Privacy
Policy

Last Updated: June 1, 2025

At Phichain Capital, we value your privacy and are committed to protecting your personal information. This Privacy Policy explains how Phichain Capital LLC (“Phichain Capital,” “we,” “us,” or “our”) collects, uses, and safeguards personal data from individuals who use our website or services. It applies to information collected through our website, investor portals, and any related online services, as well as other interactions with our company. We primarily serve accredited investors and institutions globally, and we adhere to applicable privacy laws in the United States and other regions we operate in. By using our website or services, you agree to the data practices described in this Policy. (Note: If you do not agree with this Policy, please discontinue use of our site and services.)

No Third-Party Data Sharing: Importantly, Phichain Capital does not sell, rent, or share your personal information with unaffiliated third parties for their own marketing or other independent uses. Any sharing of data is strictly limited to the purposes and circumstances described in this Policy (such as to provide our services or comply with legal obligations), and we never disclose your information for third-party direct marketing.
Information We Collect

We collect personal information that you choose to provide to us, as well as certain information automatically when you visit our website.

The types of information we may collect include:

Personal Identifiers: Information such as your name and email address, and any other contact details or credentials you provide (for example, when you fill out a contact form or subscribe to updates). This may also include professional or institutional details if you provide them (for instance, your company or investor accreditation status, when relevant). We only collect the information that you voluntarily submit to us.

Website Usage Data: Information collected automatically from your visits to our site, including your Internet Protocol (IP) address, browser type, device information, pages visited, and browsing actions on our website. We use cookies and similar tracking technologies to gather this usage data. Cookies are small text files that are placed on your browser when you visit a website; they help us recognize you and understand how you use our site. For example, our servers (or authorized analytics providers) may log information like your IP address and browser requests through cookies. You can control cookies through your browser settings, but blocking cookies may affect certain site features.

We do not intentionally collect any sensitive personal data through our public website (such as Social Security numbers or financial account details) unless you explicitly provide it for a specific purpose. Additionally, our services are not directed to children, and we do not knowingly collect personal information from anyone under the age of 13.

Phichain Capital gathers personal information in a couple of ways:

Directly from You: We collect information that you provide directly to us. For instance, when you fill out forms on our website (such as a contact inquiry or newsletter sign-up form), when you contact us by email or phone, or when you register for access to any investor portals or data rooms, you may give us personal details like your name, email address, and any information you choose to include in your message. This information is provided voluntarily by you.

Through Automated Means (Cookies & Analytics): As you interact with our website, we automatically collect certain technical data using cookies, web beacons, and log files. These technologies allow us to record details of your site visit – for example, we may capture your IP address and browser type, the pages or content you view, and the date/time of your visit. We may also use third-party analytics tools (such as Google Analytics) to help analyze how users navigate our site; these tools use cookies and similar technologies to collect information about usage patterns. All such automatic data collection is for internal use as described below, and no personal identifiers from these methods are used to personally profile you beyond site analytics. You can adjust your browser or device settings to limit or disable cookies, though doing so might impact some functionality of our website.

We may update or modify this Privacy Policy from time to time to reflect changes in our practices or to ensure compliance with legal requirements. If we make changes, we will post the revised Privacy Policy on our website with a new “Effective Date” indicated at the top. We encourage you to review this page periodically to stay informed about how we are protecting your information.
If we make any significant changes to this Policy, we may provide additional notice (such as by email notification or a notice on our homepage) as appropriate. Your continued use of our website or services after any changes to this Privacy Policy constitutes your acceptance of the updated terms, unless explicitly prohibited by applicable law. Should we ever wish to use your personal information in a manner materially different from what is stated at the time of collection, we will obtain your consent or provide you with an opportunity to opt out, as required by law

We respect your rights to control your personal information. Depending on your residency or location, you may have certain legal rights with regard to the personal data we hold about you. Phichain Capital will honor applicable data subject rights requests in accordance with the relevant privacy laws (such as the EU General Data Protection Regulation and the California Consumer Privacy Act). These rights may include:

European Union/EEA and United Kingdom (GDPR): If you are in the EU, EEA, or UK, you have robust data protection rights under the GDPR and UK data protection laws. These include the right to be informed about how your data is used, the right of access to obtain a copy of the personal data we hold about you, the right to rectification to correct inaccurate or incomplete data, and the right to erasure (or “right to be forgotten”) to request deletion of your data in certain circumstances. You also have the right to restrict processing of your data, the right to data portability to receive your data in a usable format or have it transmitted to another controller, and the right to object to certain processing (such as direct marketing). If we are processing your information based on consent, you have the right to withdraw consent at any time (without affecting the lawfulness of processing before withdrawal). Additionally, you have the right to lodge a complaint with your national Data Protection Authority (DPA) if you believe your data has been handled in a way that does not comply with the lawargainvest.com. We encourage you to contact us first with any concerns, and we will do our best to resolve them.

California Residents (CCPA/CPRA): If you are a California resident, state law provides you with specific privacy rights regarding your personal information. You have the right to know what categories of personal information we collect, use, and disclose, and the right to access the specific pieces of personal information we hold about you. You also have the right to request deletion of your personal information that we have collected (subject to certain exceptions such as information needed to comply with legal obligations or complete transactions you initiated). Additionally, you have the right to opt out of the sale or sharing of your personal information; however, please note that Phichain Capital does not sell your personal data to third parties, so this right is largely in place as a formality. We also will honor the right to non-discrimination, meaning we will not deny services, charge different prices, or provide a different level of service if you exercise your privacy rights under California law. If you are a California resident and would like to exercise any of these rights, please contact us using the information below. We will verify your identity and respond to your request as required by law.

Other Jurisdictions: If you reside in a state or country with additional privacy protections (such as Colorado, Virginia, Connecticut, Utah in the U.S., or other countries), you may have rights similar to those above. For example, some jurisdictions provide rights to correct your data or to opt out of certain data processing (like targeted advertising or profiling). Phichain Capital’s policy is to extend fundamental privacy rights to all our users where feasible. We will endeavor to comply with any valid requests regarding your personal information, in accordance with applicable law. If you have questions about your privacy rights in your jurisdiction, please contact us for assistance.

Exercising Your Rights: To exercise any of the rights described above, please reach out to us at the contact information provided in the next section. We may need to verify your identity (for instance, by confirming your email address or other details) before fulfilling certain requests, especially for access or deletion, to ensure we protect your data from unauthorized access. We will respond to legitimate requests within the timeframe required by law (for example, within 30 days for GDPR requests, and 45 days for CCPA requests, with extensions if permitted). There is no fee for making a request unless it is excessive or unfounded, in which case we will inform you of any cost before proceeding.

We collect and use personal information only for legitimate business purposes and as permitted by law. The primary purposes for which Phichain Capital uses your information include:

Providing and Improving Services: To respond to your inquiries and communications, to evaluate and process any requests you make (e.g. providing information about our investment offerings), and to deliver the services or resources you request. We also use data to operate and improve our website’s functionality, user experience, and contents. This helps us ensure our web presence meets the needs of our users and clients.

Communication: To communicate with you about our services. For example, we may use your email address to send you updates, newsletters, or event invitations if you have opted to receive them. We may also send administrative or transaction-related communications (for instance, confirmations or important notices) as needed. We will not send you marketing emails if you have not subscribed or if you choose to unsubscribe from such communications.

Legal and Regulatory Compliance: As an investment fund serving accredited investors, we may need to collect certain information to comply with applicable laws and regulations. We use personal data to fulfill our legal obligations – for example, verifying investor eligibility, satisfying know-your-customer (KYC) or anti-money laundering requirements, and maintaining records required by financial regulations. Your information may also be used to enforce our terms of service or to protect our rights and the rights of other users.

Site Analytics and Development: The usage data we gather (through cookies and logs) is used to understand how our website is used and to analyze trends. This helps us make informed improvements to content, troubleshoot technical issues, and develop new features or services in line with user interests. Any analytics are typically conducted on aggregated data that does not directly identify individuals.

Security and Fraud Prevention: We may process certain data (such as IP addresses or user activity logs) to monitor for suspicious activities and to help prevent fraud, security breaches, or other potentially illegal activities. This is part of our effort to keep our website and investor platforms safe and secure for all users.

