iConnections’ Privacy Policy

Effective Date: December 26, 2025

iConnections LLC (“we”, “us”, or “our”) provides this Privacy Policy (this “Policy”) to inform you about our collection, use, disclosure, and storage of data about you that we collect via this website, the iConnections platform, and the related services and offerings available on it (collectively, the “Platform”). Please review this Policy carefully. By registering an account for the Platform (whether as an investor, allocator, manager, or other user), or otherwise using the Platform, you agree to the terms and conditions of this Policy. We may update this Policy from time to time in our discretion, for example to keep up with changing laws regarding data processing. We will always keep the current version of this Policy posted on our website. By using the Platform after a new version of this Policy has been posted, you agree to the terms and conditions of such version of this Policy.

PUBLIC POSTINGS

Please keep in mind that certain information submitted to the Platform is publicly visible to other users within the Platform. For example, investor or allocator users may be able to view managers’ performance data in the Platform, and manager users may be able to view investors’ or allocators’ investment preferences in the Platform.

DATA WE COLLECT

“Personal Data” means information that can be used to identify you, and may include your name, email address, phone number, mailing address, birthdate, photograph, etc. We collect Personal Data that you voluntarily provide us, for example when you register a user account, when you provide it to us on a phone call, when you sign up for mailing lists or newsletters, register or pay for an event, verify your eligibility as an investor or manager, or otherwise reach out to us. Your submission of Personal Data is voluntary, but we may be unable to provide you requested information or services if you choose not to provide necessary Personal Data.

Following are the categories of Personal Data we may collect from you when you share it with us:

Identifiers (e.g., name, address, company, phone number, email address, internet protocol address, other similar identifiers)
Commercial information (e.g., interest in specific products and services, other similar information)
Internet or other electronic network activity information (e.g., internet protocol address, browser type, cookies used for identification, and information regarding a consumer’s interaction with the Website)

The Platform may offer you the ability to log in with, or otherwise connect, your third-party social media accounts. If you choose to use such social media accounts in this manner, you agree that we and the applicable third-party social media provider may exchange Personal Data to fulfill the purpose of the connection. You may connect your calendar with the Platform. The Platform calendar integration only checks the duration and free/busy status of the events in your calendar. We never store the information within the events on your calendar (e.g. event participants, event participant email addresses, the event title, or any other details about the appointments in your connected calendar.)

We may also collect and gather Personal Data through web-scanning of publicly available information, third-party sources, research surveys or phone interviews, or through direct contribution when users of the Platform contribute information about themselves or other people and companies in connection with their use of the Platform.

“Other Information” means information that does not identify you personally, and may include technical details regarding the device you use to access the Platform, IP address, operating system, browser, referral URLs, page views, location data (if location services are enabled), clicks, etc. Our systems automatically collect this kind of Other Information when you interact with the Platform. Other Information also includes information that may originally have been Personal Data but has been aggregated or anonymized such that it cannot be used to identify any individual.

COOKIES AND SIMILAR TECHNOLOGY

We use “cookies” to obtain certain types of data when your web browser accesses our website. Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser to enable our system to recognize you and your personalized settings, to better understand how you interact with the Platform, to monitor aggregate usage, and to optimize web traffic routing on our website. Most browsers have settings to disable or limit cookies, but please note that certain areas or features of the Platform may not be available or fully-functional if you choose to disable cookies for our websites. We may also use pixel tags, web beacons, or similar technologies to understand how our users interact with our sites and emails. Our website does not respond to “do not track” signals.

THIRD PARTY ANALYTICS

We use Google Analytics to better understand the behavior of visitors to our websites. This includes anonymized data associated with your IP address, such as pages viewed on the Website, length of time on the Website, browser used to access the sites, and device used to access the Website. The information collected does not personally or directly identify you or your street address. To learn more about how Google uses data when you visit our Website please visit: How Google uses information from sites or apps that use our services – Privacy & Terms – Google. You can opt out from the use of Google Analytics by following the instructed provided at: Google Analytics Opt-out Browser Add-on Download Page.

