Privacy Policy.

Effective Date: December 1, 2025

1. Introduction.

Welcome. You have arrived at a website provided by Raith Capital Partners, LLC (“Raith,” “Company,” “we,” “our” or “us”). Raith is a New York-based private investment firm that specializes in U.S. commercial real estate debt and equity investments.

At Raith, we take the privacy of our visitors seriously and provide this Privacy Policy (“Policy”) to tell you what information we collect about you, how we obtain it, how we share it, and how you may limit the ways in which we use your Personal Information.  If you have questions about this Policy after you review it, feel free to contact us at compliance@raithcapital.com.

2. Scope.

This Policy governs https://www.raithcapital.com/, its subdomains, and all subdomains or portals that link to this Policy (“Site”); or when you provide Personal Information or otherwise interact with us online. We refer to all the above as our “Services.” This Policy is expressly incorporated into our Terms of Use (“Terms”). By using our Site or using our Services, you acknowledge this Policy and agree to the Terms.

For the purposes of this Notice, "Personal Information" (sometimes referred to as “Personal Data”) means any Personal Information relating to an identified or identifiable individual that is protected by applicable privacy laws. The definition of Personal Information does not include publicly available information from federal, state, or local government records, such as professional licenses and real estate or property records.

If you are an investor, a separate Privacy Notice to Investors will be provided to you in connection with your account information.

3. What Information We Collect.

As a rule, we limit the Personal Information we collect to that which is reasonably necessary for us to provide our Services to you.

Information Provided By Clients/Investors or Prospective Clients

As you interact with our Site or Services, we collect Personal Information through your use of the website, through our account opening and onboarding process, and via telephone calls, written correspondence, investor questionnaires, applications, emails, our fund data room and/or investor reporting portal, or webforms or inputs on our Site. When you engage us for advisory services or request information about our services or investments, we may collect the following categories of Personal Information:

• Identifiers and Contact Information: full name, re

• sidential or mailing address, email address, telephone number, date of birth, signature, employer or company affiliation, title and/or business address;

• Government-Issued Identifiers: Social Security number, tax identification number, Driver’s license, passport or other government identification information, citizenship or immigration status (if required for regulatory purposes);  

• Financial Information: Bank account numbers and routing numbers, investment objectives and risk tolerance, income, assets, liabilities, and net worth, account balances, holdings and transaction history (including accounts and transactions with other institutions), tax status or related financial documents;

• Regulatory and Compliance Information: Information necessary to satisfy “Know Your Customer” (KYC), Anti-Money Laundering (AML) and other legal obligations, information collected to assess investment suitability, signed agreements or disclosures;

• Professional and Employment Information: Employer name and occupation, employment status (e.g., self-employed, retired), affiliation disclosures (e.g., FINRA reportable employment, political exposure or corporate insider relationships); 

• Other Information You Provide Voluntarily: Form submissions, email correspondence, phone calls or meeting notes, information provided during consultations or onboarding; and

• Other information that could reasonably be used to identify you personally.

Information We Collect Automatically Through Our Website

Like many businesses, we and our service providers automatically collect and/or store certain information when you visit or interact with the Site (“Usage Information”), including via cookies and other tracking technologies (additional information is available in the “Use of Cookies and Other Tracking Technologies” section below). This Usage Information may be stored and/or accessed from your personal computer, laptop, tablet, mobile phone or other device (a “Device”) whenever you visit or interact with our Site. Usage Information includes:

• Internet or Network Activity: IP address, MAC address, IDFA, Android/Google Advertising ID, IMEI, or another unique identifier; referring and exit web pages and URLs; the areas within the Site that you visit and your activities there, including remembering you and your preferences; the date and time of day you visit our Site or other information used to provide analytics or other usage information; Statistical information about how both unregistered and registered users, collectively, use the Site; Information about your engagement with our emails;

• Device Identifiers: Device functionality (including browser, browser language, settings and behavior, operating system, hardware, mobile network information), Device characteristics (such as device type (computer vs. mobile) and ID, operating system, hardware);

• Geolocation Data: Device location or other location information, including the zip code, state or country from which you accessed the Services, general location information derived from your IP address;

• Cookies and Tracking Technologies: Cookies, tags, pixels and SDKs (see our Use of Cookies and Other Tracking Technologies section below); session cookies to enable website functionality; persistent cookies for analytics and site performance; and analytics tools (e.g., Google Analytics) to understand usage patterns.   

If you have enabled location services on the device on which you access our Site, we and our Service Providers may collect and store automatically collected geolocation data. If you do not wish for us to collect this information, please disable location features on your device before accessing our Site or Services.

We may also collect sensory data such as security and audiovisual recordings from our offices or premises to protect the health and safety of our clients and associates, and to prevent, investigate, and prosecute fraud and other criminal activities.

Information Provided By Third Parties

The Site includes functionality that allows certain kinds of interactions between the Site and your account on a third-party website or application, including our Investor Portal. The use of this functionality may involve the third-party site providing information to us. For example, we might obtain information about the traffic and usage of Company from third parties, or we might receive information about your transactions in our portal or confirmation of AML or KYC status from a vendor. These third parties may also use cookies and other tracking technologies to capture information about your interactions with us. For instance, we use Google tools (Google Analytics) or Meta tools (pixels and conversions) which may drop cookies or identifiers for analytics/advertising purposes. As discussed in more detail in the Your Privacy Choices section below, you have the right to opt-out of non-essential cookies. To do so, click the ‘Cookie Settings’ link/banner on our website and toggle off the targeting categories. After you make your selection, our tagging system will communicate your choice to Google via Google Consent Mode, so Google’s cookies and tags will (depending on the choice) stop firing or fire with reduced functionality.

We do not always have control over the information that is collected, used, and shared by these third parties. We encourage you to review the privacy statements of these third parties to understand their privacy practices.

Information We Infer

We may derive information or draw inferences about you based on information we collect about you. For example, based on the information you have provided, we may infer your risk tolerance, your interest in certain investments or brands, or information about your investment activities over time.

4. Use of Cookies and Other Tracking Technologies.

We and our service providers use cookies and other tools (“Tracking Technologies”) to understand how people use our Site, make it work correctly, and to improve your experience. These Tracking Technologies store and collect Usage Information. By using this Site, you consent to our use of Tracking Technologies.

What are Cookies?

Cookies are small files that your browser stores on your Device. They help the website remember things like your preferences or whether you’ve logged in.

Some cookies are placed by us (“first-party cookies”), and some are placed by our partners (“third-party cookies”) such as companies that provide analytics, video, or advertising.  Third-party cookies we use may include Google Analytics, Meta or others.  

Do Cookies Contain Personal Information?

Cookies and similar technologies do not always directly identify you, but many laws treat them as “personal information” or “personal data” when the information collected, alone or combined with other data, can be linked to you or your Device. For example, if you log in to an Investor Portal account, we may associate cookie data with your account.

Other Types of Tracking Technologies We Use

In addition to standard browser cookies, we may use other Tracking Technologies, including:

• HTML5 local or session storage: browser-based storage used to remember certain settings or behaviors;

• Pixel tags, clear GIFs and web beacons: small images or snippets of code that load when you visit a page or open an email, telling us or partners that you have engaged with content;

• Tags, scripts and containers (e.g., tag managers): snippets of code provided by analytics or marketing vendors to measure behavior or deliver functionality, or tools used to deploy and manage other tags (like Google Tag Manager);

• Software Development Kits (SDKs): a set of tools or code provided by a third party that developers add into an app or website to enable certain features, such analytics, advertising, or login, and that may also collect information from users’ Devices.

• Embedded Scripts: snippets of code that are designed to collect information about your interactions with the Site, such as the links you click on;

• UTM parameters: short tags added to the end of a URL that help track where website traffic comes from—such as which email, ad, or social media post a visitor clicked before landing on a page.

• Device Identifiers and probabilistic identifiers: Identifiers unique to your Device (e.g., mobile advertising IDs), or technology that creates an identifier by analyzing characteristics of your Device or browser.  

• Other data technologies may be used that collect comparable information for security and fraud detection purposes.

We may also engage third parties, such as Google Analytics or Meta, to track and analyze non-personally and personally identifiable website data and to serve advertisements. To do so, we may permit third parties to place cookies on devices of users of our Sites, where permitted by law, and subject to your right to opt out through the Sites. We use the data collected to help us administer and improve the quality of the Sites and to analyze the Site’s usage. Such third parties may combine the information that we provide about you with other information that they have collected. These third parties are required to use your information in accordance with this Privacy Policy. We will record all such disclosures and will use reasonable efforts to ensure that such third parties do not use your Personal Information for any purpose that is not expressly provided for herein.

We classify our cookies into the following categories:

• Essential/Strictly Necessary Cookies. These cookies are need for the Site to work (for example, keeping you logged in or letting the Site load properly).  You cannot disable this type of cookie on our Site.

• Functionality Cookies. Also known as “preference cookies,” these cookies allow the Sites to remember choices you have made in the past, like what language you prefer, or what your username and password are so you can automatically log in. Disabling these cookies can cause some parts of the Site to not work properly, so we discourage you from disabling these cookies.

• Performance and Analytics Cookies. These cookies collect information about how you use a website, like which pages you visited and which links you clicked on. Their purpose is to improve website functions. In some jurisdictions, you may be able to turn these cookies off.

• Targeting and Advertising Cookies. These are used by us or our partners to deliver more relevant advertising, measure our marketing, or prevent you from seeing the same ad too many times. These cookies can share that information with other organizations or advertisers. In some jurisdictions, you may be able to turn these cookies off.

Depending on your browser settings or your location, you may be able to:

• Adjust your cookie preferences through our cookie banner;

• Block or delete cookies in your browser;

• Opt out of certain analytic s or advertising tools; or

• Change your Device settings to limit tracking.

If you block some cookies, certain features on our Site may not work as intended. 

Advertising Tools We Use

We use Google and Meta (Facebook) tools to help us understand how people use our website and to show ads that may be more relevant to you.

These tools may use cookies or other identifiers to measure how effective our ads are, learn what content is useful to visitors, or show ads based on your activity on our Site or other sites.

Your Choices for Google Tools

Our Google tools may include remarketing, impression reporting, demographics and interest reporting, and cross-service integrations. Google offers several ways to control how your information is used for advertising.

• Google Ads Settings – You can opt out of personalized ads from Google by adjusting your settings here.

• Google Analytics Opt-Out Browser Add-On – You can block Google Analytics from accessing your online activity with a browser add-on here.

• Direct-Level Advertising Settings – Many mobile devices allow you to limit the use of Advertising IDs (Android Ad ID or Apple IDFA).  See your Device’s settings for more information.

With respect to these advertising features, Company is the sole controller under all applicable data protection legislation. We do not identify users or merge Personal Information with Google Analytics data unless you have given us permission to do so.

Your Choices for Meta (Facebook) Tools

If we use the Meta Pixel, Meta may use information about your activity on our Site to personalize ads you see on Facebook, Instagram, and other Meta services.  You can control your ad preferences directly with Meta:   

• Meta Ad Preferences – You can view or change your Facebook Ad Preferences here.

General Cookie Information

To generally find out more about cookies, visit this site which also has instructions on how to opt out of targeted advertising cookies here. More opt-out resources are also available from the Digital Advertising Alliance. We do not control these opt-out links or whether any organization chooses to participate in these opt-out programs. Please note that even if you exercise the opt-out choices above, you may continue to receive advertisements, for example, ads based on the website you are viewing (e.g., contextually based ads), or ads that are not targeted at you and may be less relevant. Also, if your browser (like some Safari browsers) is configured to reject opt-out cookies when you opt out on the DAA websites, your opt-out may not be effective. We always do our best to honor your choices, but because some choices are set at the browser or device level, you may have to make these choices multiple times if you use different browsers or different Devices.

5. Why We Collect Information.

We use the information we collect about you in a variety of ways, including the following:

To Provide Our Services

We process certain Personal Information when you access or use our services, including to:

• Operate, maintain and improve the Site and its services;

• Enable you to access and use the Site;

• Send you notices, updates, security alerts and support and other messages;

• Provide and deliver the services and features you request, process and complete transactions, and send you related information to your transactions;

• Process your requests for products and services;

• Create and verify investor accounts;

• Perform our obligations under the governing documents of the Funds (and all applicable AML, KYC and other related laws and regulations;

• Facilitate the functionality of our Site; and

• Customize experiences and personalization when you are on our Site.

To Communicate with You

We process certain information to communicate with you in relation to your account, our services, our marketing, and your requests, including to:

• Communicate with you about services, accounts and transactions;

• Respond to your requests for information or customer service inquiries;

• Send you personalized content and special alerts;

• Communicate with you about our brands, events, or other promotional purposes; and

• Implement your communications preferences, such as sharing information with our business partners so that they may email you about their promotions, products and initiatives.

For Improvement of Our Site or Services

We want to ensure that our Site and Services are continually improving and expanding so that we meet and exceed your needs and expectations. To do so, we may process certain Personal Information, including to:

• Test, research, analyze, or develop features of our Site or additional Services;

• Maintain, improve, and analyze our Site or Services; and

• Detect, prevent, or investigate suspicious activity or fraud.

To Comply with Applicable Laws

We may be required to process certain Personal Information under certain laws and regulations, such as tax laws, as well as to:

• Maintain appropriate records for internal administrative purposes; and

• Comply with applicable legal and regulatory obligations, and respond to lawful governmental requests, as needed.

To Enforce our Terms, Agreements, or Policies

To maintain a safe, secure, and trusted environment for you when you use our Site and Services, we use your Personal Information to ensure our terms, policies, and agreements with you and any third parties are enforced.

With Your Consent

We process certain Personal Information to fulfill any other business or commercial purposes at your direction or with your consent.

6. When We Disclose Information.

To the extent permitted by law, certain Personal Information about you may be disclosed in the following situations:

• Service providers. We may disclose Personal Information to our affiliates and to third-party service providers who perform services on our behalf, such as cloud hosting, data storage, payment processing, customer service, analytics, marketing support, communications delivery, IT services, attorneys, lenders, banks, auditors, consultants, and other operational functions. We require these service providers to enter into written agreements that limit their use of the information to the services they provide to us, prohibit them from using the information for their own purposes, and require them to safeguard the information and keep it confidential. These service providers may access Personal Information only as needed to perform their services.

• Marketing and advertising. We may use and share your information with our affiliates, service providers, and trusted marketing partners to send you marketing communications, personalize the content you see, measure advertising performance, and offer products or services that may be of interest to you. We share only the information needed to support these activities, and these partners are required to protect your information and use it only for the purposes we specify. You can opt out of our marketing emails at any time by following the instructions in those messages or contacting us directly. Depending on your location, you may also have the right to opt out of certain types of data sharing used for targeted advertising.

• Legal process. To comply with law, legal process, or government requests, including responding to a validly issued and enforceable subpoena, court order, summons, search warrant, regulatory inquiry or other legally enforceable demand. We may also disclose information as necessary in connection with actual or threatened legal proceedings or alternative dispute resolution proceedings either initiated by or against us. When we do so, we limit the disclosure to what is reasonably necessary and take steps to seek confidential treatment or other protections to prevent the information from becoming public, unless we are legally prohibited from doing so. 

• Compliance. In the course of a review of our practices under the authorization of a state or federal agency, or as necessary to properly respond to an inquiry or complaint from such an agency or organization.

• Business Transfers and Corporate Transactions. In conjunction with a prospective purchase, sale, or merger of all or part of our Company. This may include sharing information with potential or actual purchasers, investors, or other transaction partners and their advisors as part of due diligence or the transaction itself. Where appropriate, we will take steps to require those parties to protect the information and use it only for the purposes of evaluating or completing the transaction. If the transaction is completed, Personal Information may be transferred to the buyer or successor or affiliate as part of the transferred assets or ongoing business operations.

Finally, we may aggregate, de-identify, and/or anonymize any information collected through the Site \or Services such that such information is no longer linked to your Personal Information. We may use and share this aggregated and anonymized information (non-Personal Information) for any purpose, including without limitation, for research and marketing purposes, and may also share such data with our affiliates and third parties, including advertisers, promotional partners and others.

7. Automated Decision Making.

Automated decision making refers to a decision that is taken solely on the basis of automated processing of your Personal Information. We may use automated decision-making software for security reasons, such as to detect fraudulent or illegal actions, or to protect consumer safety. When we do so, you cannot opt out of the use of the decision-making technology. We also may use automated decision making to assist us with responding to your inquiries on our website or in evaluating performance and making projections. We do not use automated decision-making technologies to produce an adverse legal effect on you. 

8. Retention of Personal Information.

Company will retain your Personal Information only for as long as is necessary for the purposes set out in this Policy. We will retain and use your Personal Information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your Personal Information to comply with applicable laws), resolve disputes and enforce our legal agreements and policies.

All information you provide to us is stored on our secure servers or those of our third-party data storage providers.

We utilize the following criteria to determine the length of time for which we retain Personal Information:

• How long we have had a relationship with you or provided our Services to you;

• The business purposes for which the information is used, and the length of time for which the information is required to achieve those purposes;

• Whether we are required to retain the information, or the information is otherwise necessary, in order to: comply with legal obligations or contractual commitments: defend against potential legal claims: detect or prevent potential illegal activity or actions in violation of our policies and procedures; secure our systems and online environment; or protect health and safety;

• The privacy impact on individuals of ongoing retention; and

• The manner in which information is maintained and flows through our systems, and how best to manage the lifecycle of information in light of the volume and complexity of the systems in our infrastructure.

9. Children’s Privacy.

Our Site is not intended for use by children under the age of 16. We do not request or knowingly collect any personally identifiable information from children under the age of 16. If you are the parent or guardian of a child under 16 who you believe has provided her or his information to us, please contact us using the information in the Contact Us section below to request the deletion of that information.

10. Links.

For your convenience, the Site and this Policy may contain links to other websites. Company is not responsible for the privacy practices, advertising, products, services, or the content of such other websites. None of the links on the Site should be deemed to imply that Company endorses or has any affiliation with the links.

11. Security.

We incorporate commercially reasonable safeguards to help protect and secure your Personal Information. However, no data transmission over the Internet, mobile networks, wireless transmission, or electronic storage of information can be guaranteed 100% secure. As a result, we cannot guarantee or warrant the security of any information you transmit to or from the Site, and you provide us with your information at your own risk.

12. Your Choices About the Information We Collect.

Communications Preferences

We prefer to keep your Personal Information accurate and up to date. If you would like to change your contact information, please contact us using the information in the Contact Us section below. We will make good faith efforts to make requested changes in our then active databases as soon as reasonably practicable (but we may retain prior information as business records).

Controlling Your Cookies

You can opt out of cookies by enabling an opt-out preference signal on your browser or opting out of cookies in our Sites’ cookie preference centers.

On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive a notification when you are receiving a new cookie and how to turn cookies off. Please see the links below to learn how to modify your web browser’s settings on the most popular browsers:

• Apple Safari

• Google Chrome

• Microsoft Edge

• Mozilla Firefox

Note that if you turn cookies off, you may be unable to access certain parts or benefit from the full functionality of the Sites. To learn more about cookies and similar technologies or to opt-out of targeted advertising cookies, visit resources from the Digital Advertising Alliance (“DAA”). We do not control these opt-out links or whether any organization chooses to participate in these opt-out programs.

Please note that even if you exercise the opt-out choices above, you may continue to receive advertisements, for example, ads based on the website you are viewing (e.g., contextually based ads), or ads that are not targeted at you and may be less relevant. Also, if your browser (like some Safari browsers) is configured to reject opt-out cookies when you opt out on the DAA websites, your opt-out may not be effective.

Opt-Out Preference Signals (“OOPS”)

You can also opt out of non-essential cookies by opting-out of cookies in our Site’s cookie preference center or enabling an Opt-Out Preference Signal (“OOPS”). Some browsers and browser extensions support OOPS such as the Global Privacy Control (“GPC”) that can send a signal to the websites you visit indicating your choice to opt-out from certain types of data processing, including data sales. GPC is a web browser-level setting, maintained by either a browser or a browser extension, that a user or privacy-focused technology can set. Where required by law, when we detect such a signal, we will make reasonable efforts to respect your choices.

Do Not Track

Do Not Track (“DNT”) is a web browser setting that requests that a web application disable its tracking of an individual user. When you choose to turn on the DNT setting in your browser, your browser sends a special signal to websites, analytics companies, ad networks, plug in providers, and other web services you encounter while browsing to stop tracking your activity. Various third parties are developing or have developed signals or other mechanisms for the expression of consumer choice regarding the collection of information about an individual consumer’s online activities over time and across third-party websites or online services (e.g., browser do not track signals), but there is no universally agreed upon standard for what an organization should do when it detects a DNT signal. Currently, we do not monitor or take any action with respect to these signals or other mechanisms. You can learn more about Do Not Track here.

13. Your California Privacy Rights.

This section of the Policy applies solely to California residents. We adopt this Section to comply with the California Consumer Privacy Act of 2018 (“CCPA”) as amended by the California Privacy Rights Act (“CPRA”). Any terms defined in the CCPA or CPRA have the same meaning when used in this Section.

California residents have the following rights:

• To know the categories of Personal Information being collected about you, the purposes for which the categories of Personal Information are collected or used, and whether that information is sold or shared;

• To know the length of time we intend to retain each category of Personal Information;

• To know whether your Personal Information is sold or disclosed and to whom;

• To access your Personal Information;

• To delete the Personal Information you have provided to us, with certain exceptions;

• To correct your Personal Information;

• To opt out of the sale of Personal Information;

• To know if Sensitive Personal Information (“SPI”) is being collected about you, the categories of SPI being collected, the purposes for which the categories of SPI are collected or used, and whether the SPI is sold or shared;

• To limit the use of your SPI if it is used for cross-contextual behavioral advertising or for the purposes of inferring characteristics about you; and

• Not to be discriminated against, even if you exercise your privacy rights.

Request for Information, Correction, or Deletion

California residents have the right to request, under certain circumstances, that a business that collects Personal Information about them disclose the information listed below for the preceding 12 months:

• The categories of Personal Information collected about you;

• The categories of sources from which the Personal Information is collected;

• The business or commercial purpose for collecting, selling or sharing Personal Information;

• The categories of third parties to whom the business discloses Personal Information; and

• The specific pieces of Personal Information collected about you.

Please note that if we collected information about you for a single one-time transaction and do not keep that information in the ordinary course of business, that information will not be retained for purposes of a request under this section. In addition, if we have de-identified or anonymized data about you, we are not required to re-identify or otherwise link your identity to that data if it is not otherwise maintained that way in our records.

You can also request that we correct or delete your Personal Information. There may be certain exceptions to our obligation to correct or delete your information such as if you have an existing account or transaction with us or if we have a legitimate business reason to keep your information.

Personal Information We Collect and Share

We have collected and sold or shared the following categories of Personal Information from consumers within the last twelve (12) months:

We do not have actual knowledge that we sell or share the Personal Information of consumers under 16 years of age. We do not collect or share Sensitive Personal Information other than to perform our services to you or as reasonably necessary to resist malicious, deceptive, fraudulent, or illegal actions or ensure the safety of natural persons. 

Do Not Sell My Personal Information

As a California resident, you also have the right, at any time, to tell us not to sell Personal Information – this is called the “right to opt-out” of the sale of Personal Information. We do not sell Personal Information for money, but we recognize that some privacy laws define “Personal Information” in such a way that making available identifiers linked to you for a benefit may be considered a “sale.” To opt out of this, please use our Cookie Management Platform, or contact us using the information in the Contact Us section below. 

Right to Limit Use of Sensitive Personal Information

California residents have the right to limit the use of each type of Sensitive Personal Information for each purpose with each type of third-party partner. Please note that we only keep your Sensitive Personal Information for a limited time, and only for the transaction for which it is required. Currently, we do not provide your Sensitive Personal Information to any third parties other than those service providers that are necessary for us to provide our Services to you.

Right Not to Be Discriminated Against

We will not discriminate against you for exercising any of your rights under the CCPA. Unless permitted by California law, we will not:

• Deny you goods or services.

• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.

• Provide you a different level or quality of goods or services.

• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Third Party Marketing (“Shine The Light” law)

If you are a California resident with an established business relationship with us, you have the right under California Civil Code Section 1798.83 to request information regarding the disclosure of your Personal Information to third parties for their own direct marketing purposes in the preceding calendar year. You have the right to prevent disclosure of Personal Information, and we provide a cost-free option to exercise that right as set forth below in “Exercising Your California Privacy Rights.” Please include “Shine the Light Opt Out” in your request. We do not disclose Personal Information to third parties for their own direct marketing purposes if you have exercised your opt out right.   

Exercising Your California Privacy Rights

You or your authorized agent may make a request to access, correct, delete, opt-out of the sale of your Personal Information, or limit the use of your Sensitive Personal Information by contacting us by webform, mail, email or telephone by using the information in the “Contact Us” section below, or California residents may also use the following toll-free number: 877.242.2812.

If you use an authorized agent to submit your request, we may require proof of the written authorization you have given. We also may require you to confirm your identity and your residency to obtain the information, and you are only entitled to make this request twice in a 12-month period. For emails, please include “California Privacy Rights” as the subject line. You must include your full name, email address, and attest to the fact that you are a California resident. We will acknowledge your request within 10 days and respond to your request within 45 days or let you know if we need additional time. If you make this request by telephone, we may also ask you to provide the request in writing so that we may verify your identity. If we are unable to honor your request for any reason, we will notify you of the reason within the request time period.

14. Your Privacy Rights under Other US State Laws.

If you live in certain other U.S. states, such as Colorado, Connecticut, Delaware, Iowa, Maryland, Minnesota, Montana, Nebraska, Nevada, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, or Virginia, you may have rights the following rights with respect to your Personal Information:

• To confirm whether or not a controller is processing your personal data and to access such personal data;

• To know the categories of Personal Information we collect about you, the purposes for the collection, how long we retain your Personal Information, and whether that information is sold or shared or disclosed and to whom;

• To correct inaccuracies in your personal data;

• To delete your personal data;

• To obtain a copy of your personal data that you previously provided to us in a portable, and if technically feasible, readily usable format, if processing is carried out by automated means;

• To opt out of the processing of your personal data for purposes of (i) targeted advertising, (ii) the sale of personal data, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer.

To exercise any of these rights, you may make a request to confirm, access, correct, delete, obtain a copy, or opt-out of the processing of your personal data for targeting advertising, sale, or profiling by contacting us using the information in the Contact Us section below. Please include “Privacy Rights” as the subject line. You must include your full name, email address, and attest to the state in which you are a resident.

For your security, we may require you to confirm your identity and your residency in order to obtain Personal Information from us or to effectuate a deletion, and you are only entitled to make this request up to twice annually.

If your state provides you with the right to opt out of the processing of your personal data for purposes of (i) targeted advertising, (ii) the sale of personal data, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer, you may exercise these rights using our Cookie Management Platform.

We will process your request within 45 days or let you know if we need additional time or cannot process your request. If you make this request by telephone, we may also ask you to provide the request in writing so that we can verify your identity. If we are unable to honor your request for any reason, we will notify you of the reason within the request time period.

Appeals of Our Decisions

In some jurisdictions, you may appeal to us if we refuse to take action on your exercise of certain privacy choices described above. If you are a resident of Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, or Virginia and we deny your verified request to exercise any of the privacy rights described in this Policy, you have the right to appeal our decision within a reasonable period of time after your receipt of our decision.

You may appeal our decision by sending an email to the address in the Contact Us section below.  Please include “Privacy Rights Appeal” in the subject line.  We will respond to an appeal within 45 days (even where applicable law allows a longer time to respond).  We may extend the time to respond where allowed by applicable law and reasonably necessary and will inform you if we need more time. If we still decline to act on the request you made, we will provide you with an explanation of why we declined your request, information on how to appeal our decision and/or how to make a complaint to your state Attorney General, if appliable law provides for such a complaint. 

15. Your Rights Under the General Data Protection Regulation.

This section of the Policy applies if you are a data subject who resides or is located in the European Economic Area (“EEA”). We adopt this section to comply with European privacy laws, including the General Data Protection Regulation (“GDPR”). Any terms defined in the GDPR have the same meaning when used in this section.

Under applicable law, we are considered the “data controller” of the Personal Information we handle under this Policy. In other words, we are responsible for deciding how to collect, use and disclose this information, subject to applicable law.

We want to ensure that the Personal Information we possess is always accurate and therefore we encourage you to update your information in case any changes have occurred. We have listed below the rights that you may be able to exercise in respect of the processing of your Personal Information, subject to applicable law. We take reasonable steps to ensure that the Personal Information that we process is limited to the Personal Information that are required in connection with the purposes set out in this Policy.

If you are a resident of or located within the EEA, you have certain data protection rights. These rights include:

• The right to access, update or delete the information we have collected from you.

• The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.

• The right of erasure – to request deletion of your Personal Information.

• The right to object. You have the right to object to our processing of your Personal Information.

• The right of restriction. You have the right to request that we restrict the processing of your Personal Information.

• The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable, and commonly used format.

• The right to withdraw consent. You also have the right to withdraw your consent at any time where we relied on your consent to process your Personal Information.

• The right not to be subject to automated decision-making, including profiling, which produces legal or similarly significant effects. 

  Legal Basis for Processing Personal Information

We rely on the following legal bases for processing your Personal Information:

• Contract: To conclude or perform a contract with you; for example:

  • To open and manage your client account;

  • To execute investment instructions and to provide other Account Services;

  • To manage our accounts and records;

  • To provide investment advice;

  • For client onboarding and KYC data collection; or

  • To handle your inquiries and requests.

• Legitimate Interests: When we process your Personal Information for our legitimate interests, we make sure to consider and balance any potential impact on you and your rights under data protection laws. Our legitimate business interests do not automatically override your interests – we will not use your Personal Information for activities where our interests are overridden by the impact on you unless we have your consent or those activities are otherwise required or permitted to by law. You have the right to object to processing that is based on our legitimate interests, as further described below. Examples of legitimate interests include:

  • For IT security, logging, and access monitoring;

  • To detect, prevent, or investigate security breaches or fraud;

  • To prevent unauthorized access;

  • To respond to your customer service inquiries and requests for information;

  • To maintain, improve, and analyze our Site, and Services we offer;

  • For our strictly necessary cookies;

  • To conduct marketing activities; and

  • To facilitate the functionality of our Site.

• Legal Compliance: To comply with our legal obligations; for example:

  • For AML or KYC checks;

  • For sanctions screening;

  • For fraud detection;

  • To maintain appropriate records for internal administrative purposes and as required by applicable law or agency regulations,

  • For required reporting, such as tax, accounting or financial reporting obligations; and

  • To provide important notices as required by law.

• Consent: We rely on consent when we process your Personal Information for purposes that are not necessary for providing our investment services, for fulfilling our legal or regulatory obligations, or for pursuing our legitimate business interests.  These include:

  • Sending marketing communications, including newsletters, educational content and information about events or services not included in your advisory agreement;

  • Using non-essential cookies and tracking technologies, such as for analytics, advertising, cross-site tracking, retargeting and behavioral profiling;

  • Collecting optional information in surveys, webinars, beta programs, or promotional events;

  • Enabling certain personalization features that are not required for delivering advisory services;

  • Sharing your Personal Information with third parties for their own marketing purposes (only when you have provided express consent). 

  • You have the right to withdraw your consent at any time without affecting the lawfulness of any processing that occurred before withdrawal.

International Transfers

Your Personal Information may be transferred to and processed in countries outside the EEA (like the United States) that may not have the same data protection laws.  Where required, we use Standard Contractual Clauses (SCCs) approved by the European Commission; and additional safeguards, where necessary.

How to Exercise Your Rights Under the GDPR

If applicable, you may exercise any of your rights under the GDPR by submitting a verifiable data subject request to us by using the information in the Contact Us section below. You may make a request related to your Personal Information or on behalf of someone for which you have authorization. You must include your full name, email address, and attest to the fact that you are a citizen or resident of the EEA by including your country of citizenship or residence in your request. We may require you to confirm your identity and/or legal standing for the request as well as your residency in the EEA to obtain the information. We will respond to your request within 30 days or let you know if we need additional time.

Please note that we will ask you to verify your identity before responding to such requests, and we may deny your request if we are unable to verify your identity or authority to make the request.

Should you wish to raise a concern about our use of your data (and without prejudice to any other rights you may have), you have the right to do so with your local supervisory authority- a list of authorities is available at https://www.edpb.europa.eu/about-edpb/about-edpb/members_en; however, we hope that we can assist with any queries or concerns you may have about our use of your Personal Information first by contacting us.

16. Your Rights Under the UK GDPR.

This section applies only to individuals located in the United Kingdom at the time their Personal Information is collected or processed.  It supplements, and should be read together with, the rest of this Policy.

We process Personal Information as a “controller” under the UK GDPR and the UK Data Protection Act 2018 based on the same legal bases described in the GDPR section above:

• Contract

• Legitimate Interests

• Legal Obligation

• Consent

Where UK law requires consent (particularly for marketing or non-essential cookies), we will request it separately and clearly.

Individuals in the UK have the following rights:

• Right of access

• Right to rectification

• Right to erasure

• Right to restrict processing

• Right to data portability

• Right to object

• Right to withdraw consent

• Rights relating to automated decision-making.

If we share your personal data within Company or with third parties located outside the United Kingdom, we take steps to ensure that appropriate safeguards are in place to guarantee the continued protection of your personal data, such as by entering into the UK International Data Transfer Agreement or the International Data Transfer Addendum to the European Commission’s SCCs, adopted by the UK Government under section 119A of the Data Protection Act 2018, or another lawful transfer mechanism permitted under UK law.

You have the same data subject rights as those for the EU listed above, except that references to the "GDPR" should be read as references to the "UK GDPR" and complaints should be filed with the UK supervisory authority, the Information Commissioner’s Office at https://ico.org.uk/.

17. Changes to This Privacy Policy.

We may change this Privacy Policy at any time. We will post all changes to this Policy on this page and will indicate at the top of the page the modified policy’s effective date. We therefore encourage you to refer to this page on an ongoing basis so that you are aware of our current privacy policy. If required by the applicable law, we will notify you of the changes.

By continuing to use the Site or Services or providing us with information following such a replacement Policy being uploaded, you agree that you will be bound by the Privacy Policy as changed.

18. Contact Us.

If you have any questions regarding this Policy, please contact us as follows:

Raith Capital Partners, LLC

666 Third Avenue, Suite 1701

New York, NY  10017

Webform: https://www.raithcapital.com/contact

Email: compliance@raithcapital.com

Phone: 212.938.6995