Legal

Privacy Policy.

How Genesis Global Partners Holdings collects, uses, and safeguards personal information \u2014 in accordance with United States federal and state privacy law.

Effective: January 2025

Scope

This Privacy Policy describes how Genesis Global Partners Holdings (“Genesis,” “we,” “us”) collects, uses, discloses, and protects personal information of visitors to this website and prospective and existing investors. It is provided in accordance with applicable United States federal and state privacy laws, including the Gramm-Leach-Bliley Act (GLBA), the SEC’s Regulation S-P, and applicable state laws such as the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA).

Information We Collect

We collect information you provide directly when you submit an inquiry, request materials, or subscribe to a fund — including name, contact details, accreditation status, indicative allocation range, and any notes you choose to share. During onboarding we collect information required to verify accredited investor status under SEC Rule 501, including identification, financial documentation, and information required for anti-money-laundering and Know-Your-Customer compliance under the USA PATRIOT Act and the Bank Secrecy Act. We also collect limited technical information automatically, such as IP address, device type, browser, and pages visited.

How We Use Information

We use personal information solely to (i) evaluate fit and respond to inquiries, (ii) verify accredited investor status and complete subscription, (iii) operate, administer, and report on the funds, (iv) comply with legal, regulatory, audit, and tax obligations, and (v) detect and prevent fraud, security incidents, and unlawful activity. We do not sell personal information.

Disclosure of Information

We disclose personal information only to (i) affiliates and service providers acting on our behalf under written confidentiality obligations (including fund administrators, auditors, custodians, banks, legal counsel, and compliance vendors), (ii) regulators, self-regulatory organizations, and law enforcement when required by law, subpoena, or court order, and (iii) parties to a corporate transaction subject to confidentiality protections. We do not share personal information with non-affiliated third parties for their own marketing purposes.

Data Security

We maintain administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, alteration, disclosure, or destruction, consistent with the SEC’s safeguards rule under Regulation S-P and applicable state requirements. No method of transmission or storage is fully secure; we cannot guarantee absolute security.

Data Retention

We retain personal information for as long as necessary to fulfill the purposes described in this policy and to satisfy applicable legal, regulatory, tax, accounting, and recordkeeping requirements, including SEC and IRS retention periods. After that time, information is deleted or anonymized.

Your Rights

Depending on your state of residence, you may have rights to (i) request access to personal information we hold about you, (ii) request correction or deletion, (iii) opt out of certain disclosures, and (iv) appeal a denial of these rights. California residents have additional rights under the CCPA/CPRA. To exercise any right, contact us at invest@genesisglobalpartners.net. We will verify your request in accordance with applicable law before responding.

Cookies and Analytics

This website uses essential cookies required for functionality and limited analytics cookies to understand site usage. You can control cookies through your browser settings. We honor Global Privacy Control (GPC) signals where required.

Children

This site is not directed to children under 18, and we do not knowingly collect personal information from children. Investment in our funds is restricted to accredited investors as defined under U.S, securities law.

Changes to This Policy

We may update this Privacy Policy from time to time. The effective date below reflects the most recent revision. Material changes will be communicated through this page or, where appropriate, directly to investors of record.

Contact

Questions regarding this Privacy Policy or the handling of personal information may be directed to invest@genesisglobalpartners.net.

This Privacy Policy is provided for informational purposes and does not create a contractual right enforceable against Genesis Global Partners Holdings beyond what is required by applicable law.