PRIVACY POLICY

HonTe Advisors, LLC, its affiliates and the Cayman Islands funds they manage (together, “HonTe,” “we,” “us,” or “our”) believe that protecting the privacy of our current, former, and prospective clients (who are natural persons), as well as our online visitors, is important. The following privacy policy (“Privacy Policy”) explains how we collect, use, and disclose personal data (as defined below) from and about you through your interactions with us, including your interactions with our website, honteinv.com, (the “Website”). Please review this Privacy Policy and our Terms & Conditions carefully.

This Privacy Policy provides information on our use of your personal data in accordance with relevant laws and regulations, including the Cayman Islands Data Protection Act (“DPA”), the California Consumer Privacy Act (with any implementing regulations and as may be amended from time to time, “CCPA”), the EU General Data Protection Regulation (Regulation (EU) 2016/679) (together with applicable implementing laws, the “EU GDPR”), or by the EU GDPR as retained by The Data Protection, Privacy and Electronic Communications (Amendments etc.) (EU Exit) Regulations 2019 pursuant to the European Union (Withdrawal) Act 2018 (each as amended, and together with the UK Data Protection Act 2018 and other applicable implementing laws, “UK GDPR”, and together with the EU GDPR as applicable, “GDPR”). The rights discussed in certain sections of this Privacy Policy may be subject to exemptions or other limitations under applicable law.

Depending on where you are located or the funds you invest in, different sections of this Privacy Policy may apply specifically to you. Please review this Privacy Policy carefully to understand what we do in regards to your personal data, and where applicable, the following sections:

• For our investors who are, or are associated with, investors in our funds based in the Cayman Islands (the “Cayman Funds”), see the below section, “Additional Rights Relating to Investors in the Cayman Funds” for a description of your rights and other information related to the DPA.
• If you are a California resident and subject to the CCPA, see the below section, “Additional Information for California Residents” for additional disclosures, our Notice at Collection, and a description of your rights with regard to your personal information (as defined by the CCPA) and other information related to the CCPA.
• If you are located in the European Economic Area (“EEA”) or the United Kingdom (“UK”) and subject to the EU GDPR and/or the UK GDPR, please review this Privacy Policy and see the below section “Additional Information for EEA and UK Data Subjects” for a description of your rights and other information related to the GDPR.

Personal Data Collected

HonTe may collect nonpublic personal information and other personal information about you to facilitate your investments and for our business and commercial purposes. For purposes of California residents only, pursuant to the CCPA, “personal information” includes information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a California resident or a household. “Personal data” for the purposes of this Privacy Policy means any information that can directly or indirectly identify you and includes nonpublic personal information and, with regard to California residents only, personal information as defined under the CCPA. Depending on how you interact with us, HonTe may collect the following categories of personal data from or about you, including:

• Identifiers and similar information such as a name, address, date of birth, email address, Social Security number, driver’s license number, passport number, online identifiers, or other similar identifiers.
• Additional information protected under certain federal or state laws, like a signature, education information, state identification number, credit card, bank account, or other financial information.
• Characteristics of protected classifications under certain federal or state laws, including gender, national origin, or marital status.
• Commercial information, including records of products or services purchased, obtained, or considered, or other purchasing histories or tendencies, including funds invested, investments considered, or sources of wealth.
• Internet or other electronic network activity information, including interactions with our Website or use of certain online tools.
• Professional or employment-related information, including occupation, compensation, employer, and title.
• Audio, electronic, visual, or similar information, including interactions with us on video communications platforms.
• Inferences drawn from any of the information identified above to create a profile reflecting your preferences or similar information.
• Sensitive personal information under the CCPA such as your passport number, driver’s license, Social Security Number state identification card, account log-in, or financial account, in combination with any required security or access code, password, or credentials allowing access to an account.

Sources of Personal Data

HonTe may collect personal data about you directly from you and/or your intermediaries through sources such as:

• account applications, subscription agreements, and other forms or related documentation;
• written, electronic, or verbal correspondence with us or our service providers;
• client transactions;
• a client’s brokerage or financial advisory firm, financial advisor, or consultant; and/or
• information captured on applicable websites.

In addition, HonTe may collect personal data from different sources, such as:

• our affiliates, our service providers, or our affiliates’ service providers;
• public websites or other publicly accessible directories and sources, including bankruptcy registers, tax authorities, governmental agencies and departments, and regulatory authorities; and/or
• from credit reporting agencies, sanctions screening databases, or from sources designed to detect and prevent fraud.

