Privacy Policy

Privacy Notice

We provide this Privacy Notice (“Privacy Notice”) in compliance with Regulation S-P under the Gramm-Leach-Bliley Act (the “Privacy Rules”). This Notice explains how Thesis Capital LLC and its affiliates (“Thesis Capital,” “we,” “our,” or “us”) collect, use, and protect personal information about or in connection with our investors.

Sources of Information

In connection with forming and operating our private investment funds (each, a “Fund” and collectively, the “Funds”), Thesis Capital collects and maintains personal information about our investors from the following sources:

• (a) Information provided by you through telephone conversations, voicemails, written correspondence, email or other electronic communications, or in subscription agreements, investor questionnaires, partnership agreements, or other documentation. This may include name, address, tax identification number, and other identification materials.
• (b) Information about your transactions with us or others.
• (c) Information collected through our website, data rooms, and investor reporting portals, including registration data, information provided through online forms, and data captured via cookies or similar technologies.

Disclosure of Information

Thesis Capital is committed to protecting your privacy and maintaining the confidentiality of your personal information. We may disclose information about you only as permitted or required by law and as necessary for the effective management and administration of the Funds. This includes disclosure:

• To affiliates, agents, and other investors, when appropriate for fund operations;
• To third-party service providers such as fund administrators, legal, accounting, or tax advisors, consultants, and auditors;
• To financial service providers, including placement agents, custodians, lenders, or brokers involved in fund transactions; and
• To other partners of our Funds in connection with reporting, communications, and required documentation.

Access to personal information is restricted to employees who need it to perform their duties. Thesis Capital maintains physical, electronic, and procedural safeguards to protect this information from unauthorized access or disclosure. The same protections apply to both current and former investors.

Further Information

We reserve the right to amend this Privacy Notice at any time. Updates will be posted on this Site. The examples in this Notice are illustrative and not exhaustive. This Notice is intended to comply with applicable U.S. federal privacy laws and certain other jurisdictions’ requirements where applicable.

Additional Jurisdictional Notices

Depending on your jurisdiction, you may have additional rights under other privacy laws. If you are a resident of California, please refer to the California Privacy Notice below. If the EU or UK General Data Protection Regulation (“GDPR”) applies to you, please refer to the GDPR Privacy Notice below.

California Privacy Notice

This California Privacy Notice supplements the Privacy Notice above and applies only to California residents, as defined by the California Consumer Privacy Act of 2018 (“CCPA”), as amended. It explains your rights under the CCPA and how to exercise them. To the extent there is any conflict between the CCPA and the Gramm-Leach-Bliley Act or Regulation S-P, the latter shall control.

Your Rights Under the CCPA

• Access and Disclosure: You may request details about the categories and specific pieces of personal information we have collected about you.
• Correction: You may request correction of inaccurate information we hold.
• Deletion: You may request deletion of your personal information, subject to legal exceptions.
• Non-Discrimination: We will not discriminate against you for exercising your rights under the CCPA.

To exercise these rights, contact us at privacy@thesiscapital.com or call our office at +1 (713) 555-0000. We will verify your request through reasonable procedures consistent with applicable law. Authorized agents may act on your behalf with proper written consent.

GDPR Privacy Notice

This GDPR Privacy Notice applies to individuals located in the European Economic Area (EEA) or the United Kingdom whose personal data is processed by Thesis Capital under the EU or UK General Data Protection Regulation (“GDPR”).

Data Controllers

For the purposes of this Notice, Thesis Capital LLC acts as the data controller of personal information collected through this Site and in connection with fund operations.

Legal Bases for Processing

We process personal data on the following legal bases:

• Performance of a contract or pre-contractual steps at your request;
• Compliance with applicable laws, including AML/KYC and tax obligations;
• Our legitimate interests in managing investor relationships and fund operations; and
• With your consent where required by law.

Data Sharing and Transfers

We may disclose your data to affiliates, fund administrators, advisors, auditors, regulatory authorities, or IT service providers. Personal data may be transferred to jurisdictions outside your country of residence. We implement safeguards, such as standard contractual clauses, to protect your data in accordance with applicable law.

Data Retention and Security

We retain personal data only as long as necessary to fulfill the purposes described above or as required by law. Thesis Capital uses technical and organizational measures designed to protect your information against unauthorized access, alteration, or disclosure.

Your Data Rights

Under the GDPR, you may have the following rights:

• Access and obtain a copy of your personal data;
• Request correction of inaccurate or incomplete data;
• Request deletion (“erasure”) of your data, subject to legal exceptions;
• Object to or restrict processing in certain circumstances;
• Request data portability; and
• Lodge a complaint with your local supervisory authority.

To exercise your GDPR rights or make a privacy inquiry, contact us at info@thesiscapital.com.

Contact

For any questions regarding this Privacy Policy or your rights under applicable law, please contact: