Privacy Policy

Effective Date: [Date to be confirmed] Last Updated: [Date to be confirmed]

SOEL Equity respects the privacy and security of its investors, prospective investors, website visitors, and other users.

This Privacy Policy explains how [Legal entity name to be confirmed], doing business as SOEL Equity ("SOEL Equity," "SOEL," "we," "our," or "us"), may collect, use, disclose, retain, and protect personal information when you interact with our websites, investor portal, applications, communications, and related services.

This Privacy Policy should be read together with our Terms of Use and other applicable notices.

1. Information We May Collect

Depending on how you interact with SOEL Equity, we may collect the following categories of personal information.

A. Identification Information

Examples may include:

• name;
• date of birth;
• mailing address;
• email address;
• telephone number;
• government-issued identification information;
• taxpayer identification information;
• citizenship or residency information.

We should collect sensitive identification information only when necessary for legitimate business, regulatory, compliance, tax, security, or transaction purposes.

2. Investor Profile Information

We may collect information such as:

• investor type;
• investment interests;
• investment experience;
• expected investment range;
• accredited investor status;
• accreditation verification information;
• entity ownership;
• beneficial ownership;
• authorized representatives;
• eligibility information;
• investor preferences.

3. Financial Information

Where necessary for investor onboarding or transactions, we may collect or process information such as:

• bank-account information;
• wire instructions;
• investment commitments;
• investment balances;
• contribution records;
• distribution records;
• ownership interests;
• tax information;
• financial qualification information;
• source-of-funds information where required.

Certain information may be collected directly by trusted third-party financial, payment, banking, verification, or investor-administration providers rather than stored directly by SOEL Equity.

4. Accreditation Information

Depending upon applicable offering requirements, we may collect or receive:

• accreditation self-certifications;
• third-party verification results;
• attorney verification;
• accountant verification;
• broker-dealer or investment-adviser verification;
• documentation relating to income or net worth where legally appropriate;
• verification dates and status.

Where possible, SOEL Equity may rely on qualified third-party verification services so that sensitive underlying documents do not need to be retained by SOEL Equity.

5. Entity Information

If you invest through a legal entity, we may collect:

• entity name;
• entity type;
• formation jurisdiction;
• tax information;
• ownership information;
• beneficial owners;
• managers;
• trustees;
• authorized signatories;
• formation documents;
• organizational documents.

6. Investment and Transaction Information

We may maintain information regarding:

• investment opportunities viewed;
• deal access granted;
• subscription activity;
• investment amounts;
• investments held;
• distributions;
• statements;
• investment documents;
• signed agreements;
• tax documents;
• communications concerning investments.

7. Communications

We may collect communications you send to us, including:

• emails;
• support inquiries;
• investor-relations communications;
• messages sent through the Platform;
• feedback;
• requests for information;
• meeting or call information where legally permitted.

8. Device and Usage Information

When you use our websites or applications, we may automatically receive information such as:

• IP address;
• browser type;
• device type;
• operating system;
• login activity;
• pages viewed;
• referring pages;
• session information;
• authentication activity;
• approximate location derived from IP address;
• security logs.

We may use this information for security, fraud detection, platform functionality, analytics, and performance.

9. Cookies and Similar Technologies

SOEL Equity may use cookies, session technologies, analytics tools, or similar technologies where actually implemented.

These technologies may help us:

• keep users logged in;
• secure accounts;
• remember preferences;
• understand Platform usage;
• improve functionality;
• prevent fraud;
• measure website performance.

Where legally required, we will provide appropriate choices regarding non-essential cookies.

SOEL Equity should not state that advertising cookies or tracking technologies are used unless those technologies are actually implemented.

10. Sources of Information

We may collect information:

• directly from you;
• from entities you represent;
• from authorized representatives;
• from accreditation-verification providers;
• from identity-verification providers;
• from banking or payment providers;
• from professional advisers;
• from compliance-service providers;
• from public records where legally permitted;
• automatically through Platform usage.

11. How We Use Personal Information

We may use personal information to:

• provide and operate the Platform;
• process investor-access requests;
• create and maintain accounts;
• determine investor eligibility;
• verify accredited investor status where required;
• verify identity;
• perform compliance reviews;
• process investment subscriptions;
• administer investments;
• process contributions and distributions;
• provide statements and tax documents;
• manage investor communications;
• provide access to private deal rooms;
• maintain transaction records;
• prevent fraud;
• protect Platform security;
• enforce agreements;
• comply with legal obligations;
• respond to requests;
• improve our technology and services.

12. How We May Disclose Information

We may disclose personal information to service providers and other parties when reasonably necessary for legitimate business or legal purposes.

These may include:

• investment entities or issuers;
• fund administrators;
• transfer or investor administrators;
• banks and payment providers;
• accreditation-verification providers;
• identity-verification providers;
• KYC/AML providers;
• electronic-signature providers;
• accountants;
• auditors;
• attorneys;
• tax professionals;
• cloud infrastructure providers;
• database providers;
• cybersecurity providers;
• communications providers;
• analytics providers;
• governmental or regulatory authorities where required.

Service providers should receive only information reasonably necessary for the services they perform.

13. We Do Not Sell Investor Information

SOEL Equity does not intend to sell investor personal information for monetary consideration.

If SOEL Equity ever engages in activities defined as a "sale" or "sharing" of personal information under applicable privacy laws, we will provide legally required notices and choices.

This statement must be updated if SOEL Equity's actual data practices change.

14. Confidential Financial Information

SOEL Equity treats investor account information, financial information, statements, tax information, identity information, and investment records as sensitive information.

Access should be limited to:

• the applicable investor;
• authorized representatives;
• authorized SOEL Equity personnel;
• service providers with a legitimate need for access;
• parties legally entitled to receive the information.

15. Security

SOEL Equity uses reasonable administrative, technical, and organizational safeguards designed to protect personal information.

Depending on the system and information involved, safeguards may include:

• encryption in transit;
• encryption at rest where appropriate;
• access controls;
• role-based permissions;
• multi-factor authentication;
• private file storage;
• logging and monitoring;
• authentication controls;
• security reviews;
• vendor-management controls.

No system can guarantee absolute security.

Users should protect account credentials and promptly report suspected unauthorized access.

16. Data Minimization

SOEL Equity seeks to collect only information reasonably necessary for legitimate business, investment, legal, compliance, and security purposes.

We may use third-party providers to verify information without retaining unnecessary underlying sensitive documents where practical.

17. Retention

We may retain personal information for as long as reasonably necessary to:

• maintain an investor relationship;
• administer investments;
• fulfill contractual obligations;
• satisfy tax requirements;
• comply with securities laws;
• comply with recordkeeping obligations;
• prevent fraud;
• resolve disputes;
• enforce agreements;
• protect legal rights.

Retention periods may vary by information type and applicable legal requirement.

18. Private Investor Documents

Private documents such as:

• investor statements;
• subscription agreements;
• tax forms;
• accreditation records;
• banking records;
• investment documents

should be stored using restricted-access systems.

SOEL Equity should not intentionally make private investor documents publicly accessible.

19. Third-Party Platforms

SOEL Equity may use third-party technology to provide portions of the Platform.

Those providers may process information under their own privacy obligations and contractual arrangements with SOEL Equity.

Third-party providers may include providers of:

• hosting;
• authentication;
• databases;
• payment processing;
• investor administration;
• identity verification;
• accreditation verification;
• electronic signatures;
• communications;
• analytics.

20. Links to Other Websites

The Platform may contain links to third-party websites.

SOEL Equity is not responsible for the privacy practices of independent third parties.

You should review their privacy policies before providing personal information.

21. California Privacy Rights

If SOEL Equity is subject to the California Consumer Privacy Act, as amended by the California Privacy Rights Act, California residents may have rights that include, subject to applicable exceptions:

• the right to know categories and specific pieces of personal information collected;
• the right to know sources of personal information;
• the right to know purposes for collecting or using information;
• the right to know categories of third parties receiving information;
• the right to request deletion;
• the right to request correction;
• the right to opt out of certain sales or sharing;
• the right to limit certain uses of sensitive personal information where applicable;
• the right not to receive discriminatory treatment for exercising applicable privacy rights.

Some financial information or activities may be subject to exemptions under applicable financial privacy laws.

22. California Requests

Where applicable, California residents may submit requests concerning their privacy rights by contacting:

Email: [Privacy email to be confirmed]

Web Form: [Privacy request form to be confirmed]

Telephone: [Telephone number to be confirmed, if required]

SOEL Equity may need to verify your identity before processing a request.

Authorized agents may submit requests where permitted by law and subject to appropriate verification.

23. Notice at Collection

Where required, SOEL Equity will provide appropriate notice at or before collecting personal information.

Such notice may identify:

• categories of information being collected;
• purposes for collection;
• whether information is sold or shared where applicable;
• retention information where required;
• a link to this Privacy Policy.

24. Other State Privacy Rights

Residents of certain U.S. states may have additional rights concerning their personal information.

Where applicable, SOEL Equity will honor rights required by the privacy laws governing the relevant individual and processing activity.

25. Financial Privacy Laws

Depending on SOEL Equity's legal structure and services, certain investor information may be subject to federal or state financial privacy requirements.

Where applicable, SOEL Equity will provide any additional privacy notices required by laws governing nonpublic personal financial information.

A separate financial privacy notice may be provided where required.

26. Children

The SOEL Equity Platform is intended for adults and is not designed for children under 18.

We do not knowingly use the Platform to solicit investment accounts from children.

If we learn that information from a child has been collected improperly, we will take reasonable steps to address the issue.

27. International Users

If SOEL Equity allows investors or visitors outside the United States, additional privacy laws may apply.

Before expanding investor onboarding internationally, SOEL Equity should implement appropriate jurisdiction-specific privacy and data-transfer requirements.

28. Email and Communication Preferences

You may be able to unsubscribe from certain marketing communications.

However, SOEL Equity may continue to send transactional or administrative communications concerning:

• your account;
• security;
• investments;
• statements;
• documents;
• compliance matters;
• legal notices.

29. Data Breach and Security Incidents

If SOEL Equity experiences a security incident involving personal information, we will investigate and provide notices where required by applicable law.

30. Changes to This Privacy Policy

SOEL Equity may update this Privacy Policy periodically.

The "Last Updated" date will identify the most recent version.

Where required, we will provide notice of material changes.

31. Contact SOEL Equity

Questions or requests concerning this Privacy Policy may be directed to:

SOEL Equity Legal Entity: [Legal entity name to be confirmed] Address: [Business address to be confirmed] Privacy Email: [Privacy email to be confirmed] Telephone: [Phone number to be confirmed]

32. Legal Entity and Regulatory Disclosure

"SOEL Equity" may be a brand or trade name.

The legal entity responsible for your information should be clearly identified in the final published version of this Privacy Policy.

Nothing in this Privacy Policy should be interpreted as representing that SOEL Equity is a registered broker-dealer, registered investment adviser, bank, financial institution, or other regulated entity unless that representation has been independently confirmed and is legally accurate.