Privacy Policy

Introduction

KPC Private Funds, LLC ("KPC," "we," "us," or "our"), an affiliate of Kelly Park Investment LLC, is committed to protecting the privacy and security of personal information. This Privacy Policy describes how we collect, use, disclose, and safeguard information when you visit our website or engage with our investment advisory services. As a registered investment adviser with the U.S. Securities and Exchange Commission, we are also subject to regulations that govern the handling of client information.

In the event of any inconsistency between this website privacy statement and our formal Privacy Policy Notice provided pursuant to Regulation S-P, the formal Privacy Policy Notice shall govern.

KPC Privacy Policy Notice

Smart Investments, Made Simple™

Kelly Park Investment LLC, Kelly Park Management II LLC, and KPC Terrapin Group LLC (together, "KPC") have adopted this policy in recognition that protecting the privacy and security of the personal information KPC obtains from its clients is an important responsibility. KPC understands that its clients and prospective clients expect KPC to provide its services in an accurate and efficient manner. To do so, KPC must collect and maintain certain personal information about its clients. KPC wants its clients to know what information KPC collects and how KPC uses and safeguards that information.

What information the firm collects

KPC collects certain nonpublic personal identifying information about its clients (such as the client's name, address, social security number, etc.) from information that the client provides in account applications or other forms as well as communications (electronic, telephone, written or in person) with the client or the client's authorized representatives (such as an attorney, accountant, etc.).

What information the firm discloses

KPC does not disclose the nonpublic personal information KPC collects about its clients and prospective clients to anyone except:

• In furtherance of KPC's business relationship with them and then only to those persons necessary to effect the transactions and provide the services that they authorize (such as broker-dealers, custodians, independent managers etc.);
• To persons assessing the Firm's compliance with industry standards (e.g., professional licensing authorities, etc.);
• The Firm's attorneys, accountants and auditors; or
• As otherwise provided by law.

KPC is permitted by law to disclose the nonpublic personal information about its clients to governmental agencies and other third parties in certain circumstances (such as third parties that perform administrative or marketing services on KPC's behalf or for joint marketing programs). These third parties are prohibited from using or sharing the information for any other purpose. If a client decides at some point to terminate its advisory relationship with KPC, KPC will continue to adhere to its privacy policy, as may be amended from time to time.

Use of Artificial Intelligence and Data Processing Tools

KPC may utilize advanced technologies, including artificial intelligence ("AI") and machine learning tools, to enhance operational efficiency, data analysis, and client service delivery.

KPC does not input or disclose clients' nonpublic personal information into third-party AI systems or tools that are not subject to appropriate confidentiality, security, and data protection safeguards. Specifically, KPC does not permit the use of client nonpublic personal information in AI systems that may use such data for model training or other purposes beyond KPC's control.

Where AI or similar technologies are used in connection with client-related data, KPC utilizes enterprise-grade or controlled environments designed to maintain the confidentiality, integrity, and security of such information and to prevent unauthorized use, retention, or external training on such data.

KPC continues to evaluate its use of emerging technologies to ensure alignment with applicable privacy, data protection, and regulatory standards.

Security of client information

KPC recognizes the need to prevent unauthorized access to the information collected, including information held in electronic format. KPC restricts access to client nonpublic personal information to those personnel who need to know that information to provide its services to the client. KPC maintains physical, electronic and procedural safeguards that comply with applicable federal or state standards to protect each client's nonpublic personal information. Former clients can be assured that nonpublic personal information will continue to be treated according to KPC's privacy policies and practices, as amended from time to time.

Limiting Sharing

As KPC's disclosure of clients' nonpublic personal information is limited to sharing necessary to everyday business purposes, or as permitted or required by law, clients cannot further limit how we share your information. It is necessary for us to share certain nonpublic personal information in order to effectively manage your account.

Changes to the firm's privacy policy or relationship with you

KPC's policy about obtaining and disclosing information may change from time to time. KPC will provide its clients with notice of any material change to this policy before KPC implements the change.

If you have any questions concerning any information in this privacy notice or how we collect, share or protect your information, please call 212-710-4111 or email investorrelations@kellyparkcapital.com.