Purposes for Collecting, Using, and Processing Personal Data

HonTe may collect, use, and process your personal data for various business or commercial purposes, including:

• performing our contractual obligations to a client, including providing updates on performance, providing tax reporting, and other operational matters;
• complying with our legal or regulatory obligations;
• detecting security incidents and protecting against malicious, deceptive, fraudulent, or illegal activity, including preventing fraud and conducting “Know Your Client,” anti- money laundering, terrorist financing, and conflict checks;
• where permitted by applicable law, providing you with marketing or promotional materials;
• internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes; and
• pursuing our legitimate interests or those of a third party where we consider that, on balance, our (or their) legitimate interests are not overridden by your interests, fundamental rights, or freedoms, including performing services on behalf of a fund like fulfilling your requests, maintaining or servicing accounts, providing client relations services, processing subscriptions, verifying information, and processing payments or providing similar services, and enabling or effecting commercial transactions, including using bank account details to remit funds and process distributions.

Sharing Personal Data
HonTe may share all or some of your personal data that we collect with our affiliates in order to service your account. Otherwise, we do not disclose any personal data about you, except:

• to counterparties and service providers, including administrators, banks, auditors, law firms, consultants, and placement agents and entities that have been advised as to the proper handling of such data;
• at your request or direction or with your consent;
• where we believe in good faith that the disclosure is required or permitted under law, to cooperate with regulators, tax or law enforcement authorities, or to protect our rights or property;
• as reasonably necessary to prevent fraud, unauthorized transactions or liability;
• in the event we seek to buy or sell any business or assets, we may release information about you to the prospective buyer or seller, and if we, or substantially all of our assets, are acquired by a third party, your personal data will be one of the transferred assets; and/or
• as otherwise required or permitted by law or regulation.

We require third-party service providers and financial institutions to protect the confidentiality of personal data and to use such personal data only for the purposes for which it was disclosed to them. HonTe restricts access to personal data it collects about clients to its employees and agents who have been advised as to the proper handling of such personal data and who need to know that personal data in order to provide products or services to clients.

Please note that for purposes of this section (“Sharing Personal Data”) “sharing” does not mean “sharing” as defined under the CCPA. For additional disclosures and information on our CCPA practices, please review “Additional Information for California Residents,” below.

Security of Personal Data

HonTe will take reasonable steps and use security measures, including physical, electronic, and procedural safeguards, appropriate to the nature of the information and that comply with applicable laws to protect clients’ and users’ personal data against unauthorized access and exfiltration, acquisition, theft, or disclosure. Given the nature of information security, there is no guarantee that such safeguards will always be successful.

Retention of Personal Data

How long we keep your personal data will vary depending on the type of personal data and our reasons for collecting it. The retention period will be determined by various criteria, including the purposes for which we are using it (as it will need to be kept for as long as is necessary for any of those purposes) and our legal obligations (as laws or regulations may set a minimum period for which we have to keep your personal data). HonTe will retain your personal data for as long as we require it to perform our contractual rights and obligations or for our legitimate interests, or for such longer period as required by our legal or regulatory obligations. In general, we will retain your personal data throughout your investment with us. We will also retain certain of your personal data after you cease to be a client.

Links to External Websites

Our Website may contain links to third-party websites. Any access to and use of such third-party websites is not governed by this Privacy Policy, but, instead, is governed by the privacy policies of those third-party websites. HonTe is not responsible for the information practices of such third-party websites.

Cookies and Similar Technologies

Cookies are small text files that are stored in your computer’s memory and hard drive or in your mobile device or tablet when you visit certain web pages. They are used to enable websites to function or to provide information to the owners of a website or other third parties that receive data obtained from that website. Our Website uses cookies and other tools to collect analytics information about your visit to our Website. Service providers, including Google Analytics, may provide these tools. The information does not identify a particular individual visitor or user. For more information on (a) how Google Analytics collects and processes such information, please click here, and (b) how to prevent the use of Google Analytics relating to your use of our Website by downloading and installing a browser plug-in, please click here. You can change your cookie preferences by changing the setting on your web browser to delete or reject cookies.
If you delete or reject cookies, some websites may not function properly.

Please note that some of our third-party service providers may use cookies and similar technologies to support the operation of our digital offerings. These entities may be collecting such information in order to provide services to or for us. You should be aware that these third-party service providers may have different privacy policies and information security practices; as such, we encourage you to read the privacy statements provided by other websites before you provide personal data to them.

Do Not Track

Our Website currently recognizes “Do Not Track” signals. Do Not Track is a privacy preference that you can set in your web browser to indicate that you do not want certain information about your webpage visits collected across websites when you have not interacted with that service on the page. For details, including how to turn on Do Not Track, visit http://www.donottrack.us. Please note that third-party websites may not recognize Do Not Track signals. As previously noted, we encourage you to read the privacy statements provided by third party websites.

