Privacy Policy

Last Updated: June 12, 2026

Introduction

Cygnet Holdings LLC, a Delaware limited liability company (“Company”, “Cygnet”, “we”, “us”, or “our”), and, where applicable, its subsidiaries, affiliates, and related entities involved in operating the Website or providing access to its content, portals, data rooms, or documents (together with the Company, the “Cygnet Group”), respect your privacy and are committed to protecting it through our compliance with this policy. This policy describes how we collect, process, retain, and disclose personal data about you when providing services to you through https://cygnetholdingsllc.com/, including all public pages and any restricted areas, account systems, verification workflows, investor portals, data rooms, document systems, communications, and related services operated by or on behalf of the Cygnet Group, together with any content, functionality, and services offered on or through such site (collectively, the “Website”), and our practices for using, maintaining, protecting, and disclosing that information.

This policy applies only to information we collect:

Through the Website, including the investor portal, any data room, account systems, and verification workflows.
In communications, including email, contact forms, chats, calls, and other electronic messages between you and the Company.
From third parties engaged by the Company in connection with the Website or your investor relationship with the Cygnet Group, including escrow agents, attorneys, accountants, registered broker-dealers, registered investment advisers, fund administrators, transfer agents, banks, custodians, and other service providers and business partners.

It does not apply to information collected by:

Us through any other means, including on any other website operated by the Company or any third party (including our subsidiaries and affiliates) that does not link to this policy; or
Any third party (including our subsidiaries and affiliates), including through any application or content that may link to or be accessible from or through the Website.

Certain portions of the Website, including the investor portal, any data room, and document systems, may also be subject to supplemental privacy notices, confidentiality acknowledgements, and other written agreements between you and the Company. If a supplemental notice conflicts with this policy, the supplemental notice controls with respect to the applicable portion of the Website or subject matter.

Please read this policy carefully to understand our policies and practices regarding your information and how we treat it.

By accessing or using the Website, or by providing us with your information, you agree to the collection, use, and disclosure of your information as described in this privacy policy and our Terms of Use. This policy may change from time to time (see Changes to Our Privacy Policy below). Your continued use of the Website after we make changes as described here is deemed acceptance of those changes, so please check the policy periodically for updates.

No Sale of Personal Data

The Cygnet Group does not sell your personal data and does not share your personal data for cross-context behavioral advertising, in each case as those terms are defined under applicable U.S. state privacy laws. We do not engage in targeted advertising based on your personal data through the Website.

Children's and Minors' Data

The Website is intended for users who are 18 years of age or older. We do not knowingly collect any personal data from children under the age of 18. If we learn we have collected or received personal data from a child under 18 without verification of parental consent, we will delete that information. Certain features of the Website are provided through third-party service providers, and although we will direct any such provider to delete the relevant information, we cannot guarantee that it will be completely or permanently removed from their systems, as the retention and deletion of data by third parties is outside of our control.

The Personal Data We Collect or Process

“Personal data” is information that identifies, relates to, or describes, directly or indirectly, you as an individual. We may receive such information from you directly or through our third-party verification providers, such as an escrow agent. The types and categories of personal data we collect or process include:

Account and contact information, including your name, postal address, email address, telephone number, username, and other contact information you provide.
Identity verification information, including date of birth, government-issued identification numbers (such as Social Security number or other taxpayer identification number, driver's license number, passport number, or equivalent), copies of government-issued identification documents, signatures, photographs, and other documents reasonably necessary to verify your identity and to comply with applicable “know your customer”, anti-money laundering, sanctions, beneficial ownership, and tax laws.
Accredited investor and eligibility verification information, including financial information sufficient to verify accredited investor status or other eligibility criteria (such as income, net worth, asset and liability statements, brokerage and account statements, tax returns or summaries, credit reports, professional licenses, and similar materials), and written verification letters provided by licensed attorneys, certified public accountants, registered broker-dealers, SEC-registered investment advisers, or other qualified professionals.
Investor profile information, including investment experience, investment objectives, risk tolerance, source of funds, occupation, employer, professional and regulatory affiliations, and answers to investor questionnaires.
Investment and account information, including subscription documents, investor questionnaires, capital commitments, capital contributions, capital calls, distributions, redemptions, transfers, beneficial ownership information, custody and brokerage account information, banking, escrow and wire transfer instructions, and tax-related information necessary to prepare and deliver Forms K-1, 1099, FATCA/CRS reports, and other tax filings.
Communications and submissions, including content of emails, contact-form submissions, portal messages, support tickets, telephone calls, video conferences, and other communications between you and the Company, and any documents, materials, or content you choose to upload, submit, or share through the Website.
Device and technical information, including your IP address, device identifiers, operating system and version, preferred language, hardware identifiers, browser type and settings, and other device information.
Activity, audit, and access information, including views, downloads, uploads, acknowledgements, session information, IP addresses, device information, timestamps, login and authentication events, multifactor authentication artifacts, document access events, search queries within the investor portal or data room, and other activity records collected by the Website for security, compliance, confidentiality, securities, audit, and recordkeeping purposes.
Location information, including general geographic location such as country, state or province, or city, derived from your IP address or other technical signals.

We also collect:

Statistics and aggregated information. Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from personal data. If we combine or connect non-personal data with personal data so that it directly or indirectly identifies an individual, we treat the combined information as personal data.
Technical and usage information. Technical information includes information about your internet connection and usage details about your interactions with the Website, including clickstream information, page response times, length of your visits to certain pages, page interaction information, or methods used to browse away from a page.

Some of the information identified above (including identity document information, taxpayer identification numbers, and other identifiers) may be considered sensitive personal data under certain laws. Where required by applicable law, we collect and process sensitive personal data only with your consent or on another permitted legal basis. If you choose not to provide or allow us to collect certain information, we may not be able to verify your identity, complete accredited investor or other eligibility verification, grant access to the investor portal or any data room, accept your subscription, or provide other features, services, or information.

How We Collect Your Personal and Other Data

You Provide Information to Us. We collect information about you when you interact with the Website, such as when you submit an inquiry through a contact form, create or update an account, request access to the investor portal or any data room, complete an investor profile or questionnaire, submit identity or accreditation verification materials, execute a subscription document or related agreement, communicate with the Company or its representatives, or upload content through the Website.

Automatically Through the Website. As you navigate through and interact with the Website, we may use automatic data collection technologies to collect information that may include personal data. Information collected automatically may include device and technical information, usage details, IP addresses, operating system and browser type, audit and access logs (including in the investor portal, any data room, account systems, and document systems), and information collected through cookies, web beacons, and other tracking technologies, including details of your interactions with the Website and which resources and features that you access and use. We use these automatic collection technologies primarily to operate, secure, and improve the Website, to authenticate users, to maintain audit and recordkeeping records, and to detect and prevent fraud and unauthorized access - not for cross-context behavioral advertising.

The technologies we use for this automatic data collection may include:

Cookies. A cookie is a small file placed on your device when you interact with the Website. You may refuse to accept or disable cookies by activating the appropriate setting on your browser or device. However, if you select this setting, you may be unable to access certain features of the Website, including the investor portal and any data room.
Web Beacons. Some parts of the Website and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those parts or opened an email and for other related statistics.
Logging and Audit Technologies. The Website logs portal activity, document access events, authentication events, and other activity for security, compliance, confidentiality, securities, audit, and recordkeeping purposes.
Third-Party Hosting and Tracking Technologies. Portions of the Website are provided or supported by third-party service providers. In delivering these services, such providers may deploy their own cookies, web beacons, server logs, and similar technologies that independently collect, store, and process information about your device and activity. This information is collected by, and is subject to the privacy practices of, those third parties, which we do not control.

From Verification Providers, Professional Verifiers, and Service Providers. We may receive personal data about you from third parties engaged in connection with the Website or your investor relationship with the Cygnet Group, including escrow agents; licensed attorneys, certified public accountants, registered broker-dealers, SEC-registered investment advisers, and other qualified professionals who provide written verification of your accredited investor status; fund administrators, transfer agents, custodians, banks, payment processors, tax advisers, auditors, legal counsel, anti-money laundering and sanctions screening providers, cloud hosting and document storage providers, analytics providers, and other service providers and business partners. The Company is not responsible for the independent determinations, delays, errors, omissions, outages, or practices of such third parties, except to the extent required by applicable law.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal data, to:

Provide, operate, secure, maintain, and improve the Website, including the investor portal, any data room, account systems, verification workflows, and document systems.
Verify your identity and authenticate access to the Website, the investor portal, and any data room, including through multifactor authentication.
Verify your accredited investor status or other eligibility criteria, including through third-party verification providers and written verification letters from qualified professionals.
Evaluate, approve, or decline applications for access to the investor portal, any data room, and to investor materials, and to assign and manage user access tiers.
Administer your account, manage user roles and permissions, deliver investor communications, and respond to your inquiries and requests.
Process subscriptions, capital commitments, capital calls, capital contributions, distributions, redemptions, and transfers, and to manage investor relationships, books and records, and capital accounts.
Prepare and deliver investor reports, financial statements, tax forms (including Forms K-1, 1099, FATCA/CRS, and similar reports), notices, capital account statements, and other investor communications.
Conduct “know your customer”, anti-money laundering, sanctions screening (including OFAC), beneficial ownership, fraud prevention, credit risk, and similar diligence.
Maintain security, integrity, and confidentiality of the Website and restricted materials, including by monitoring and logging activity in the investor portal, any data room, account systems, and document systems, and by detecting and responding to unauthorized access, credential compromise, security incidents, prohibited use, and abuse.
Comply with applicable law, including federal and state securities laws, tax laws, anti-money laundering and sanctions laws, recordkeeping obligations, and lawful requests from regulators, government authorities, and courts.
Establish, exercise, or defend legal claims, enforce agreements (including the Terms of Use and any supplemental agreements), and protect the rights, property, or safety of the Cygnet Group, investors, users, or others.
Carry out our obligations and enforce our rights arising from any contracts entered into between you and us.
Notify you when Website updates are available and about changes to the investor portal, any data room, account features, or other features or services.
In any other way we may describe when you provide the information, or with your consent.

The usage information we collect, whether connected to your personal data or not, helps us improve the Website and deliver a better, more secure experience by enabling us to estimate audience sizes and usage patterns, store information about your preferences, recognize you when you return to the Website, and operate audit and security controls.

Who We Disclose Your Information To

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may also disclose personal data that we collect or you provide as described in this privacy policy:

To our subsidiaries and affiliates within the Cygnet Group.
To contractors, service providers, and other third parties we use to support our organization and the Website, who are bound by contractual obligations to keep personal data confidential and use it only for the purposes for which we disclose it to them. This includes cloud hosting providers, document storage and data-room providers, authentication providers, analytics providers, email providers, fund administrators, transfer agents, custodians, banks, payment processors, anti-money laundering and sanctions screening providers, IT and security service providers, and similar service providers.
To escrow agents, licensed attorneys, certified public accountants, auditors, tax advisers, registered broker-dealers, SEC-registered investment advisers, and other professional advisers engaged by the Company or, with your authorization, engaged by you.
To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, financing, sale of assets, or other sale or transfer of some or all of the Company's or a Cygnet Group member's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal data held by the Company is among the assets transferred.
To regulators, self-regulatory organizations, tax authorities, government authorities, and law enforcement, including the U.S. Securities and Exchange Commission, FINRA, state securities regulators, the Internal Revenue Service, the Financial Crimes Enforcement Network, the Office of Foreign Assets Control, and other authorities, as required or permitted by applicable law.
To fulfill the purpose for which you provide it.
For any other purpose disclosed by us when you provide the information, or with your consent.

We may also disclose your personal data:

To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
To enforce or apply our Terms of Use and other agreements, including confidentiality acknowledgements, subscription documents, and supplemental terms, and for billing and collection.
If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Cygnet Group, investors, users, or others, including for fraud prevention, security investigation, and credit risk reduction.

The categories of personal data we may disclose include:

account and contact information
identity verification information
accredited investor and eligibility verification information
investor profile information
investment and account information
communications and submissions
device and technical information
activity, audit, and access information
location information

We do not sell personal data to third parties and do not share personal data with third parties for cross-context behavioral advertising or targeted advertising.

Your Rights and Choices About Your Information

This section describes mechanisms you can use to control certain uses and disclosures of your information and rights you may have under state law, depending on where you live.

Cookies and Other Tracking Technologies. You can set your browser to refuse all or some browser cookies, or to alert you when these files are being sent. If you disable or refuse cookies, some Website features may be inaccessible or not function properly, and you may be unable to access the investor portal or any data room. Some browsers include a “Do Not Track” (DNT) setting. Because there is not a common understanding of how to interpret the DNT signal, the Website may not respond to all browser DNT signals.

Investor Communications. If you do not wish to receive non-transactional informational communications about the Cygnet Group, you may opt out by contacting us. We may still send you transactional, legal, regulatory, tax, security, and investor relations communications relating to your account, subscription, investment, or compliance, which are necessary to administer your investor relationship and to comply with law.

Location Data. You can choose whether to allow the Website to collect and use real-time information about your device's location through your device's privacy settings. If you block the use of location information, some Website features may become inaccessible or not function properly, and certain authentication, security, and audit controls may be affected.

Your State Privacy Rights

Depending on your state of residency, you may have certain rights related to your personal data, including:

Access and Data Portability. You may confirm whether we process your personal data and access a copy of the personal data we process. To the extent feasible and required by applicable state law, data will be provided in a portable format.
Correction. You may request that we correct inaccuracies in your personal data that we maintain, taking into account the information's nature and processing purpose.
Deletion. You may request that we delete personal data about you that we maintain, subject to exceptions under applicable law, including exceptions for records we are required to retain in connection with securities, tax, anti-money laundering, recordkeeping, audit, and dispute-related obligations.
Opt Out of Targeted Advertising, Profiling, and Sales. You may request that we do not use your personal data for these purposes. As described above, we do not sell personal data, do not engage in cross-context behavioral advertising, and do not engage in profiling that produces legal or similarly significant effects.

