Global Privacy Policy

Cosmius Capital ("Cosmius Capital," "we," "us," or "our") respects your privacy and is committed to protecting personal data. This Global Privacy Policy ("Policy") describes how we collect, use, disclose, and safeguard personal data in connection with our website, communications, and business activities, and it explains the rights available to individuals whose personal data we process, including rights under the General Data Protection Regulation ("GDPR") and other applicable data protection laws.

This Policy applies to personal data we collect from investors, prospective investors, business contacts, website visitors, job applicants, and other individuals who interact with Cosmius Capital. By using our website or otherwise providing personal data to us, you acknowledge the practices described in this Policy.

Cosmius Capital is the data controller responsible for the personal data described in this Policy, unless otherwise stated. Our registered address is:

Cosmius Capital
345 Park Avenue, 22nd Fl
New York, NY 10154

We may collect the following categories of personal data:

• Identification and contact data: name, title, employer, postal address, email address, and telephone number.
• Investor due diligence data: information provided in connection with investor onboarding, "know your customer" (KYC), anti-money laundering (AML), and suitability checks, including identification documents, financial information, and source of wealth/funds information.
• Professional and employment data: information submitted through job applications, including resumes, references, and employment history.
• Technical data: IP address, browser type and version, device information, operating system, and browsing behavior on our website, collected through cookies and similar technologies.
• Communications data: records of correspondence and communications between you and Cosmius Capital, including inquiries submitted through our website.

We collect personal data:

• Directly from you, when you complete forms on our website, submit an inquiry, or otherwise communicate with us.
• From third parties, such as service providers, administrators, regulators, and publicly available sources, in connection with due diligence and compliance obligations.
• Automatically, through cookies and similar tracking technologies when you visit our website.

We use personal data for the following purposes:

• To respond to inquiries and provide information about Cosmius Capital and our investment strategies.
• To perform due diligence, KYC, AML, and other regulatory or compliance obligations.
• To manage investor relationships and communications.
• To evaluate job applications and manage recruitment.
• To operate, maintain, and improve our website and communications.
• To comply with applicable laws, regulations, and legal processes.
• To protect the rights, property, and safety of Cosmius Capital, our personnel, and third parties.

Where the GDPR applies, we rely on one or more of the following legal bases to process personal data:

• Consent: where you have given clear consent for us to process your personal data for a specific purpose.
• Contractual necessity: where processing is necessary to perform a contract with you or to take steps at your request prior to entering into a contract.
• Legal obligation: where processing is necessary to comply with a legal or regulatory obligation, including AML and KYC requirements.
• Legitimate interests: where processing is necessary for our legitimate business interests, such as managing investor relationships or improving our services, provided such interests are not overridden by your data protection rights.

We may share personal data with:

• Affiliates and related entities of Cosmius Capital.
• Service providers who perform services on our behalf, including fund administrators, custodians, auditors, legal counsel, and technology providers.
• Regulators, government authorities, and law enforcement, where required by law.
• Professional advisors, such as auditors and legal counsel.
• A successor entity in connection with a merger, acquisition, or sale of assets.

We do not sell personal data to third parties.

Cosmius Capital is headquartered in the United States and may transfer, process, and store personal data in jurisdictions outside of the European Economic Area ("EEA"), the United Kingdom, and Switzerland. Where we transfer personal data originating from the EEA, UK, or Switzerland to a country that has not been deemed to provide an adequate level of data protection, we rely on appropriate safeguards, such as the European Commission's Standard Contractual Clauses, to ensure that personal data remains protected in accordance with this Policy and applicable law.

We retain personal data for as long as necessary to fulfill the purposes described in this Policy, including to satisfy legal, regulatory, tax, accounting, or reporting requirements. The criteria used to determine retention periods include the nature and sensitivity of the personal data, the purposes for which it is processed, and applicable legal and regulatory requirements.

We maintain administrative, technical, and physical safeguards designed to protect personal data against unauthorized access, disclosure, alteration, and destruction. While we take reasonable steps to protect personal data, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.

If the GDPR applies to the processing of your personal data, you have the following rights, subject to certain exceptions and limitations under applicable law:

• Right of access: to request confirmation of whether we process your personal data, and to obtain a copy of that data.
• Right to rectification: to request correction of inaccurate or incomplete personal data.
• Right to erasure: to request deletion of your personal data in certain circumstances.
• Right to restrict processing: to request that we limit the way we use your personal data in certain circumstances.
• Right to data portability: to request a copy of your personal data in a structured, commonly used, and machine-readable format.
• Right to object: to object to our processing of your personal data in certain circumstances, including for direct marketing purposes.
• Right to withdraw consent: where processing is based on consent, to withdraw that consent at any time.
• Right to lodge a complaint: with a supervisory authority in your country of residence, place of work, or the place of an alleged infringement, if you believe our processing of your personal data violates applicable law.

To exercise any of these rights, please contact us using the details provided in the "Contact Us" section below.

Our website may use cookies and similar tracking technologies to enhance your browsing experience, analyze website traffic, and understand where our visitors come from. You can control or disable cookies through your browser settings; however, doing so may affect the functionality of our website.

Our website and services are not directed to individuals under the age of 18, and we do not knowingly collect personal data from children. If we become aware that we have inadvertently collected personal data from a child, we will take steps to delete such information promptly.

We may update this Policy from time to time to reflect changes in our practices, legal requirements, or other operational reasons. We will post any updated version on this page with a revised "Last updated" date. We encourage you to review this Policy periodically.

If you have questions, concerns, or requests regarding this Policy or our data processing practices, or if you wish to exercise your data protection rights, please contact us at:

Cosmius Capital
345 Park Avenue, 22nd Fl
New York, NY 10154