Privacy Policy

FACTS

WHAT DOES TWENTY-FIVE CAPITAL DO WITH YOUR PERSONAL INFORMATION?

Why?

Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.

What?

The types of personal information we collect and share depend on the product or service you have with us. This information can include:

Social Security number and/or Employer Identification Number (EIN)
Account balances and financial account information
Subscription book certifications (for accreditation determinations)

How?

All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons Twenty-Five Capital chooses to share; and whether you can limit this sharing.

Reasons we share you personal information

Does Twenty-Five Capital share?

Can you limit this sharing?

For our everyday business purposes –
such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus

Yes

No

For our marketing purposes –
to offer our products and services to you

Yes

For joint marketing with other financial companies

No

We don't share

For our affiliates’ everyday business purposes –
information about your transactions and experiences

No

We don't share

For our affiliates to market to you

No

We don't share

For our nonaffiliates to market to you

No

We don't share

Who we are

Who is providing this notice?

Twenty-Five Capital LLC

What we do

How does Twenty-Five Capital protect my personal information?

To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings.

How does Twenty-Five Capital collect my personal information?

We collect your personal information, for example, when you

Open an account
Contact us
Engage in transactions with us
Give us your contact information or provide account information

Why can’t I limit all sharing?

Federal law gives you the right to limit only

sharing for affiliates’ everyday business purposes – information about your creditworthiness
affiliates from using your information to market to you
sharing for nonaffiliates to market to you

State laws and individual companies may give you additional rights to limit sharing. See below for more on your rights under state law.

Definitions

Affiliates

Companies related by common ownership or control. They can be financial and nonfinancial companies.

Nonaffiliates

Companies not related by common ownership or control. They can be financial and nonfinancial companies.

Why can’t I limit all sharing?

A formal agreement between non-affiliated financial companies that together market financial products or services to you.

Twenty-Five Capital doesn’t market or jointly market.

Other important information

California and Vermont Residents: We will not share information we collect about you with companies outside of Twenty-Five Capital (including with our affiliates) except as permitted by law and as described in this Privacy Policy.

TWENTY-FIVE CAPITAL PRIVACY POLICY

Effective Date / Date of Last Revision: March __, 2023

WHO WE ARE.
HOW TO CONTACT US.
WHY AND HOW WE COLLECT DATA.
PROTECTING YOUR PRIVACY GENERALLY.
CHILDREN’S PRIVACY.
TYPES OF INFORMATION WE COLLECT.
DO NOT TRACK SIGNALS.
HOW WE USE YOUR PERSONAL DATA.
INFORMATION WE SHARE WITH THIRD PARTIES.
HOW TO ACCESS & CONTROL YOUR PERSONAL DATA.
SECURITY.
DATA RETENTION.
ACCESSIBILITY.
NOTICE TO NEVADA RESIDENTS
NOTICE TO CALIFORNIA RESIDENTS.

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WHO WE ARE.

Twenty-Five Capital LLC (“Twenty-Five Capital,” “we,” “our” or “us”) executes a long/short equity strategy, utilizing a top-down approach. Twenty-Five Capital invests in U.S. equities across all GICS sectors in our long only fund and long/short fund. Twenty-Five Capital operates a partially publicly available website at http://xxvcapital.com/ (“Site”), where we provide information and opportunities to accredited investors (“Services”). When providing our Site and Services, we collect data from certain categories of individuals, such as our accredited investors, prospective customers and web site users.

Some of the data we collect may be considered “personally identifiable information,” “personal information” or “personal data” under applicable law (collectively referred to in this Privacy Policy as “Personal Data”). Generally, Personal Data is information that can be reasonably connected to an identified or identifiable individual. It does not include deidentified or anonymized data.

The purpose of this Privacy Policy is to plainly and transparently disclose to you how we collect, use and share information, and how we attempt to safeguard the data you provide to us. We are committed to securing data that we collect concerning you (“you”) and complying with applicable data protection and privacy laws.

HOW TO CONTACT US.

If you have any questions regarding data protection or your rights, please contact us:

Twenty-Five Capital LLC

1133 Broadway, Suite 1510

New York, NY 10010

917.825.9205

IR@xxvcapital.com

WHY AND HOW WE COLLECT DATA.

We collect, process and use Personal Data to allow you to utilize the functionality and features we provide on our Site, to provide you with Services, and to communicate with you. The legal basis for our collection of Personal Data is with your consent, for our legitimate business purposes and/or to comply with our legal and contractual obligations. We obtain Personal Data directly from you, through cookies and other technologies, and from third parties as described in this Policy and any other privacy notices we may provide to you when you interact with us.

Information from you. You provide data directly to us when you directly submit information to us (for example, when you send us information through a contact form).
Cookies & Technology. We collect data by automatically recording how you interact with our website and applications using technologies like cookies. More information on cookies is provided below.

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PROTECTING YOUR PRIVACY GENERALLY.

Industry-Standard Protection. We utilize industry-standard security measures to safeguard the information we collect, maintain and use. These measures include technical and procedural steps to protect your data from misuse, unauthorized access or disclosure, loss, alteration or destruction. However, we do not guarantee the performance or adequacy of such security measures.
Limitation on Access. Access to any Personal Data we collect and store is generally restricted to our employees and/or contractors who require it to perform a job or other contracted function. We require vendors and contractors we work with to use reasonable, industry standard protocols to maintain the confidentiality, security, and integrity of Personal Data.
Payment & Distribution. We currently do not collect payment card information or process payment cards. We make ACH and wire distributions to our investors through the bank that holds the operating accounts of the investment.

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CHILDREN’S PRIVACY.

We do not intentionally collect any Personal Data from children under the age of sixteen (16). We do not sell the Personal Data of children under the age of sixteen (16).

TYPES OF INFORMATION WE COLLECT.

Information We Collect From You. We collect the following categories of Personal Data:

Contact information (name, local and permanent address, telephone number, electronic mail address).
Your date of birth, gender and gender identity.
Your social security number (if investor is an individual) or your Employer Identification Number (if investor is an entity).
Your country of domicile.
Your financial account information.
Any other information you provide to us.

Information We Collect Via Tracking Technology. We use cookies and other tracking technologies (such as pixels and web beacons) (collectively, “Cookies”) to collect information as you navigate our websites. Cookies are small files of information that are stored by your web browser software on your computer hard drive, mobile or other devices (e.g., smartphones or tablets).

We use Cookies to: (a) estimate audience size and usage patterns; (b) understand and save your preferences for future visits, allowing us to customize the online experience to your individual needs; (c) advertise new content, events and services that relate to your interests; (d) keep track of advertisements and search engine results; (e) compile aggregate data about website traffic and website interactions to resolve issues and offer better online experiences and tools in the future; and (f) recognize when you return to our websites.

The Cookies we use collect the following types of Personal Data:

Usage Information. We collect information such as which areas of the sites you access, the frequency of access, and what you click on while using the sites.
Technical Information. We collect technical information about your connection to our sites, including the Internet protocol (IP) address, browser type and version, browser plug-in types and versions.
Device Information. We collect information about the device you are using, such as hardware model, operating system, application version number.
Mobile Device Information. In addition to the device information listed above, when you access our sites on your mobile device, we collect and aggregate information about whether you are accessing the sites via a mobile device or tablet, device type, and carrier.
Location Information. We collect location information from site visitors on a city-regional basis.

We set some Cookies ourselves and others are set by service providers. We use Cookies set by service providers to provide us with useful information to help us improve our sites, to conduct advertising, and to analyze the effectiveness of advertising. To manage your cookie settings, please view our cookie management center.

Google Analytics

We may use Google Analytics, a web analytics service provided by Google, Inc. Google Analytics uses Cookies or other tracking technologies to help us analyze how users interact with the Sites and Services, compile reports on their activity, and provide other services related to their activity and usage. The technologies used by Google may collect information such as your IP address, time of visit, whether you are a returning visitor, and any referring website. The technologies used by Google Analytics do not gather information that personally identifies you. The information generated by Google Analytics will be transmitted to and stored by Google and will be subject to Google’s privacy policies. To learn more about Google’s partner services and to learn how to opt-out of tracking of analytics by Google, click here.

How To Opt-Out of Cookies & Learn More. Cookies can be blocked by changing your settings to refuse all or some Cookies. If you choose to block all Cookies (including essential Cookies) you may not be able to access all or parts of the sites. You can find out more about Cookies and how to manage them by visiting www.AboutCookies.org. You can also learn about which third parties have currently enabled Cookies for your browser or mobile device and how to opt-out of some of those Cookies by accessing the Network Advertising Initiative’s website or the Digital Advertising Alliance’s website. For more information on mobile specific opt-out choices, visit the Network Advertising Initiative’s Mobile Choices website, Your Ad Choices, Your Online Choices and Global Privacy Control.

DO NOT TRACK SIGNALS.

Some internet browsers incorporate a “Do Not Track” feature that signals to websites you visit that you do not want to have your online activity tracked. Given that there is not a uniform way that browsers communicate the “Do Not Track” signal, the Site does not currently interpret, respond to or alter its practices when it receives “Do Not Track” signals.

HOW WE USE YOUR PERSONAL DATA.

We use the Personal Data we collect to:

Communicate with you;
Provide you with information;
Provide our Services;
Provide support;
Improve our Services;
Maintain and improve our Site;
Defend our legal rights and the rights of others;
Efficiently maintain our business; and
Comply with applicable law.

