will take steps to verify your identity before fulfilling your request. This may involve matching data points you provide with data we maintain.

To exercise these rights, email us at [email protected].

9. CHILDREN’S PRIVACY

The Site is not directed to individuals under the age of 18. We do not knowingly collect personal information from children under 13. If we become aware that a child under 13 has provided us with personal information, we will take steps to delete such information.

10. THIRD-PARTY LINKS

The Site may contain links to third-party websites. This Privacy Policy does not apply to those websites. We are not responsible for the privacy practices or content of third-party sites. We encourage you to read the privacy policies of any third-party sites you visit.

11. RECAPTCHA AND FRAUD PREVENTION

We may use the reCAPTCHA service provided by Google Inc. to protect our Site from spam and abuse. This includes the sending of your IP address and other data required by Google for the reCAPTCHA service. By using the reCAPTCHA service, you consent to the processing of data about you by Google in the manner and for the purposes set out in Google's privacy policy.

12. CONTACT INFORMATION

If you have any questions or concerns regarding this Privacy Policy, please contact us at:

Rozario Global Management LLC515 Madison Avenue, Suite 8116
New York, NY 10022
Attention: General Counsel / Privacy OfficerEmail: [email protected]

13. UPDATES TO THIS POLICY

Rozario Global reserves the right to modify this Privacy Policy at any time. If we make material changes, we will notify you by updating the date at the top of this policy and posting the revised version on the Site. Your continued use of the Site after any such changes constitutes your acceptance of the new Privacy Policy.