Children’s Privacy

This Website is not intended for use by children. We do not knowingly collect, maintain, or use personal data from children under 16 years of age, and no part of our services is directed to children. If you learn that a child has provided us with personal data in violation of this Privacy Policy, please contact us at contact@honteinv.com.

Where We Process Your Data

We are based in the U.S. When you provide personal data to us from outside of the U.S., please be aware that we will receive and process it in the U.S. and that U.S. data protection laws may be different from those of your country of residence.

Your Rights and Choices

Depending on how you interact with us and where you are located, you may have certain rights to your personal data, including:

• Opt-Out of Marketing Communications. We may send communications about our services and events to you. You can opt out of these communications by contacting us using the details in Contact Information below.
• Access or Correct Your Information. We take reasonable steps to keep your personal data accurate and complete. You can request to access or update your personal data by using the details in Contact Information below.

Additional Rights and Disclosures Relating to Investors in the Cayman Funds

For the purposes of the DPA, we are a data controller of personal data of individuals who are, or who are associated with, investors in our Cayman Funds (“you” or “your”), and such individuals’ personal data are processed for the purposes set out in this notice. Under the DPA, HonTe is generally a data controller and our affiliates and/or delegates may be data processors (or, in some circumstances, data controllers in their own right). “Personal data” as used in this section has the same meaning as provided in the DPA. If you are a natural person, this Privacy Policy will be relevant to you directly. If you are a non-natural person investor that provides us with personal data on individuals connected to you for any reason in relation to your investment with us, this Privacy Policy will be relevant for those individuals and you should transmit this document to such individuals or otherwise advise them of its content.

Additional Rights of Data Subjects Who Are, or Who Are Associated With, Investors in our Cayman Funds

Under the DPA, investors in our Cayman Funds who are individuals, wherever you are located, have certain rights under the DPA in relation to your personal data. These include the right, in certain circumstances, to:

• be informed about the purposes for which your personal data are processed;
• request access to your personal data;
• stop direct marketing;
• restrict the processing of your personal data;
• have incomplete or inaccurate personal data corrected;
• ask us to stop processing your personal data;
• be informed of a personal data breach (unless the breach is unlikely to be prejudicial to you);
• require us to delete your personal data in certain circumstances; and
• complain to the Cayman Islands Ombudsman, who may be contacted by email (info@ombudsman.ky), telephone (+1 345-946-6283) or post (PO Box 2252, Grand Cayman KY1-1107, Cayman Islands).

How to Exercise Your Rights under the DPA

To exercise your rights under the DPA, if applicable, you should contact us using the information provided below in the “Contact Information” section and include “DPA Rights Request” as the subject of your communication.

Transfers of Personal Data Outside of the Cayman Islands

HonTe may transfer your personal data to jurisdictions that do not have data protection laws equivalent to the DPA (should the DPA be applicable). This may be necessary for a number of reasons, including for the performance of our rights and obligations under agreements with you or under an agreement with a third party that is in your interests or in connection with international cooperation arrangements between governmental, regulatory, tax and law enforcement authorities.

Additional Information for California Residents

The CCPA imposes certain obligations on HonTe and grants certain rights to California residents (“California Resident,” “you,” or “your”) with regard to “personal information.” If you are a California Resident, please review the following information about our privacy practices surrounding how and why we collect, use and disclose your personal information and your potential rights with regard to your personal information under the CCPA. The rights described herein are subject to exemptions and other limitations under applicable law.

Terms used in this California-specific section have the meaning ascribed to them in the CCPA. HonTe is a “business.”

Notice at Collection and Use of Personal Information

Information We Collect

Depending on how you interact with us, we may collect the categories of personal information listed above in the section “Personal Data Collected.”

Purpose for Collection and Use of Information

We may collect and use your personal information for the purposes listed above in the section
“Purposes for Collecting, Using, and Processing Personal Data.”

Sale or Sharing of Personal Information

We do not sell or share your personal information (as such terms are defined under the CCPA).

How Long We Keep Information

We retain your personal information as described above in the section “Retention of Personal Data” above.

For more information about our privacy practices, please review our Privacy Policy.

Our Collection, Use, and Disclosure, of Personal Information and Sensitive Personal Information

What Information We Have Collected, the Sources from Which We Collected It, and Our Purpose for Collecting the Information

In the preceding 12 months, depending on how you interact with us, we may have collected the categories of personal information listed above in the section, “Personal Data Collected.” We may collect personal information from all or some of the categories of sources listed in the section, “Sources of Personal Data.” We may collect all or a few of the categories of personal information for the business or commercial purposes identified in the section, “Purposes for Collecting, Using, and Processing Personal Data.”

