Privacy Policy

1. Introduction

Pacilio Capital ("Company", "we", "us", or "our") is committed to protecting the privacy of individuals who visit our website (www.paciliocapital.com), submit inquiries, or engage with us as prospective or current investors (collectively, "Users", "you", or "your").

This Privacy Policy describes how we collect, use, store, share, and protect personal information in connection with our website and investor relations activities. By using our Site or providing us with your personal information, you consent to the practices described herein.

This Policy does not apply to information collected pursuant to a separate subscription agreement, limited partnership agreement, or other contractual relationship, which is governed by the terms of those agreements.

2. Information We Collect

2.1 Information You Provide Directly

We may collect personal information that you voluntarily provide to us, including:

• Contact Information: name, email address, mailing address, and telephone number
• Investor Qualification Data: accredited investor status, net worth or income representations, investment experience, and entity type
• Communication Records: the content of messages, inquiries, or correspondence you send to us
• Subscription Information: information submitted in connection with a formal investor inquiry, indication of interest, or subscription process
• Document Submissions: any documents voluntarily uploaded or transmitted to us, including identification documents required for AML/KYC compliance

2.2 Information Collected Automatically

When you visit our Site, we and our technology partners may automatically collect certain technical and usage information, including:

• Device and Browser Information: IP address, browser type and version, operating system, device identifiers
• Usage Data: pages visited, time spent on pages, links clicked, referring URLs, and navigation paths
• Cookies and Tracking Technologies: session cookies, persistent cookies, web beacons, and similar technologies

2.3 Information from Third Parties

We may receive information about you from third-party sources such as background check and identity verification providers, accredited investor verification services, professional referrals or intermediaries, and publicly available sources including LinkedIn and other professional networks.

3. How We Use Your Information

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

• Investor Relations: to evaluate investor eligibility, respond to inquiries, and provide information about our investment programs
• Regulatory Compliance: to verify your identity and accredited investor status; to comply with AML, KYC, and other applicable legal obligations
• Communications: to send you information about our offerings, market updates, investor reports, and other relevant materials
• Legal & Contractual Obligations: to fulfill obligations under subscription agreements, limited partnership agreements, or other investment documents
• Site Improvement: to analyze usage data and improve the functionality and content of our website
• Security: to detect, prevent, and address fraudulent or unauthorized activities
• Legal Defense: to establish, exercise, or defend legal claims

4. Legal Basis for Processing

To the extent that applicable law (including GDPR for EEA residents, or CCPA/CPRA for California residents) requires us to identify a legal basis for processing personal data, we rely on the following:

• Contractual Necessity: processing required to enter into or perform a contract with you
• Legitimate Interests: processing necessary for our legitimate business interests, including investor relations, marketing, and fraud prevention
• Legal Obligation: processing required to comply with applicable laws and regulations (e.g., AML/KYC, tax reporting)
• Consent: where we have obtained your explicit consent to process your information for a specific purpose

5. Information Sharing & Disclosure

5.1 Service Providers

We may share information with third-party service providers who perform functions on our behalf, including fund administrators, registered transfer agents, legal counsel, accounting firms, investor verification platforms, cloud hosting providers, and email communication platforms. These providers are contractually obligated to use your information only for the purposes for which it was disclosed.

5.2 Co-Investors and Syndication Partners

In connection with specific investment opportunities, we may share certain investor information with co-sponsors, co-investors, joint venture partners, or lenders as reasonably necessary to structure, close, and administer an investment.

5.3 Legal and Regulatory Disclosure

We may disclose your information when required to do so by law, court order, subpoena, or regulatory inquiry, or when we believe disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or comply with a legal obligation.

5.4 Business Transfers

In the event of a merger, acquisition, reorganization, or sale of all or substantially all of our assets, your personal information may be transferred as part of that transaction, subject to customary confidentiality protections.

6. Data Retention

We retain personal information for as long as necessary to fulfill the purposes described in this Policy, unless a longer retention period is required or permitted by applicable law:

• Investor and compliance records are retained for a minimum of seven (7) years from the date of collection, consistent with securities law and tax recordkeeping requirements
• Marketing and communication records are retained until you opt out or request deletion, subject to applicable legal holds
• Website usage data is retained for up to twenty-four (24) months

After the applicable retention period expires, we will securely delete or anonymize your personal information.

7. Cookies & Tracking Technologies

Our Site uses cookies and similar tracking technologies to enhance user experience and gather usage analytics. We use the following types of cookies:

• Essential Cookies: required for basic site functionality and security; cannot be disabled
• Analytics Cookies: used to collect aggregated information about how visitors use our Site (e.g., Google Analytics); no personally identifiable information is collected
• Preference Cookies: used to remember your settings and preferences for future visits

You may control the use of cookies through your browser settings. Note that disabling certain cookies may affect the functionality of the Site. We do not currently respond to "Do Not Track" browser signals.

8. Data Security

We implement commercially reasonable administrative, technical, and physical safeguards to protect your personal information against unauthorized access, disclosure, alteration, or destruction. These measures include encrypted communications (TLS/SSL), access controls, and data minimization practices.

However, no method of transmission over the Internet or electronic storage is completely secure. We cannot guarantee absolute security and encourage you to exercise caution when transmitting personal information electronically.

9. Your Privacy Rights

Depending on your jurisdiction, you may have certain rights with respect to your personal information, including:

• Right of Access: the right to request a copy of the personal information we hold about you
• Right to Correction: the right to request correction of inaccurate or incomplete information
• Right to Deletion: the right to request deletion of your personal information, subject to legal retention requirements
• Right to Restrict Processing: the right to request that we limit how we use your information in certain circumstances
• Right to Data Portability: the right to receive your information in a structured, machine-readable format
• Right to Object: the right to object to processing based on legitimate interests or for direct marketing purposes
• Right to Withdraw Consent: where processing is based on consent, you may withdraw consent at any time

To exercise any of these rights, please contact us using the information in Section 12. We will respond to requests within the timeframes required by applicable law (generally 30–45 days). We may require verification of your identity before processing a request.

10. California Privacy Rights (CCPA/CPRA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act ("CCPA") and the California Privacy Rights Act ("CPRA"), including:

• The right to know what personal information we collect, use, disclose, and sell
• The right to delete personal information we have collected, subject to exceptions
• The right to opt-out of the sale or sharing of your personal information (we do not sell personal information)
• The right to non-discrimination for exercising your privacy rights
• The right to correct inaccurate personal information
• The right to limit use of sensitive personal information

To submit a CCPA/CPRA request, please contact us at the address in Section 12. We will acknowledge your request within 10 business days and respond within 45 calendar days.

11. Children's Privacy

Our Site is not directed to individuals under the age of 18, and we do not knowingly collect personal information from minors. If we become aware that we have inadvertently collected personal information from a person under 18, we will promptly delete such information.

12. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:

13. Updates to This Policy

We reserve the right to modify this Privacy Policy at any time. When we make material changes, we will update the Effective Date at the top of this Policy. We encourage you to review this Policy periodically. Your continued use of the Site after any modification constitutes your acceptance of the updated Policy.

NOTE: This Privacy Policy is provided as a template for informational purposes and should be reviewed and customized by a licensed attorney familiar with applicable federal and state privacy laws, including CCPA/CPRA, GDPR (if applicable), and relevant securities regulations, before being published on your website.