Privacy Policy

GOVERNANCE

Last Updated: As of November 2025

1. Overview

This Privacy Policy describes how .168 Capital (together with its subsidiaries and affiliates, “.168 Capital”, “we”, “us” or “our”) collects, uses, shares, and protects personal information about you when you:

communicate with us, and
visit this website and any other .168 Capital websites that link to this Privacy Policy (collectively, the “Sites”).

It also explains certain rights you may have in relation to your personal information under applicable law.

When you are an investor in a fund, vehicle, or structure managed or advised by us, or a job applicant, additional or separate privacy notices may apply (for example, subscription documents or a candidate privacy notice). Those documents will govern where applicable.

Please read this Privacy Policy carefully and consult our Terms of Use for additional terms governing your use of the Sites.

If you are a California resident, please review Section 14 – Additional Information for California Residents for disclosures under the California Consumer Privacy Act (as amended by the CPRA, together “CCPA”).

If you have any questions or concerns about this Privacy Policy, if you object to our use of your personal information, or if you wish to exercise your rights under applicable law, please contact us at:

Email: contact@168.capital

2. The Types of Information We Collect and How We Collect It

When you visit, browse, or use the Sites, or otherwise communicate with us, we may collect personal information directly from you, automatically from your devices, and from third parties.

“Personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked (directly or indirectly) with a particular individual or household, as defined under applicable law.

2.1 Information You Provide to Us

Depending on how you interact with us and which Site or service you use (including as a vendor, service provider, or business partner), we may collect the following categories of personal information directly from you:

Identifiers and similar information
Name, address, date and place of birth, email address, telephone number, national ID/passport details, tax identification number, driver’s license or other ID numbers, IP address, username, password, and other online identifiers.
Certain financial information
Signature, bank account or payment details, and other limited financial information where needed (e.g., to effect payments or verify identity under KYC/AML requirements for investors or partners).
Personal details / protected characteristics
In some contexts, characteristics of protected classifications under certain laws (e.g., gender, marital status), and in some cases data that may be considered “special category” or “sensitive” under applicable law (such as racial or ethnic origin), where necessary and permitted.
Commercial information
Records of products or services purchased, obtained, or considered; investment interests; investment history; and information relating to sources of wealth or transaction history, where relevant.
Education information
Non-public education information, including education history, degrees, certifications (particularly for applicants, counterparties, or key personnel).
Internet or electronic network activity information
Interactions with our Sites, online tools, and services (e.g., pages visited, actions taken).
Audio, electronic, visual, or similar information
Voicemail recordings, email content, and other communications you send to us.
Professional or employment-related information
Occupation, employer, role/title, professional licenses, certifications, and similar data.
Inferences
Inferences drawn from any of the above to create a profile reflecting preferences, behavior, or similar attributes, to the extent allowed by law and appropriate for institutional relationship management.

In certain secure or restricted areas of the Sites, you may be required to provide a username and password to gain access. If you choose not to provide required personal information, you may not be able to access some services or features.

2.2 Information We Collect Automatically

When you visit the Sites, we may automatically collect certain information from your device, which may be personal information, including:

IP address
browser type and settings
operating system
pages viewed on the Sites, time and date of visits, and duration
referring and exit pages
search terms entered on the Sites

We generally collect this information using cookies, log files, and similar technologies. For more information, see Section 4 – Our Use of Cookies and Similar Technologies.

If you communicate with us via email, phone, or other electronic channels, our systems may log details of those communications (including content where necessary) for compliance, security, and record-keeping purposes.

2.3 Information from Other Sources

We may receive personal information about you from:

service providers (e.g., hosting, analytics, CRM, KYC/AML, or compliance tools),
business partners and vendors,
third-party platforms or portals,
public sources (e.g., professional directories, regulatory filings, corporate records), and
where applicable, from third parties at your direction.

We may combine:

information collected online with information collected offline, and
information received from third parties with information you provide directly.

Where our use of information received from a third party is governed by that third party’s privacy policy, we will comply with such restrictions as applicable.

3. Links to Other Websites

The Sites may contain links to websites operated by third parties. If you choose to visit such sites, your personal information may be collected and processed by those third parties under their own privacy policies.

We do not control, endorse, or accept responsibility for the privacy practices, policies, or content of third-party sites. You access them at your own risk. We encourage you to review the privacy policies of any third-party site you visit.

4. Our Use of Cookies and Similar Technologies

We use cookies and similar technologies to:

understand how visitors use the Sites,
improve user experience and functionality,
enhance security,
support analytics and performance measurement, and
in limited cases, support marketing to institutional/professional users.

Technologies we use include:

Cookies – Small data files stored on your browser or device.
Log files – Record actions on the Sites (IP address, browser type, time/date stamps, etc.).
Web beacons / pixels – Small electronic images used to understand usage patterns or email engagement.
Social media widgets – Tools (e.g., LinkedIn, X/Twitter, YouTube) that may collect information in accordance with their providers’ privacy policies.

Types of cookies:

Strictly Necessary Cookies – Required for operation of the Sites (e.g., secure login).
Analytics/Performance Cookies – Help us understand how the Sites are used and improve them.
Functional Cookies – Remember your preferences (e.g., language, region, interface settings).
Advertising/Targeting Cookies – In limited cases, used to surface content relevant to institutional/professional users or to measure campaign effectiveness.

Your controls:

Adjust cookie settings in your browser (“options” or “preferences”).
Use third-party tools such as those referenced at allaboutcookies.org to manage or block cookies.

Note: Disabling cookies may affect functionality or access to some features of the Sites.

5. How We Use the Information We Collect

How we use your personal information may vary depending on your relationship with us and which Site or service you use. In general, we use personal information:

to provide and administer our Sites, services, and tools,
to support our institutional/investor relationships, and
to comply with legal and regulatory requirements.

Where required, we rely on a legal basis under applicable law (e.g., contract, legitimate interests, consent, legal obligation).

We may use your personal information to:

Respond to requests
Provide you with materials, information, or responses you request (legitimate interest and, where applicable, performance of a contract).
Manage and administer accounts and services
Create and maintain online or investor accounts; administer operational processes (performance of contract; legitimate interest in service delivery and record integrity).
Process transactions
Execute, manage, and record transactions and operational workflows (performance of contract; legal obligations).
Provide services you request
Deliver platform functionality, tools, and analytics requested by institutional or professional users (performance of contract; legitimate interest).
Prepare disclosures and reporting
Prepare investor communications, disclosures, or operational and risk reporting (legal obligations; legitimate interest in managing our business and informing stakeholders).
Improve Sites and services
Analyze usage data to improve Site performance, including troubleshooting, testing, and research (legitimate interest in improving services).
Maintain security and prevent fraud
Detect, prevent, and respond to security incidents, suspected fraud, or misuse (legal obligations; legitimate interest).
Communicate with you
Provide information about Site features, operational updates, changes to this Privacy Policy or Terms of Use, and, where permitted, information about .168 Capital products or services (consent where required; otherwise legitimate interest).
Internal operations and analytics
Data analysis, testing, research, and statistical purposes (legitimate interest).
Comply with laws and regulations
Meet legal, regulatory, and supervisory obligations in relevant jurisdictions.
Protect rights and interests
Establish, exercise, or defend legal claims and protect our rights, your rights, or the rights of others.

Where permitted by law, we may use information that does not identify you (and cannot reasonably be used to identify you) for any purpose, including aggregated analytics and research.

6. How We Share the Information We Collect

6.1 Third-Party Offers and Partners

Where you engage with offerings, tools, or services that involve third parties (for example, co-branded content, joint webinars, or integrations), we may share limited personal information (e.g., name, business contact details) with those third parties as necessary to deliver those offerings, subject to applicable law and any disclosures provided at the point of collection.

6.2 Service Providers

We may engage service providers to process personal information on our behalf in connection with:

hosting and IT infrastructure,
Site development and maintenance,
data storage and backup,
analytics and performance monitoring,
communications and email services,
cybersecurity and fraud prevention,
KYC/AML, compliance, or risk systems.

We require these service providers to handle personal information only in accordance with our instructions and applicable law, and to implement appropriate security measures.

6.3 Analytics Providers

We may use analytics providers to better understand how users interact with the Sites (for example, tools such as Google Analytics or comparable platforms). These providers may use cookies and similar technologies to collect information about use of the Sites and other online services over time.

Where required by local law, we will obtain consent before using analytics cookies or similar technologies.

6.4 Affiliates, Counterparties, and Professional Advisors

We may share personal information with:

our affiliates and subsidiaries,
transaction counterparties,
auditors, legal counsel, consultants, and other professional advisors,
financial institutions or intermediaries involved in a transaction, and
other parties where reasonably necessary for the purposes described in this Policy (e.g., to manage relationships, conduct diligence, or complete transactions).

6.5 Legal and Regulatory Disclosures

We may disclose personal information when we believe in good faith that such disclosure is:

required by applicable law, regulation, or legal process (e.g., court orders, regulatory requests),
necessary to protect our rights or enforce our Terms of Use,
necessary to detect, prevent, or address fraud, security, or technical issues, or
necessary to protect the rights, property, or safety of .168 Capital, our users, or others.

6.6 Corporate Transactions

We may share personal information as reasonably necessary in connection with the consideration, negotiation, or completion of a corporate transaction, such as a merger, sale, restructuring, or transfer of some or all of our assets.

6.7 De-Identified or Aggregated Information

We may share information that does not identify you and cannot reasonably be used to identify you with third parties for any purpose.

6.8 No Sale of Personal Information

We do not sell your personal information and have not done so in the 12 months preceding the effective date of this Privacy Policy, as “sell” is defined under the CCPA.

7. Security Measures

We implement commercially reasonable technical, administrative, and physical safeguards designed to protect personal information from unauthorized access, use, alteration, and disclosure.

However, no system or method of transmission over the Internet is completely secure. We cannot guarantee absolute security.