Information We Collect

Personal Information

We may collect the following categories of personal information:

• Identifiers: Name, email address, phone number, mailing address
• Financial Information: Investment experience, net worth, income, investment objectives, risk tolerance
• Professional Information: Firm name, title, professional credentials
• Account Information: Account numbers, holdings, transaction history (for clients)
• Tax Information: Social Security number, tax identification numbers (for clients)

Automatically Collected Information

When you visit our website, we may automatically collect:

• IP address and device identifiers
• Browser type and operating system
• Pages viewed and links clicked
• Date and time of visits
• Referring website addresses

How We Use Your Information

We use the information we collect for the following purposes:

• To provide investment advisory services and manage client accounts
• To respond to inquiries and communicate with you
• To comply with legal and regulatory requirements
• To prevent fraud and maintain security
• To improve our website and services
• To send firm updates and communications consistent with applicable law

Information Sharing and Disclosure

We do not sell your personal information to third parties. We may share your information in the following circumstances:

• Service Providers: We may share information with trusted third parties who assist us in operating our business, such as custodians, administrators, auditors, and technology providers
• Legal Requirements: We may disclose information when required by law, regulation, court order, or governmental authority
• Regulatory Examinations: We may provide information to regulatory bodies conducting examinations of our firm
• Business Transfers: In connection with a merger, acquisition, or sale of assets, your information may be transferred
• With Your Consent: We may share information when you have provided explicit consent

Data Security

We implement appropriate technical and organizational measures to protect personal information against unauthorized access, alteration, disclosure, or destruction. These measures include encryption, access controls, secure data storage, and regular security assessments. However, no method of transmission over the Internet or electronic storage is completely secure, and we cannot guarantee absolute security.

Data Retention

We retain personal information for as long as necessary to fulfill the purposes for which it was collected, comply with legal and regulatory requirements, and support our business operations. For client records, we are required by SEC regulations to maintain certain records for a minimum of five years, and in some cases longer. When information is no longer needed, we securely dispose of it.

Your Rights and Choices

Depending on your jurisdiction, you may have certain rights regarding your personal information:

• Access: Request a copy of the personal information we hold about you
• Correction: Request correction of inaccurate or incomplete information
• Deletion: Request deletion of your personal information, subject to legal retention requirements
• Opt-Out: Unsubscribe from marketing communications at any time

These rights are subject to applicable law and regulatory record-retention requirements, including those imposed on SEC-registered investment advisers. To exercise any of these rights, please contact us using the information provided below.

Residents of certain states (such as California) may have additional privacy rights regarding website data under applicable state privacy laws. Please note that personal information collected in connection with our investment advisory services may be exempt from these state law rights to the extent it is subject to federal financial privacy regulations, including the Gramm-Leach-Bliley Act (GLBA) and SEC Regulation S-P.

Cookies and Tracking Technologies

Our website uses cookies and similar tracking technologies to enhance your browsing experience, analyze website traffic, and support our business operations. When you first visit our site, you will be presented with a consent banner allowing you to accept or decline non-essential cookies.

Technologies We Use

• Google Analytics (GA4): We use Google Analytics to collect anonymized data about how visitors interact with our website, including pages visited, time spent on pages, and navigation patterns. This helps us understand user behavior and improve our website. Google Analytics uses cookies to distinguish unique users and sessions. Data is processed by Google LLC in accordance with their Privacy Policy.
• HubSpot: We use HubSpot for form functionality, lead management, and communications. HubSpot may place cookies to track form submissions and help us respond to inquiries. HubSpot processes data in accordance with their Privacy Policy.

Managing Your Cookie Preferences

You can control cookies through the following methods:

• Consent Banner: When you first visit our site, you can accept or decline analytics cookies via the consent banner
• Browser Settings: Most browsers allow you to block or delete cookies through their settings
• Google Analytics Opt-Out: You can install the Google Analytics Opt-Out Browser Add-on
• Clear Preferences: To reset your cookie preferences, clear your browser's local storage for this site

Note that disabling cookies may affect the functionality of certain features on our website. Information collected through website analytics and cookies is separate from client nonpublic personal information collected in connection with advisory services.

Third-Party Links

Our website may contain links to third-party websites or services. We are not responsible for the privacy practices of these third parties. We encourage you to review the privacy policies of any third-party sites you visit.

Children's Privacy

Our website is not directed to children under the age of 13, and we do not knowingly collect personal information from children under 13. If we become aware that we have inadvertently collected such information, we will take steps to delete it promptly. If you believe a child has provided us with personal information, please contact us using the information below.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable laws. We will post any changes on this page and update the "Last Updated" date. We encourage you to review this Privacy Policy periodically.

Contact Us

If you have any questions about this Privacy Policy or our privacy practices, please contact us: