1. INTRODUCTION & SCOPE

This Privacy Policy (“Policy”) governs how Achelion Capital Management, LLC (“Achelion Capital,” “we,” “our,” or “us”) collects, processes, retains, and protects information obtained from visitors to our website, prospective investors, limited partners, counterparties, and other individuals and entities who interact with our firm (collectively, “you” or “Data Subjects”).

Achelion Capital Management, LLC operates as a private fund adviser and makes notice filings in the State of Texas in reliance on applicable exemptions from investment adviser registration. The firm is not registered as an investment adviser with the U.S. Securities and Exchange Commission or any state securities authority. Such notice filings do not constitute approval, endorsement, or supervision by any regulatory authority.

Achelion Capital operates as a private investment management firm focused on AI infrastructure equities and digital asset strategies. Given the sensitive nature of our operations and the information entrusted to us, we maintain strict privacy standards that are designed to comply with applicable legal requirements.

This Policy applies to all digital touchpoints, communications, and data collection activities associated with Achelion Capital, including our website, investor portal, subscription materials, and direct communications.

2. INFORMATION WE COLLECT

2.1 Information You Provide Directly

• • Identity information: full legal name, date of birth, nationality, government-issued identification
  • Contact information: email addresses, mailing addresses, telephone numbers
  • Financial and accreditation information: net worth declarations, income verification, investment history, and documentation required to confirm Qualified Purchaser or Accredited Investor status
  • Subscription and transactional data: fund subscription documents, capital commitment amounts, banking and wire transfer instructions
  • Communications: correspondence, inquiries, and any information you voluntarily submit to us

 

2.2 Information Collected Automatically

• • Technical data: IP addresses, browser type and version, device identifiers, operating system, referral sources
  • Usage data: pages visited, time on site, clickstream data, and interaction patterns
  • Cookie and tracking data: as further described in Section 7 below

2.3 Information Received from Third Parties

• • Identity verification services and KYC/AML compliance providers
  • Financial data aggregators and market data providers
  • Publicly available sources including regulatory filings and professional directories
  • Placement agents, finders, and referral sources acting in a lawful capacity

Your use of this Site does not create any advisory, fiduciary, or client relationship between you and Achelion Capital. Any offer or solicitation of interests in any investment vehicle managed by Achelion Capital will be made only pursuant to confidential offering documents and in accordance with applicable law.

3. HOW WE USE YOUR INFORMATION
We process personal information only for legitimate business purposes, including:

• Evaluating eligibility for investment in funds managed by Achelion Capital
• Fulfilling regulatory and compliance obligations, including KYC, AML, FATCA, and applicable securities law requirements
• Managing investor relationships, capital accounts, and fund administration
• Communicating material information about fund operations, performance, and strategy developments
• Responding to inquiries and providing requested information or materials
• Improving our website, investor communications, and operational processes
• Protecting against fraud, unauthorized access, and other security threats
• Complying with court orders, regulatory requests, and legal processes

 

4. LEGAL BASIS FOR PROCESSING
To the extent applicable data protection laws require a lawful basis for processing, we rely upon the following:

• Contractual necessity: Processing required to enter into or perform a fund subscription agreement, Limited Partnership Agreement, or other contractual relationship
• Legal obligation: Processing required to comply with securities regulations, tax law, anti-money laundering statutes, and other applicable law
• Legitimate interests: Processing necessary for our legitimate business interests, including fraud prevention, firm security, and investor communications, where such interests are not overridden by your privacy rights
• Consent: Where we rely on your explicit consent, which you may withdraw at any time without affecting prior processing

 

5. INFORMATION SHARING AND DISCLOSURE
Achelion Capital does not sell, rent, or trade personal information. We may share your information in the following limited circumstances:

5.1 Service Providers and Agents
We engage third-party service providers who process data on our behalf under strict contractual obligations, including fund administrators, custodians, legal counsel, auditors, technology providers, and compliance consultants. These parties are prohibited from using your information for any purpose beyond their specific service engagement.

5.2 Regulatory and Legal Disclosure
We may disclose information as required by applicable law, regulation, court order, or government authority, including to the SEC, FINRA, IRS, FinCEN, or other regulators with jurisdiction over our activities.

5.3 Business Transfers
In the event of a merger, acquisition, or reorganization of the firm, personal information may be transferred to a successor entity, subject to equivalent privacy protections.

5.4 Investor Consent
We may share information with co-investors, general partners of related vehicles, or other third parties when you have provided explicit written consent.

6. DATA RETENTION
We retain personal information for as long as necessary to fulfill the purposes outlined in this Policy, satisfy our legal and regulatory obligations, resolve disputes, and enforce our agreements. Specifically:

• Investor records and subscription documentation: minimum of seven (7) years following the conclusion of the investor relationship, or longer if required by law
• KYC and AML records: minimum of five (5) years following the termination of the investor relationship
• General correspondence and communications: three (3) years, unless longer retention is legally required
• Website and analytics data: twenty-four (24) months from collection

 

7. COOKIES AND TRACKING TECHNOLOGIES
Our website may use cookies, web beacons, and similar technologies to enhance functionality, analyze usage patterns, and support compliance. Specifically:

• Essential cookies: Required for basic site functionality and security. These cannot be disabled without affecting site operation.
• Analytics cookies: Aggregate, anonymized data used to understand how visitors interact with our site. No personally identifiable information is used for advertising purposes.
• Preference cookies: Store settings such as language preferences and display choices.

You may control cookie settings through your browser. Note that disabling certain cookies may impair website functionality. We do not use cookies for behavioral advertising or third-party tracking. We do not use cookies or tracking technologies for targeted advertising or cross-site tracking.

8. SECURITY
We implement commercially reasonable administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, loss, destruction, alteration, or misuse. These measures include encryption of data in transit and at rest, role-based access controls, audit logging, and regular security assessments.

9. YOUR RIGHTS
Residents of certain U.S. states may have additional rights under applicable data protection laws, including rights to access, correct, delete, and obtain information about how their personal information is collected, used, and disclosed. Achelion Capital does not sell or share personal information.  Depending on your jurisdiction, you may have certain rights with respect to your personal information, including the right to:

• Access: Request a copy of the personal information we hold about you
• Correction: Request correction of inaccurate or incomplete information
• Deletion: Request erasure of personal information where no overriding legal basis for retention exists
• Restriction: Request that we limit the processing of your data in certain circumstances
• Portability: Receive your data in a structured, machine-readable format in applicable circumstances
• Objection: Object to processing based on our legitimate interests
• Withdrawal of Consent: Where processing is based on consent, withdraw that consent at any time

 

10. INTERNATIONAL DATA TRANSFERS
Achelion Capital operates from the United States. If you are located outside the United States, please be aware that information we collect is transferred to and processed in the United States. We take steps to ensure that cross-border data transfers are conducted in accordance with applicable law and that adequate protections are in place.

11. CHANGES TO THIS POLICY
We reserve the right to update this Privacy Policy at any time. Material changes will be communicated via posted notice on our website and, where appropriate, direct notification to investors. Continued engagement with Achelion Capital following the effective date of an updated Policy constitutes acceptance of the revised terms.

12.CONTACT
For privacy-related inquiries, requests, or complaints:

Achelion Capital Management, LLC
Privacy & Compliance Department
Email: compliance@achelion.capital

All privacy requests must be submitted in writing and will be responded to within thirty (30) days.