Our Disclosure of Personal Information

HonTe does not sell or share your personal information (as those terms are defined under the CCPA). We do not knowingly sell or share personal information of California Residents under 16 years old.

In the preceding 12 months, we may have disclosed for a business purpose the following categories of personal information to the following categories of third parties, as describe in the below chart:

In addition, in the preceding 12 months, we may have disclosed all of the categories of personal information identified above in the section, “Personal Data Collected,” to the following categories of third parties: (i) judicial courts, regulators, or other government agents purporting to have jurisdiction over us, our subsidiaries, or our affiliates, or opposing counsel and parties to litigation; and (ii) other third parties as may otherwise be permitted by law. We may disclose personal information to all of the third parties listed above to comply with our legal obligations or for the business or commercial purposes identified above in “Purposes for Collecting, Using, and Processing Personal Data.”

HonTe may also disclose or make available your personal information with our service providers, including our client relationship management, human resources, and information technology providers, other entities that have agreed to limitations on the use of your personal information, or entities that fit within other exemptions or exceptions in or as otherwise peritted by the CCPA.

Use and Disclosure of Sensitive Personal Information

As noted above in “Personal Data Collected” under the CCPA, certain personal information we collect and process may be considered “sensitive personal information.” The CCPA requires that we provide you with a right to limit our use or disclosure of such sensitive personal information in certain circumstances. Currently we are not using your sensitive personal information for purposes that would require that we provide you with a right to limit.

California Residents’ Rights under the CCPA

If your personal information is subject to the CCPA, you may have certain rights with regard to such personal information, including the right to:

(1) Be informed, at or before the point of collection, of the categories of personal information to be collected and the purposes for which the categories of personal information shall be used.
(2) Request that HonTe delete any personal information about you that we collected, subject to certain exceptions (“Request to Delete”).
(3) Correct inaccurate personal information (“Request to Correct”).
(4) Request that HonTe, as a business that collects personal information about you and that discloses your personal information for a business purpose, disclose to you (“Request to Know”):

• The categories of personal information we have collected about you.
• The categories of sources from which we collected the personal information.
• The business or commercial purpose for collecting or selling the personal information.
• The categories of third parties with which we disclose personal information.
• The specific pieces of personal information we have collected about you.

(5) Not be discriminated against because you exercised any of your rights under the CCPA.
(6) Opt-out of the “sale” (as that term is defined in the CCPA) of your personal information if a business sells your personal information (we do not).
(7) Opt-out of the “sharing” (as that term is defined in the CCPA) of your personal information if a business shares your personal information with third parties (we do not).
(8) Limit the use and disclosure of sensitive personal information where required by the CCPA (“Right to Limit”) (please note that we are not using your sensitive personal information for purposes that would require that we provide you with a Right to Limit).

The CCPA does not restrict HonTe’s ability to do certain things like comply with other laws or comply with regulatory investigations. In addition, the CCPA does not apply to certain information like personal information collected, processed, sold, or disclosed pursuant to the federal GrammLeach-Bliley Act and its implementing regulations. HonTe also reserves the right to retain, and not to delete, certain personal information after receipt of a Request to Delete where permitted by the CCPA.

How to Submit a Request under the CCPA

If your personal information is subject to the CCPA, you may submit Requests to Know, Requests to Correct and Requests to Delete (“Consumer Rights Request”) through the following methods: 415-801-4250, or on HonTe’s website at www.honteinv.com.

HonTe is only required to respond to verifiable Consumer Rights Requests made by a California resident or their legally authorized agent. When you submit a Consumer Rights Request to, we may ask that you provide clarifying or identifying information to verify your request. Such information may include, at a minimum, depending on the sensitivity of the information you are requesting and the type of request you are making, your name and email address. Any information gathered as part of the verification process will be used for verification purposes only.

You are permitted to designate an authorized agent to submit a Consumer Rights Request on your behalf and have that authorized agent submit the request through the aforementioned methods. In order to be able to act, authorized agents have to submit written proof that they are authorized to act on your behalf or have a power of attorney. We may deny requests from authorized agents who do not submit proof that they have been authorized by you to act on your behalf. We may also require that you directly verify your own identity with us and directly confirm with us that you provided the authorized agent permission to submit the request.

HonTe will deliver responses to verifiable consumer requests, free of charge, either through your online account with us, if you have such an account already, or, if you do not have a pre-existing online account, by mail or electronically, at your election. HonTe will try to respond to your Requests to Know or to Delete within forty-five (45) days of receipt of the request. If we require more time, we will try to inform you of our need for an extension. Even with an extension, we will try to provide a response within ninety (90) days of initial receipt of the request.

Keep in mind that HonTe is not required to provide information in response to Requests to Know more than twice in a 12-month period. Any response to a Request to Know will only cover the 12- month period preceding the verifiable request.

Additional Information for EEA and UK Data Subjects

The GDPR, to the extent applicable, imposes certain obligations on us, as a data controller, and grants certain rights to data subjects located in the EEA or UK (“data subject,” “you” or “your”). “Personal data” and other terms as used in this section have the same meaning provided in the GDPR.

a. Legal Basis

As described above in, “Personal Data Collected” and “Purposes for Collecting, Using, and Processing Personal Data” we process personal data for various purposes. Our lawful bases for processing that personal data include:

• where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
• to comply with certain legal and regulatory requirements;
• depending on the circumstances, we may need to process your personal data for the performance of a contract to which you are a party, or related pre-contractual steps; and
• with your consent, as required by the GDPR.

b. Rights Applicable to Certain EEA or UK Data Subjects

Under the GDPR and any other applicable EU or UK data privacy laws, data subjects have a right to: (i) request access to and rectification of your personal data; (ii) correct personal data that we hold where it is incomplete or inaccurate; (iii) restrict the processing of your personal data in certain circumstances; (iv) object to the processing of your personal data in certain circumstances, including where we process personal data for direct marketing purposes or where we have processed such data on the basis of our legitimate interests; (v) request that we erase your personal data under certain circumstances; (vi) ask for a copy of your personal data to be provided to you, or to a third party, in a digital form; (vii) withdraw your consent to the processing of your personal data (where applicable); and (viii) lodge a complaint about the processing of your personal data with your local data protection authority (the UK data protection authority is the Information Commissioner. You can contact the Information Commissioner at: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF; telephone: +44 (0)303 123 1113; email: casework@ico.org.uk).

c. How to Exercise Your Rights Under the GDPR

If you wish to exercise any of these rights as an EEA or UK data subject, you should contact us at the details set out below and include “GDPR Rights Request” as the subject of your communication

d. Transfers of Personal Data Outside the EEA or the UK

Our activities and the jurisdictions in which we are established are such that it may be necessary for personal data that we obtain from you to be transferred and/or processed outside of the EEA or the UK, chiefly but not limited to the United States and the Cayman Islands. Personal data may be accessible by employees and other persons working on our behalf, located outside of the EEA or the UK, including to certain service providers (including but not limited to technical service providers and electronic data storage providers) who may process the information you give us. In circumstances where we transfer personal data outside the EEA or the UK, we will seek to ensure a similar degree of protection is afforded to it by ensuring that, where possible, personal data is generally transferred only to persons in countries outside the EEA or the UK in one of the following circumstances:

• to persons and undertakings in countries that have been deemed to provide an adequate level of protection for personal data by the European Commission or the equivalent entity in the UK;
• to persons and undertakings to whom the transfer of such personal data is made pursuant to a contract that is compliant with the model contracts for the transfer of personal data to third countries from time to time approved by the European Commission (as supplemented where and if required) or the equivalent entity in the UK;
• to persons and undertakings outside of the EEA or the UK pursuant to other appropriate safeguards for the transfer of personal data;
• to persons and undertakings based in the United States if they are part of the EU-U.S. Data Privacy Framework which requires them to provide similar protection to personal data shared between the EEA and the United States, as well as between the UK and the United States pursuant to the Data Protection (Adequacy) (United States of America) Regulations 2023 for the UK Extension to the EU-U.S. Data Privacy Framework (the UK-US Data Bridge); and
• only on one of the conditions allowed under the GDPR in the absence of (i) a decision by the European Commission or the equivalent entity in the UK that has deemed a country to provide an adequate level of protection for personal data (i.e. an adequacy decision) or (ii) appropriate safeguards such as a contract that is compliant with the model contracts for the transfer of personal data to third countries approved by the European Commission or the equivalent entity in the UK.

You can contact us through the information provided in the Contact Information section below for further information on specific mechanisms we utilize for transferring personal data outside the EEA or the UK and the countries to which such transfer may be made (which may include, but are not limited to, the United States).

Notification of Changes

Any changes to this Privacy Policy will be posted to this Website. Accordingly, please refer back to this Privacy Policy frequently as it may change. This Privacy Policy was last updated on April 7th, 2025.

Contact Information

This Privacy Policy is available in alternative formats upon request. If you have any questions concerning this privacy policy, including to request this Privacy Policy in an alternative format, please contact us at 415-801-4250 and/or contact@honteinv.com.