Important: The exact scope of these rights varies by state, and there are several exceptions where we may not have an obligation to fulfill your request, including where retention is required to comply with securities, tax, anti-money laundering, or other legal obligations.

California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Montana, Oregon, Tennessee, Texas, Utah, and Virginia provide (now or in the future) their state residents with rights to:

Confirm whether we process their personal information.
Access and delete certain personal information.
Correct inaccuracies in their personal information, taking into account the information's nature processing purpose (excluding Iowa and Utah).
Data portability.
Opt-out of personal data processing for targeted advertising (excluding Iowa), sales, or profiling in furtherance of decisions that produce legal or similarly significant effects (excluding Iowa and Utah).
Either limit (opt-out of) or require consent to process sensitive personal data.

The exact scope of these rights may vary by state. To exercise any of these rights, please submit a privacy inquiry. If you are appealing a decision regarding a consumer rights request, please identify your request as an appeal.

Some browsers and browser extensions support the Global Privacy Control (“GPC”) that can send a signal to process your request to opt out from certain types of data processing, including data sales as defined under certain laws. When we detect such a signal, we will make reasonable efforts to respect your choices as required by applicable law.

How We Protect Your Personal Data

We use commercially reasonable administrative, physical, and technical measures designed to protect your personal data from accidental loss or destruction and from unauthorized access, use, alteration, and disclosure. These measures may include access controls, authentication (including multifactor authentication), encryption in transit and at rest, audit and activity logging, watermarking and access restrictions for documents made available through the investor portal or any data room, role-based permissions, and incident response procedures.

However, no website, mobile application, system, electronic storage, or online service is completely secure, and we cannot guarantee the security of your personal data transmitted to, through, using, or in connection with the Website. In particular, email, texts, and chats sent through ordinary, non-secured channels may not be secure, and you should carefully decide what information you send to us via such channels. You should not submit confidential offering materials, investor documents, bank information, tax documents, government identification numbers, or other sensitive information through public contact forms unless expressly directed by the Company to use an approved secure channel. Any transmission of personal data is at your own risk.

The safety and security of your information also depends on you. You are responsible for safeguarding your credentials, for using strong and unique passwords, for keeping multifactor authentication factors secure, and for notifying us promptly of any unauthorized access, suspected security breach, or credential compromise. You may not attempt to bypass, disable, manipulate, or circumvent any authentication, authorization, verification, audit logging, access control, document restriction, watermark, legend, or other security control on the Website.

How We Retain Your Personal Data

We keep the categories of personal data described in this policy for as long as reasonably necessary to fulfill the purposes described or as otherwise legally permitted or required, such as maintaining the Website, operating our organization, complying with our legal and regulatory obligations, resolving disputes, and for safety, security, and fraud prevention. In particular, we may be required or permitted to retain investor records, verification records, audit and access logs, communications, and related materials for periods required by federal and state securities laws, tax laws, anti-money laundering and sanctions laws, books-and-records requirements applicable to private funds and their advisers and affiliates, statutes of limitations, and related recordkeeping obligations. At the end of the retention period, personal data will be deleted, destroyed, or deidentified.

Users Located Outside the United States

The Website is intended for use only by persons located in the United States. We make no claims that the Website or any of its content is accessible or appropriate outside of the United States. If you access the Website from outside the United States, you do so on your own initiative and are responsible for compliance with local laws. Your personal data will be transferred to, processed in, and stored in the United States.

Changes to Our Privacy Policy

We may update this policy from time to time, and we will provide notice of any such changes as required by law. The date the privacy policy was last updated is identified at the top of the page. We will notify you of changes to this policy by updating the “Last Updated” date and posting the updated policy on the Website. We may also email or otherwise communicate reminders about this policy, but you should check the Website periodically to see the current policy and any changes.

Contact Information

To exercise your rights, ask questions, or comment about this privacy policy or our privacy practices, please submit a privacy inquiry or write to us at:

Cygnet Holdings LLC
PO Box 124
Savage, MN 55378
Attention: Privacy

Legal, privacy, terms, and accessibility pages are public notices for site use and public context. Formal offering documents and risk factors remain in controlled investor materials.

Site notices do not provide tax, legal, investment, accounting, or financial advice. Visitors and investors are responsible for consulting their own advisers.

Cygnon™ is a trademark of Cygnet Scientific Holdings LLC.