We will only use your personal information for the purposes for which we collected it (or as compatible with those purposes), unless we obtain your consent for other uses or as otherwise required or permitted by law.
Information Sharing and Disclosure
Phichain Capital respects the confidentiality of your personal information. We do not share your data with third parties for their own independent marketing purposes, and we never sell or rent your personal information to outside parties. Any disclosures of personal data to third parties are limited to the following circumstances:

Service Providers: We may share information with trusted third-party service providers and partners who perform services on our behalf and under our instructions. This can include, for example, IT hosting companies, website analytics providers, email delivery services, or compliance support services. These parties are only given the information necessary to perform their functions, and they are contractually obligated to keep your information confidential and use it solely for the purposes of providing services to Phichain Capital. We do not allow these service providers to use your data for their own marketing or any other purposes.

Legal Requirements and Protection: We may disclose personal information if we are required to do so by law or pursuant to a legal process (such as a subpoena, court order, or regulatory request). Additionally, if we believe in good faith that disclosure is necessary to protect our rights, safeguard your or others’ safety, investigate fraud, or respond to a government request, we may share information as needed. This includes cooperating with regulators and law enforcement authorities where legally obligated.

Business Transfers: In the event that Phichain Capital undergoes a business transaction such as a merger, acquisition, reorganization, or sale of assets, your personal information may be disclosed to the parties involved (e.g., to lawyers, auditors, or prospective purchasers) and ultimately transferred as part of that deal. If such a transfer occurs, we will ensure that the recipient of the data is bound to respect your personal information in a manner consistent with this Privacy Policy.

With Your Consent: In situations where you have explicitly given us consent to share your information with a third party (for example, if you request that we introduce you to a partner fund or service), we will share your data only as instructed by you. In general, unless one of the above conditions applies, your information stays within Phichain Capital and is used only for the purposes for which you provided it.

(To reiterate, Phichain Capital does not share personal data with third parties for their own marketing, and we do not engage in selling personal information.)
Data Storage and Security

We take data security seriously and employ industry-standard security measures to protect the personal information we hold. Phichain Capital maintains technical, administrative, and physical safeguards designed to prevent unauthorized access to or misuse of your data. These measures include, for example, secure server environments, encryption of data in transit (e.g., SSL/TLS for our website), firewalls and access controls to restrict access to data, and regular monitoring for vulnerabilities. We also limit access to personal information to only those employees, contractors, and agents who need to know such information in order to operate our business or provide services to you.

While we strive to protect your information, please note that no method of electronic transmission or storage is 100% secure. The internet by its nature cannot be guaranteed to be completely secure, and therefore we cannot warrant absolute security of your data. However, we continuously update and improve our security practices to meet or exceed industry best practices. In the unlikely event of a data breach affecting your personal information, we will notify you as required by applicable law.

We retain personal information only for as long as necessary to fulfill the purposes outlined in this Policy (or for such a longer period as may be required by law or our record-keeping policies). When personal information is no longer needed, we will securely destroy or anonymize it in accordance with our data retention procedures.
International Data Transfers

Phichain Capital is a U.S.-based company, but we serve individuals and organizations around the world. If you are accessing our website or submitting information from outside the United States, be aware that your personal information will be transferred to and processed in the United States (or other countries where we or our service providers operate). The data protection laws of these countries may differ from those in your home jurisdiction. By providing your information to us, you acknowledge that your data may be transferred internationally.
Whenever we transfer personal data from the European Economic Area (EEA), the United Kingdom, or other regions with data transfer restrictions, we take steps to ensure appropriate safeguards are in place to protect your information. In particular, we rely on standard contractual clauses or other approved transfer mechanisms to ensure that your data receives essentially the same level of protection abroad as it would under local law. For example, if we transfer EEA/UK personal data to the U.S. or another country, we will do so under the European Commission’s Standard Contractual Clauses or by ensuring the recipient is in a jurisdiction deemed adequate by the EU, or by obtaining your consent where required. We also implement technical and organizational security measures for these data transfers.

If applicable law in your country requires your consent for the international transfer of personal data, by using our site and providing information you are consenting to that transfer. We will comply with all legal requirements regarding international data transfers and will happily provide additional information on the safeguards we use upon request.

Privacy Policy

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