INFORMATION WE SHARE WITH THIRD PARTIES.

We do not sell personal data. We may share the information that we collect about you in the following limited ways:

With Service Providers. We may share information with service providers who:
- perform data services on our behalf (e.g., email, hosting, maintenance, backup, analysis, etc.);
- prepare, deploy and analyze advertising content on our behalf;
- provide other services on our behalf, such as accounting services, and other various services; and
- process payment information on our behalf.

To Meet Our Legal Requirements or Exercise Our Rights. We may share information with third parties in the following instances:

When we are required to do so by law.
In connection with any legal proceedings or prospective legal proceedings.
To establish, exercise, or defend our legal rights, including providing information to others for the purposes of fraud prevention.
When we reasonably believe it is appropriate to apply to a court or other competent authority for disclosure of that Personal Data where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that Personal data.

We may share information with other persons or entities as part of our own corporate transactions, such as during financing or any asset sale.

HOW TO ACCESS & CONTROL YOUR PERSONAL DATA

We respect your privacy and provide ways for you to choose whether to share your information with us or any third parties.

You may decline to provide information. You have the right to decide not to share information with us.

Request deletion. You may submit a request to update or delete your personal data by contacting us at us at IR@xxvcapital.com.

Please note, however, that if you choose not to provide us with certain information OR ASK US TO DELETE YOUR INFORMATION, we may not be able to provide you with SOME OF OUR OPPORTUNITIES OR SERVICES. IN ADDITION, IN SOME CIRCUMSTANCES, WE MAY NOT BE ABLE TO MODIFY OR DELETE DATA DUE TO OUR OWN OBLIGATIONS.

Review and request changes to your personal data. You may use your account to access, correct, or view certain personal data we have collected which is associated with your account. You may also contact us at IR@xxvcapital.com to request information or changes.

Marketing communications. You can always choose whether you wish to receive communications we send via email, SMS messages, telephone calls and postal mail. To do so, contact us at IR@xxvcapital.com.

Control Cookies. You may opt out of cookies through your account settings in the Sites or as described in Section 6 (b) above.

SECURITY.

When you register for an account with us, you will be required to choose or will be assigned a password which enables you to access our Sites. You are responsible for keeping this password confidential and for all activity that takes place through your account credentials. Do not share your password with anyone. If your password is compromised, change your password within your account. If you believe your password or account may have been compromised, please notify us immediately.

We take industry standard security measures to protect your information. We also have put into place appropriate agreements and/or procedures with our service providers to ensure that your Personal Data is treated consistent with applicable data privacy and security laws. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot and do not guarantee the security of your data.

DATA RETENTION.

We will store your Personal Data for as long as: (a) you maintain an account with us; (b) you continue using our Sites and Services; (c) your Personal Data is stored in our back up servers and/or services; (d) in accordance with our retention policies and schedules; and (e) as long as we are legally required to retain the Personal Data.

ACCESSIBILITY.

We are committed to ensuring this Privacy Policy is accessible to individuals with disabilities. If you wish to access this Privacy Policy in an alternate format, or would like to report an issue you are experiencing, please email us at IR@xxvcapital.com. You expressly agree to attempt to resolve any and all issues with accessibility directly with us and in good faith prior to instituting any legal action against us.

NOTICE TO NEVADA RESIDENTS

Nevada law allows Nevada residents to opt-out of the sale of certain types of personal information. Subject to a number of exceptions, Nevada law defines “sale” to mean the exchange of certain types of personal information for monetary consideration to a person for the person to license or sell the information to additional persons. We do not currently sell personal information as defined in the Nevada law. However, if you are a Nevada resident, you still may submit a verified request to opt-out of sales and we will record your instructions and incorporate them in the future if our policy changes. Opt-out requests may be sent to us at IR@xxvcapital.com.

NOTICE TO CALIFORNIA RESIDENTS

The California Consumer Privacy Act (“CCPA”) and the California Privacy Rights Act (“CPRA”) provide certain rights to California residents regarding the collection, use, disclosure, and sale of personal information. As of the date of last revision of this Privacy Policy, we were not / are not subject to the requirements of the CCPA or CPRA. If this changes, we will update our Privacy Policy. In the interim, of you would like to contact us to access and control your Personal Data, please see the options and tools we provide in Section 10 above and feel free to contact us with any questions.

SHINE THE LIGHT LAW: If you are a California resident, California Civil Code § 1798.83 permits you to request information regarding the disclosure of your personal information by us to third parties for the third parties’ direct marketing purposes (as those terms are defined in that statute). We do not sell or disclose information to third parties for their direct marketing purposes.