Privacy Policy.

Effective Date: January 2026

Fortuneo, LLC and its affiliates (collectively, "Fortuneo," "we," "us," or "our") respect your privacy and are committed to protecting personal information you provide to us. This Privacy Policy describes how we collect, use, share, and safeguard personal information about visitors to our website, limited partners in our sponsored funds, prospective investors, tenants, business counterparties, job applicants, and employees.

1. Information We Collect

We may collect the following categories of personal information:

• Contact information: name, email address, mailing address, telephone number, employer, and title.
• Investor information: accreditation and qualification data, source-of-funds information, tax identification numbers, bank account and wire information, subscription documentation, and beneficial ownership information.
• Website usage information: IP address, browser type, device information, referring URL, pages visited, and interactions with the site (collected via cookies, log files, and similar technologies).
• Communications: the content and metadata of emails, forms, and other communications you send to us.
• Employment information: résumés, employment history, references, and other information job applicants provide.

2. How We Use Information

We use personal information to (a) evaluate and respond to inquiries and applications; (b) administer subscriptions, capital calls, distributions, tax reporting, and other fund operations; (c) comply with legal, regulatory, tax, anti-money-laundering, and know-your-customer requirements; (d) communicate with limited partners, tenants, and business counterparties; (e) operate, secure, monitor, and improve our website and platform; and (f) exercise or defend legal rights.

3. Legal Basis

Where required by law, we process personal information on the basis of your consent, our legitimate business interests, the necessity of performing a contract with you, or our compliance with legal obligations.

4. How We Share Information

We share personal information with (a) our affiliates and sponsored funds; (b) our service providers, including our fund administrator, auditor (PwC), legal counsel, tax advisors, cybersecurity vendors, and technology providers; (c) governmental, regulatory, and tax authorities where legally required; (d) counterparties in a specific transaction (such as lenders or joint-venture partners) where relevant and appropriate; and (e) any acquirer of Fortuneo or its assets. We do not sell personal information.

5. Cookies and Similar Technologies

Our website uses cookies and similar technologies for site functionality, security, and analytics. You may control cookies through your browser settings; disabling cookies may affect site functionality.

6. Security

We maintain administrative, technical, and physical safeguards designed to protect personal information from unauthorized access, use, alteration, and disclosure, aligned to the NIST Cybersecurity Framework. No system, however, is fully secure, and we cannot guarantee absolute security.

7. Retention

We retain personal information for as long as necessary to fulfill the purposes described in this Privacy Policy and to satisfy legal, regulatory, tax, audit, and contractual retention requirements.

8. Your Rights

Depending on your jurisdiction, you may have rights to access, correct, delete, restrict, or object to processing of your personal information, and to request portability of your information. To exercise these rights, contact [email protected]. We may need to verify your identity before responding to a request.

9. International Transfers

Fortuneo is headquartered in the United States. Personal information you provide may be transferred to, stored in, and processed in the United States. Where required, we implement appropriate safeguards for international data transfers.

10. Children

Our website is not directed to children under 16, and we do not knowingly collect personal information from children.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Updates will be posted on this page with a revised "Effective Date."

12. Contact

Questions or requests regarding this Privacy Policy may be directed to [email protected], or by mail to Fortuneo, LLC, 1910 Pacific Avenue, Suite 2000, Dallas, TX 75201.