Privacy Policy

Last Updated: November 10, 2025

This Privacy Policy describes how PLUS Capital Management, LLC (“PLUS Capital,” “we,” “us” or “our”) may collect, use, share, and otherwise process personal information when you visit our website at https://www.pluscapital.com/ (the “Website”) or in other contexts. If you are an investor in a fund or the holder of an account managed directly or indirectly by us (or, in either case, their representative), please refer to the Investor Privacy Notice for further information about how PLUS Capital collects and processes personal information about its current, prospective and former investors.

By accessing and using the Website, you agree and consent to the collection, use, processing and disclosure of your personal information as outlined in this Privacy Policy.

I. The Personal Information PLUS Capital May Collect and How It Will Be Used

We may collect and process the following categories and examples of personal information about you: contact information such as name and email address; professional or employment-related information; identification information such as date of birth and national insurance or social security number; background information revealed in know-your-customer and anti-money laundering due diligence; financial information; and Internet or other electronic network activity information.

We may use your personal information for a variety of business purposes, including where it is necessary to do so for purposes such as processing and responding to requests, processing transactions and maintaining accounts, improving our operations, maintaining details of our business contacts, facilitating business transactions and developing new business, sending announcements and communications, complying with any legal, regulatory, or contractual obligation, and investigating, defending, and otherwise managing legal issues.

We may also automatically collect certain information about your interaction with the Website. To do this, we may use cookies, web beacons/clear gifs, or other tracking technologies. This data may include internet or other electronic network activity information such as unique device identifiers, device type, IP address, browser type, date and time stamps (such as the date and time you first accessed the Website), operating system, log data, geolocation information, and other information regarding your interaction with the Website.

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. We do not currently recognize or respond to browser-initiated DNT signals.

II. How We Disclose Your Personal Information

We may disclose your personal information to the following categories of third parties:

  • Attorneys, auditors, accountants, consultants, and other professional service providers;

  • As required by law or in connection with a legal claim, dispute, or proceeding or in response to requests by governmental regulatory authorities, or as we may reasonably determine to be necessary or appropriate to protect our rights or the rights of others or to avert loss or harm to persons or property.

  • Third parties as needed to protect our legitimate interests, including to establish or defend our legal rights;

  • Third parties in the event that we sell all or part of its business or makes a sale or transfer of assets or is otherwise involved in a merger, restructuring or business transfer;

  • Certain other persons to the extent authorized by you.

III. Data Retention and Security

Your personal information will be retained for as long as you maintain a business relationship with us and afterwards in accordance with our legal and regulatory obligations. When deciding how long to retain your personal information, we take into account our legal and regulatory obligations, the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means. We may also retain your personal information to investigate or defend against potential legal claims in accordance with the limitation periods of countries where legal action may be brought.

PLUS Capital has implemented security measures designed to protect your personal information against loss, unauthorized disclosure or access, and other unlawful forms of processing. Despite the security measures that we have put in place to protect your personal information, no such measures can guarantee security or protect against unauthorized activity.

 

IV. Data Subject Rights

Depending on your jurisdiction, you may have certain data subject rights. These rights vary by jurisdiction and may be subject to certain limitations and exemptions. These rights may include the right to: (i) request access to and rectification or erasure of your personal information; (ii) obtain restriction of processing or to object to processing of your personal information; and (iii) the right to data portability.

These rights are not absolute, and we reserve all of our rights available to us at law in this regard. You can exercise the foregoing rights by contacting us at ir@pluscapital.com.

 

V. Links to Other Websites

The Website may provide links to third-party websites. This Privacy Policy does not apply to those sites, which operate independently from the Website and are not under our control. These sites may have their own privacy notices in place, which we strongly suggest you review if you visit them. We are not responsible for the content of these sites, any products or services that may be offered through these sites or any other use of these sites, nor for any data processing and privacy practices associated with such sites.

 

VI. Children

The Website is not targeted at children under the age of eighteen (18) and we do not knowingly collect personal information from children under the age of 18. If we become aware of having collected personal information from a child under the age of 18 without valid consent, including as applicable, from their respective parents or guardians, we will take steps to delete the information from our records.

 

VII. Updates to this Privacy Policy

We may amend this Privacy Policy from time to time to reflect changes in our practices with respect to the processing of personal information or changes in applicable law. We encourage you to periodically review this Privacy Policy to stay informed about our information practices. We will indicate above the date on which this Privacy Policy was last modified. Your continued use of the Website constitutes your agreement to the Privacy Policy and any updates.

 

VIII. Contact Information

If you have any questions about how we process your personal information, please contact us at info@pluscapital.com.