Privacy Policy

1. Controller & Contact Information

Data Controller: Sea Point Capital Partners, LP

Website: https://seapoint.capital

Address: 1000 Brickell Ave, Ste 715, PMB 2173, Miami, FL 33131, United States

General Contact / Privacy & Compliance: compliance@seapoint.capital

2. What personal information we collect

We collect personal information you provide directly through the Site and information collected automatically when you visit the Site.

Personal information you provide directly

• Contact & identity: Full name, email address, phone number, job title, company name, country of residence — submitted via the contact form or the "Request Information" form.
• Interest form data: Message text, investment interest, and consent to receive communications, submitted through the interest registration form on the Site.

Information collected automatically

• Technical data: IP address, device type, browser, operating system, pages viewed, timestamps, referring URLs.
• Cookies & tracking: Cookies, device identifiers and similar tracking that enable analytics, performance monitoring, fraud detection, and personalization. See our Cookie & Tracking section below.

3. Legal bases for processing (EU / EEA GDPR)

To the extent the GDPR applies, our legal bases include:

• Contract necessity: Processing necessary to respond to your inquiry or fulfill pre-contractual obligations.
• Legitimate interests: For business communications, fraud detection, site security, analytics, and product improvement (balanced against individual rights). We will document legitimate interest assessments.
• Consent: For non-essential cookies and direct marketing (where required). You may withdraw consent for cookies at any time (see Cookie & Tracking section).

Under other laws (e.g., CCPA), we rely on similar bases such as contract necessity, legitimate interests, and compliance with legal obligations.

4. How we use your personal information

We use personal information for the following purposes, consistent with the legal bases above:

• To respond to requests & communications: To respond to inquiries submitted via the Site, handle support requests, and process Data Subject Requests (access, rectification, erasure, portability, objection).
• Interest registration: To record and manage expressions of interest submitted through the "Request Information" form and to follow up as appropriate.
• Compliance & legal obligations: To comply with applicable laws and lawful requests from regulators or courts.
• Security & fraud prevention: To detect, prevent and remediate fraud, abuse, security incidents, or other malicious activity.
• Analytics & product improvement: To analyze use of the Site and improve our offerings (subject to cookie consent where required).
• Marketing & communications: With your consent (or where permitted by law), to send marketing materials, newsletters and event invitations. You can opt out at any time.
• Record retention & audit: To maintain records for regulatory, auditing and legal defense purposes.

5. Disclosure & sharing of personal information

We may share personal information with the following categories of recipients:

• Service providers who perform operational, technology, legal, or administrative services on our behalf. These providers process data under contract and only for specified purposes.
• Professional advisers and counsel, including our legal and tax advisers.
• Regulators, law enforcement or courts, where required by law or to defend legal rights.
• Acquirers or affiliates: In the event of a merger, sale, reorganization, or similar corporate transaction, personal data may be transferred in connection with the transaction subject to confidentiality and data safeguards.
• Analytics & marketing vendors, only with consent where required by law.

When we share personal data we require vendors to provide contractually binding commitments to protect the data, process only as instructed, and implement appropriate security measures.

6. International transfers & data location

Personal data we collect is primarily stored and processed in the United States. We may transfer personal data to jurisdictions outside your country of residence where our service providers operate, including the United States and Cayman Islands (for feeder fund administration), and other jurisdictions. Where required by law, we put in place appropriate safeguards for transfers (standard contractual clauses, data processing agreements, and/or binding corporate rules).

7. Data retention & deletion

We retain personal data only as long as necessary to fulfill the purposes described in this Policy, to satisfy legal, tax and regulatory obligations, and to resolve disputes. Our standard retention periods include:

• Contact and interest-form records: retained for as long as necessary to respond to your inquiry or manage your interest registration, and thereafter as required by applicable law.
• Marketing and cookie consent records: retained while consent is active; consent records are retained for evidence of consent.
• Audit logs & system logs: retained per internal policy and applicable law.

If you request deletion of your personal information, we will follow the deletion workflow described in our Data Subject Request procedures, subject to legal, contractual and regulatory exceptions. Deletion requests may be limited where retention is required by law.

8. Cookies, tracking & targeted advertising

We use cookies, pixels and similar technologies for site functionality, analytics, security and advertising. We categorize cookies as follows:

• Strictly necessary: Required to operate the Site (session management, security). These do not require consent.
• Performance & analytics: For measuring site usage and improving performance (e.g., GA4). Consent is requested where required.
• Functional: For optional features and preferences.
• Advertising & targeting: For marketing and remarketing. We only deploy these with consent.

We display a cookie consent banner for EU/EEA visitors and applicable visitors under local law. You can manage cookie preferences through the banner or the cookie management tool linked in the Site footer. To opt out of certain analytics or ad cookies, follow the instructions in the cookie tool.

Third-party trackers: We use third-party analytics and marketing services. These providers collect data under their own privacy policies. Where required, we only enable these services after receiving your consent.

9. Your rights (EU/EEA, UK, and certain other jurisdictions)

Subject to applicable law, you may have the following rights over your personal data:

• Access: Request a copy of personal data we hold.
• Rectification: Request correction of inaccurate or incomplete data.
• Erasure ("right to be forgotten"): Request deletion of personal data where there is no overriding legal basis to retain it.
• Restriction: Request limitation of processing under certain conditions.
• Portability: Request a machine-readable copy of data you provided.
• Objection: Object to processing based on legitimate interests or for direct marketing.
• Withdraw consent: Withdraw consent where processing relies on consent.
• Complain to a supervisory authority: If you are in the EU/EEA/UK, you may lodge a complaint with your local data protection authority.

To exercise any right, contact us at compliance@seapoint.capital. For security, we will take reasonable steps to verify your identity before fulfilling requests. We will respond in accordance with applicable law.

10. Data subject request and deletion workflow

• Submit request: Use the data subject request form on the Site or email compliance@seapoint.capital.
• Verification: We will verify your identity to prevent unauthorized disclosures.
• Response & timing: We aim to respond within statutory timeframes (e.g., 30 days where applicable) but may extend as allowed by law.
• Exceptions: Requests may be limited where retention is required by law, for compliance, tax, or litigation reasons. We will explain any refusal.

11. Security

We maintain reasonable administrative, technical and physical safeguards to protect personal data. Measures include encryption of data in transit, access controls, logging and monitoring, and incident response policies. We require vendors to implement commensurate safeguards.

No system is perfectly secure. If we learn of a security incident involving personal data that creates a risk to your rights, we will notify affected individuals and regulators as required by law.

12. Children & Minors

The Site is not directed to children and we do not knowingly collect personal data from individuals under the age of 18. If you believe we have collected information from a minor, contact us at compliance@seapoint.capital and we will promptly investigate and, where required, delete the information.

13. Changes to this Policy

We may update this Privacy Policy to reflect legal, business or operational changes. The "Last updated" date above will be revised for material changes. For significant changes we will provide notice (for example, via the Site or direct email to registered users). Continued use of the Site after notice constitutes acceptance.

14. Third-party links & embedded content

The Site may contain links to third-party websites. Sea Point is not responsible for the privacy practices of those sites. Please review their privacy notices before providing personal data.

15. Contact & complaints

For privacy inquiries or to submit a Data Subject Request, contact:

Privacy & Compliance: compliance@seapoint.capital

If you believe we have not addressed your privacy concern, you may have the right to lodge a complaint with the competent data protection authority in your jurisdiction.