USE OF YOUR DATA

We use your Personal Data:

For the purposes for which you provided it to us (e.g., to create or update your user account, register you for promotions, newsletters, or events, or process a transaction, as applicable);
To verify your eligibility as a manager or investor;
To respond to your inquiries and communications to us;
To improve, maintain, and operate the Platform;
To inform you about opportunities, events, or services in which you may be interested, including those offered by our affiliates, subject to the SEC Marketing Rule;
To investigate and prevent possible fraud;
To exercise or defend our rights and comply with statutory and regulatory requirements, including responding to lawful requests for information by governmental authorities; and
For other reasons with your prior consent.

You can opt out of receiving promotional or marketing emails from us at any time by clicking the unsubscribe, opt-out, or similar link at the bottom of any such emails. Please note we may still contact you in connection with your account or any transactions involving you.

We may use Other Information (which does not identify you personally) for any manner we deem appropriate, including without limitation to improve, maintain, and operate the Platform, including to develop, train, and improve our AI-powered systems.

DISCLOSURE OF YOUR DATA

We will not sell or share your Personal Data to third parties. We may disclose or sub-process your Personal Data with our affiliates and as needed to fulfill the purposes described in the “USE OF YOUR DATA” section above, including:

With managers or investors with whom you may wish to communicate;
With a third party involved in hosting or supporting an event using the Platform;
With our service providers, such as email service providers, customer support providers, and payment processors, who are only permitted to use the data on our behalf;
As necessary to exercise or defend our rights or comply with applicable law or orders from law enforcement and other governmental authorities; and
To other third parties with your prior consent.

Additionally, in the event of a merger, consolidation, sale, or transfer of all or substantially all of our assets or business, one of the assets that would generally be transferred is the data we have collected, which would be transferred subject to the applicable version of this Policy.

We have disclosed for a business purpose to one or more third parties the following categories of Personal Data that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a consumer:

Identifiers (e.g., name, address, company, phone number, email address, internet protocol address, other similar identifiers)
Commercial information (e.g., interest in specific products and services, other similar information)
Internet or other electronic network activity information (e.g., internet protocol address, browser type, cookies used for identification, and information regarding a consumer’s interaction with the Website)

We may disclose Other Information (which does not identify you personally) to any parties and for any purposes we deem appropriate.

LOCATION; DATA RETENTION, ACCESS, AND CORRECTION; SECURITY

We are based in the United States. By using the Platform, you consent to your Personal Data being transferred to and stored in the United States. We may retain your data so long as we can reasonably foresee the data may be required in connection with our business relationship with you. In some cases, we will retain the data for a longer period as necessary to comply with our legal obligations, follow records retention policies, resolve disputes, and enforce our agreements. You may access and update your Personal Data by visiting your account profile.

We have implemented commercially reasonable physical, organizational, and technical procedures to secure the Personal Data we have in our possession. Unfortunately, no measures can be guaranteed to provide 100% security when dealing with internet connections.

YOUR U.S. STATE RIGHTS

You may be entitled the following privacy rights listed below based on various state privacy laws, including if you are a resident of California, Colorado, Connecticut, Florida, Oregon, Texas, Utah, and Virginia:

The rights to know/access. You may have the right to request to access or know (i) the specific pieces of Personal Data we have about you; (ii) the categories of Personal Data we have collected about you; (iii) the categories of sources from which that Personal Data was collected; (iv) the categories of Personal Data we have sold or disclosed; (v) the categories of third parties to whom your Personal Data was sole or disclosed; and (vi) the purposes for collecting and selling your Personal Data. Generally:
- iConnections has collected the categories of Personal Data detailed in the section titled “Data We Collect” above.
- iConnections has disclosed the categories of Personal Data detailed in the section titled “Disclosure of Your Data” above.
The right to correction. You may have the right to request that we correct the Personal Data that we have collected or maintain about you.
The right to data portability. You may have right to request your Personal Data in a format that is portable and useable.
The right to deletion. You may have the right to request that we delete the Personal Data that we have collected or maintain about you. We may deny your request under certain circumstances, such as if we need to comply with our legal obligations or complete a transaction for which your Personal Data was collected. If we deny your request for deletion, we will let you know the reason why.
The right to restrict or opt out of the sale of your Personal Data. You may have the right to opt out of the sale of your Personal Data. We do not sell your Personal Data. If this changes we will update our privacy policy accordingly.
The right to equal service. If you choose to exercise any of these rights, we will not discriminate against you in any way. If you exercise certain rights, understand that you may be unable to use or access certain features of our services.

You may request your right to know and your right to deletion free of charge up to two (2) times in any twelve (12) month period.

To exercise the rights described above, please contact us as follows:

Email: privacy@iconnections.io (please use “Consumer Privacy” in the subject line)

We may require verification of your identity before further processing your request. In certain instances, we may be permitted by law to decline some or all of such request.

YOUR EUROPEAN UNION, UK, SWISS PRIVACY RIGHTS

If you are a European Union, UK, or Swiss resident, the legal bases for our processing of Personal Data about you are as follows:

Contract: When you purchase a product or service from us, we collect Personal Data about that is necessary for completing that transaction and delivering the product or service to you;
Consent: We obtain your consent to collect Personal Data for distinct purposes such as receiving marketing communications from us, subject to SEC marketing rules. You have the right to withdraw your consent at any time.
Legitimate Interest: We have a legitimate interest to collect Personal Data about you for certain purposes such as data analytics and the protection and administration of the Website so that we can (i) understand our customers’ preferences and improve the product selection available on the Website; (ii) to protect the Website from information security threats and our Company in connection with legal claims and proceedings; (iii) to communicate administrative changes in connection with the use of the Website; and (iv) to comply with laws that apply to us and the Website.

If you are a European Union, UK, or Swiss resident, applicable data protection laws may provide you with certain rights with regards to our processing of your Personal Data. To the extent established under applicable law, European Union, UK, or Swiss residents may have the right:

To access, review, and update their Personal Data;
To correct incomplete, outdated, or incorrect Personal Data;
To restrict our processing of their Personal Data;
To request that we provide them a copy of, or access to, their Personal Data in structured, commonly used and machine-readable format (or that we transfer their Personal Data to another controller, when technically feasible);
To withdraw their consent when our processing of their Personal Data is based on consent (and not another legitimate basis);
To request that we delete their Personal Data (subject to certain limitations); and
To lodge a complaint with the applicable supervisory authority. Before you do this, we ask that you please contact us directly in order to give us an opportunity to work directly with you to resolve any concerns about your privacy.

We do not engage in or have features that engage in automated decision making. If this changes, we will update this Policy accordingly.

To make any of the above requests, please contact us as set forth at the end of this Policy. We may require verification of your identity before further processing your request. In certain instances, we may be permitted by law to decline some or all of such request. Please note that if you make unfounded, repetitive, or excessive requests (as determined in our reasonable discretion) to access your Personal Data, you may be charged a fee to the extent permitted by law.

CHILDREN

The Platform is not directed toward children under 13. If a parent or guardian becomes aware that his or her child has provided us with Personal Data, the parent or guardian should contact us as set forth at the end of this Policy, and we will take reasonable steps to promptly remove such data from our systems (subject to any applicable, legally required or permitted, retention standards).

THIRD PARTY SITES

The Platform may include links to third party sites and services. If you visit or use such third party sites and services, please be mindful that the relevant third party controls the cookies and other technologies it uses on its sites and how it collects, uses, and shares your Personal Data. This Policy only governs our own privacy practices; please review the applicable third party privacy policy when visiting or using any third party sites or services.

CONTACT

For more information or for help in answering any questions, please contact us at privacy@iconnections.io.