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Privacy Policy

Introduction

This notice explains how we use your personal data under the Cayman Islands Data Protection Act (as revised) (the “DPA”). In this notice, “we”, “us” and “our” refer to Liquibit Capital (the “Manager”), a registered person under the Securities Investment Business Act (as revised), and Liquibit USD Market Neutral Arbitrage Fund (the “Fund”) and their affiliates and/or delegates.

The Manager is the data controller of personal data collected through the website. The Fund and the Manager are each a data controller of Investor Data for their respective purposes. Their affiliates and delegates may act as data processors or, where they process Investor Data to meet their own legal or regulatory obligations, as data controllers.

Investor Data

You will give us certain personal information when you:

  • visit our website;
  • deal with the Fund or the Manager about making an investment, or a potential investment, in the Fund, along with any related interactions with us. This includes any subscription, capital commitment and/or capital contribution (past, present or future) and, where applicable, recordings of electronic communications or phone calls; or
  • give us personal information about individuals connected with you as an investor, such as directors, trustees, employees, representatives, shareholders, investors, clients, beneficial owners or agents.

This information is personal data within the meaning of the DPA (the “Investor Data”). We may also obtain Investor Data from public sources, from third-party identity verification, sanctions and screening providers, and from public blockchain records.

Investor Data includes, without limitation, the following information about you and/or individuals connected with you as an investor:

  • name, residential address, email address and other contact details
  • corporate contact information
  • signature
  • nationality, place of birth and date of birth
  • tax identification details
  • passport or other identity document details
  • credit history
  • bank account details and digital asset wallet addresses, including the transaction history associated with those wallet addresses on public blockchains, which we review as part of our anti-money laundering and source-of-funds checks
  • source of funds and source of wealth details
  • correspondence records
  • details of your investment activity

In carrying out anti-money laundering, counter-terrorist financing and sanctions checks we may also obtain sensitive personal data within the meaning of the DPA, such as information about criminal convictions or alleged offences and whether you are a politically exposed person. We process this information only where necessary to comply with our legal obligations, in accordance with Schedule 3 of the DPA.

Who This Affects

If you are a natural person, this notice affects you directly. You may be a corporate investor, which for these purposes includes legal arrangements such as trusts or exempted limited partnerships. If you give us Investor Data about individuals connected to you in relation to your investment with us, this notice is relevant to those individuals. You should pass this notice on to them or otherwise tell them what it says.

How We May Use Your Personal Data

As data controllers, the Fund and the Manager may collect, store and use Investor Data for lawful purposes, in particular where this is necessary:

  • to perform our rights and obligations under the subscription agreement and/or the Fund’s constitutional and operational documents;
  • to comply with a legal or regulatory obligation that applies to the Fund or the Manager, such as anti-money laundering, counter-terrorist financing, sanctions and FATCA/CRS requirements; and/or
  • for our legitimate interests, where your interests, fundamental rights or freedoms do not override those interests.

The Manager, Formidium Corp. (the “Administrator”) and RSM Cayman Ltd. (the “Auditors”) may also use Investor Data. For example, they may use it to provide their services to the Fund or to meet legal or regulatory requirements. These can be requirements that apply to them directly, or requirements for which the Fund relies on them. Any such use will always be compatible with at least one of the purposes listed above.

If we want to use Investor Data for any other specific purpose, including a purpose that requires your consent, we will contact you.

Why We May Transfer Your Personal Data

In some circumstances, we and/or our authorised affiliates or delegates may be legally required to share Investor Data, and other information about your interest in the Fund, with regulatory authorities. These include the Cayman Islands Monetary Authority and the Tax Information Authority (acting through the Department for International Tax Cooperation). Those authorities may in turn share this information with foreign authorities, including tax authorities.

We expect to disclose Investor Data to the following parties, who provide services to the Fund or the Manager and will process your personal data on our behalf. This includes their affiliates, some of which may be located outside the Cayman Islands or the European Economic Area.

  • the Manager;
  • the Administrator;
  • the Auditors;
  • [the Manager’s affiliates and personnel located in [the United Kingdom, Hong Kong and other jurisdictions] who assist with investor relations, compliance and operations]; and
  • [third-party identity verification, sanctions screening and blockchain analytics providers engaged for anti-money laundering purposes].

The Data Protection Measures We Take

We and our authorised affiliates and/or delegates will only transfer Investor Data outside the Cayman Islands in line with the requirements of the DPA. Where Investor Data is transferred to a country or territory that does not ensure an adequate level of protection, we will ensure that appropriate safeguards are in place, such as contractual commitments from the recipient that meet the requirements of the DPA, or that one of the exemptions in Schedule 4 of the DPA applies. We and they will apply appropriate technical and organisational security measures to protect Investor Data against:

  • unauthorised or unlawful processing; and
  • accidental loss, destruction or damage.

If we become aware of a personal data breach affecting Investor Data, we will notify the Cayman Islands Ombudsman and the individuals affected without undue delay and in any event no later than five days after we should, with reasonable diligence, have become aware of the breach, as section 16 of the DPA requires.

Data Retention

We will keep Investor Data for as long as we need it for the purposes described in this notice. We will also keep it for as long as applicable law, regulation (including anti-money laundering record-keeping requirements, which currently require records to be kept for at least five years after the end of the business relationship or the completion of the transaction) or our internal policies require. When we no longer need Investor Data, we will securely delete or anonymise it.

Your Rights

Under the DPA, you have the right to:

  • be informed about how we use your personal data;
  • request access to your personal data;
  • have inaccurate or incomplete personal data rectified, blocked, erased or destroyed
  • ask us to stop processing your personal data where that processing is likely to cause substantial damage or distress;
  • ask us to stop using your personal data for direct marketing;
  • be informed of, and object to, decisions made solely by automated processing;
  • seek compensation for damage suffered as a result of a contravention of the DPA; and
  • complain to the Cayman Islands Ombudsman.

These rights have limits. For example, we may be unable to delete personal data that the law requires us to keep. To use any of these rights, please contact us using the details below. We will respond to a request for access within 30 days of receiving it, as the DPA requires.

Cookies and Analytics

The website uses cookies and similar technologies, including [name analytics tool(s)], to [understand how visitors use the website, measure its performance and improve it]. [Describe each category of cookie: strictly necessary; analytics; functional.] Where the law requires, we will ask for your consent before placing non-essential cookies on your device, and you may withdraw that consent at any time through [the cookie banner / cookie settings link]. You can also adjust your browser settings to refuse cookies, although some parts of the website may not then work properly. If you access the website from the United Kingdom or the European Economic Area, local rules on cookies and electronic marketing also apply and we will comply with them.

Children

We do not knowingly collect information from minors. You must be of the age of legal majority where you live to use the website, and by using it you confirm that you are. We do not use any application or other method to check the age of website users. We will treat all information given to us as if an adult provided it. If we learn that a minor has given us information about themselves, we will delete it as soon as possible.

Links to Other Sites or Third-Party Services

The website may include links to third-party sites. If you click one, you will be taken to a website we do not control, and this notice does not apply to its privacy practices. Please read the privacy policies of other websites carefully. We are not responsible for third-party sites.

Disclaimer and Policy Updates

This notice is not business, legal or other advice. We apply the security measures described in this notice, but no transmission of information over the internet can be guaranteed to be completely secure.

We may update this notice from time to time. Any changes will be posted on this page with a revised “last updated” date.

This notice was last updated on 30 September 2026.

Contact Information

The data controllers are:

  • Liquibit Capital [full legal name], registered office: [address], Cayman Islands; and
  • Liquibit USD Market Neutral Arbitrage Fund [full legal name], registered office: [address], Cayman Islands.

For questions about this notice, or to exercise your rights, please contact us at info@liquibit.io or by post at the address above.

You may also contact the Office of the Ombudsman of the Cayman Islands (ombudsman.ky) if you are not satisfied with how we handle your personal data.