Privacy Policy

Overview

KapStone Digital Associates LLC ("KapStone," "we," "our," or "us") is committed to protecting the privacy of individuals who interact with our website and who provide information in connection with potential or actual investment in our fund.

This Privacy Policy describes how we collect, use, disclose, and safeguard personal information when you visit [website URL — placeholder], submit an interest form, subscribe to our research communications, or otherwise engage with KapStone. Please read this policy carefully. By using our website or providing us with information, you acknowledge the practices described herein.

This policy does not govern the use of personal information provided to us pursuant to a Limited Partnership Agreement or other fund governing documents, which are addressed in those agreements and in our investor onboarding disclosures.

Information We Collect

We collect information in two ways: information you provide to us directly, and information collected automatically when you use our website.

Information you provide directly:

• Contact information: name, email address, phone number, and mailing address
• Professional and entity information: employer, title, firm or entity name
• Investor qualification information: accredited investor or qualified purchaser status, investment range, and investment horizon
• Communications: messages you send us through the interest form or by email
• Newsletter subscriptions: email address and communication preferences

Information collected automatically:

• Log data: IP address, browser type and version, pages visited, time and date of visit, referring URL
• Device information: operating system, screen resolution, and device type
• Cookie and similar tracking data: as described in the Cookies section below

We do not collect sensitive personal information such as government identification numbers, biometric data, or health information through this website.

How We Use Your Information

We use the information we collect for the following purposes:

• Investor relations: to evaluate interest form submissions, schedule introductory calls, and communicate with prospective and current investors
• Compliance: to satisfy know-your-customer (KYC), anti-money laundering (AML), and other regulatory obligations applicable to our fund and its operations
• Fund administration: to administer investor accounts, process subscriptions, and maintain fund records in accordance with our legal and regulatory obligations
• Research communications: to deliver investment research notes, quarterly letters, and market commentary to subscribers who have opted in
• Website operation: to operate, maintain, and improve our website and analyze how it is used
• Legal compliance: to comply with applicable laws, regulations, and legal processes, and to respond to lawful requests from public authorities

We do not sell personal information. We do not use personal information for algorithmic profiling or automated decision-making that produces legal effects on individuals.

Sharing & Disclosure

KapStone does not sell, rent, or trade personal information. We may share information in the following limited circumstances:

• Fund service providers: our fund administrator, legal counsel, auditors, custodians, and other service providers who require access to perform services on our behalf, subject to confidentiality obligations
• Regulatory authorities: government agencies, regulatory bodies, or law enforcement where required by applicable law or legal process, including SEC, FINRA, or other applicable regulators
• Professional advisors: attorneys, accountants, and compliance consultants engaged in connection with fund operations
• Business transfers: in connection with a merger, acquisition, or sale of all or substantially all of our assets, where investor information may be transferred to the successor entity

All third parties to whom we disclose personal information are required to maintain its confidentiality and to use it only for the purposes for which it was disclosed.

Data Security

We implement reasonable administrative, technical, and physical safeguards designed to protect personal information from unauthorized access, use, alteration, or disclosure. Our interest form submissions and investor communications are transmitted using industry-standard encryption.

No method of transmission over the internet or electronic storage is completely secure. While we take reasonable precautions, we cannot guarantee absolute security of your information. In the event of a data breach that affects your rights or freedoms, we will notify you and applicable regulators as required by law.

Access to personal information within KapStone is limited to personnel who require it to fulfill their responsibilities, and all such personnel are subject to confidentiality obligations.

Data Retention

We retain personal information for as long as necessary to fulfill the purposes described in this policy, to comply with our legal and regulatory obligations, and to resolve disputes. Specifically:

• Interest form submissions are retained for [X years — placeholder] or until you request deletion, whichever is sooner, unless you become an investor in the fund
• Investor records are retained in accordance with applicable securities law requirements and our fund's record-retention policy, which may extend for [X years — placeholder] following the termination of the investor relationship
• Newsletter subscriber information is retained until you unsubscribe
• Website log data is retained for [X months — placeholder] and then aggregated or deleted

Your Rights

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

• Access: the right to request a copy of the personal information we hold about you
• Correction: the right to request correction of inaccurate or incomplete information
• Deletion: the right to request deletion of your personal information, subject to our legal retention obligations
• Objection: the right to object to certain processing activities
• Portability: the right to receive your personal information in a structured, machine-readable format
• Opt-out of communications: the right to unsubscribe from marketing or research communications at any time

To exercise any of these rights, please contact us using the information in the Contact section below. We will respond within a reasonable timeframe and in accordance with applicable law. Please note that certain requests may be subject to legal exceptions — for example, we may be required to retain records for regulatory compliance purposes.

If you are a California resident, you may have additional rights under the California Consumer Privacy Act (CCPA). [California-specific supplement — placeholder if applicable.]

Cookies & Tracking

Our website may use cookies and similar tracking technologies to operate the site and analyze usage. We use the following categories of cookies:

• Strictly necessary cookies: required for the website to function. These cannot be disabled.
• Analytics cookies: used to understand how visitors interact with our website, such as pages visited and time spent. [Analytics provider — placeholder, e.g., no third-party analytics currently used.]

We do not use advertising or behavioral tracking cookies. You may configure your browser to refuse cookies or to alert you when cookies are being sent. Disabling cookies may affect the functionality of certain website features.

Our website does not respond to "Do Not Track" signals at this time.

Children's Privacy

Our website and services are intended solely for adults and are not directed to individuals under the age of 18. We do not knowingly collect personal information from anyone under 18. If you believe we have inadvertently collected such information, please contact us and we will promptly delete it.

Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or the services we offer. When we make material changes, we will update the "Last Updated" date at the top of this page. We encourage you to review this policy periodically. Continued use of our website or continued investor relationship following notification of changes constitutes acceptance of the revised policy.

Contact Us

For privacy-related inquiries, requests to exercise your rights, or questions about this policy, please contact us at:

We aim to respond to all privacy inquiries within 30 days of receipt.