8. Updating Your Contact Information

You may update certain contact information and/or modify communication preferences by contacting us at:

Email: contact@168.capital

Where available, we may also provide online tools or account settings for updates.

9. Children’s Information

The Sites are intended for use by individuals who are 18 years of age or older. They are not directed at children under 13.

We do not knowingly collect personal information from children under 13 through the Sites. If we become aware that a child under 13 has provided personal information to us via the Sites, we will delete such information, except where retention is required to comply with law or protect the child or others.

10. Do Not Track

Some browsers and devices allow you to send “Do Not Track” (“DNT”) signals. We do not currently respond to DNT signals.

Third parties (e.g., analytics providers) may collect information about your online activities over time and across different websites or online services. Their handling of DNT signals is governed by their own privacy policies.

11. Your Choices and Rights

11.1 Marketing Communications

If you no longer wish to receive marketing communications from us, you may opt out by:

using any unsubscribe mechanism provided in the communication, or
contacting us at contact@168.capital

We may continue to send non-marketing communications (e.g., service announcements, legal notices).

11.2 Rights Under Data Protection Laws

Depending on your jurisdiction and subject to legal limitations, you may have some or all of the following rights:

Right of access – to obtain confirmation as to whether we process your personal information and to receive a copy.
Right to rectification – to correct inaccurate or incomplete personal information.
Right to erasure (“right to be forgotten”) – to request deletion of personal information in certain circumstances.
Right to restrict processing – to request that we limit our use of your personal information in certain cases.
Right to object – to object to processing where we rely on legitimate interests or use personal information for direct marketing.
Right to data portability – to receive personal information in a structured, commonly used, and machine-readable format and to transmit it to another controller where technically feasible.
Right to withdraw consent – where our processing is based on your consent.
Right to lodge a complaint – with a competent data protection authority.

If you are a California resident, please refer also to Section 14 – Additional Information for California Residents.

11.3 How to Exercise Your Rights

To exercise applicable rights, please contact us at:

Email: contact@168.capital

We will process your request in accordance with applicable law and may need to verify your identity before acting.

12. Where Information Is Processed

We may process and store personal information in the United States and in other countries where we or our service providers operate.

Some countries may not provide the same level of data protection as your home country. Where required, we will implement appropriate safeguards (such as Standard Contractual Clauses or equivalent mechanisms) or rely on another lawful transfer basis to ensure adequate protection of personal information transferred across borders.

13. How Long We Retain Information

We retain personal information for as long as necessary to:

maintain our relationship with you,
provide the services you request,
comply with legal, regulatory, and contractual obligations (including those related to financial services and record-keeping), and
establish, exercise, or defend legal claims within applicable limitation periods.

Retention periods may vary based on the type of information and the context in which it is collected.

14. Additional Information for California Residents (CCPA/CPRA)

If you are a California resident, the CCPA (as amended by the CPRA) provides certain rights with respect to your personal information. This section supplements the rest of this Privacy Policy and applies only to California residents.

For purposes of this section, “personal information” and other terms have the meanings given in the CCPA.

14.1 Notice at Collection

The categories of personal information we may collect, the purposes for which we use it, and the types of sources we obtain it from are described in:

Section 2 – The Types of Information We Collect and How We Collect It
Section 5 – How We Use the Information We Collect

We do not sell or share personal information as those terms are defined under the CCPA (including for cross-context behavioral advertising), and we do not knowingly sell or share the personal information of California residents under 16 years of age.

We retain personal information as described in Section 13 – How Long We Retain Information.

14.2 Your CCPA Rights

Subject to applicable exemptions and limitations, California residents may have the right to:

Know – Request that we disclose the categories and specific pieces of personal information we have collected about you in the preceding 12 months, as well as details about sources, purposes, and disclosures.
Delete – Request deletion of personal information we have collected from you, subject to exceptions (e.g., compliance with other laws, security, fraud prevention).
Correct – Request correction of inaccurate personal information.
Non-discrimination – Not be discriminated against for exercising CCPA rights.
Limit use and disclosure of sensitive personal information – If applicable under CCPA, limit our use and disclosure of sensitive personal information to certain purposes (note: we do not use sensitive personal information from website visitors in a way that triggers this right).

We do not sell or share your personal information, so opt-out rights relating to “sale” or “sharing” under the CCPA do not apply to our current practices.

14.3 Submitting a CCPA Request

You may submit a Request to Know, Request to Delete, or Request to Correct by contacting us at:

Email: contact@168.capital

We may request information necessary to verify your identity and the scope of your request. You may also designate an authorized agent to act on your behalf, subject to verification and documentation requirements.

We will respond within the timeframes required by the CCPA.

15. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal obligations, or for other operational reasons.

When we do so, we will revise the “As of” date at the top. Where required by law, we will provide additional notice of material changes.

Your continued use of the Sites after the effective date of any changes will constitute your acceptance of the updated Privacy Policy.

16. How to Contact Us

If you have any questions about this Privacy Policy, our privacy practices, or if you wish to exercise your rights, you may contact us at:

Email: contact@168,capital

This Privacy Policy is available in alternative formats upon request, where required by law.