Hondius Capital Management

Legal

Privacy Policy

Hondius Capital Management, LP

Effective October, 2026

Introduction

Hondius Capital Management, LP ("Hondius," "we," "us" or "our") respects your privacy. This Privacy Policy explains what personal information we collect, how we use and share it, and how we protect it. It applies to information we collect through our website at https://www.hondiuscapital.com (the "Website") and, on behalf of Hondius and the private investment funds it manages (the "Funds"), in connection with investments in the Funds. As a registered investment adviser, Hondius is subject to the Gramm-Leach-Bliley Act and SEC Regulation S-P, and as a CFTC registrant, to the CFTC's privacy rules under 17 CFR Part 160. Investors in the Funds may receive additional privacy disclosures in the Funds' offering documents, and investors outside the United States may have additional rights under the laws of their jurisdiction or the jurisdiction of the Fund in which they invest.

Information We Collect

Depending on how you interact with us, we may collect:

  • Identification and contact information, such as name, address, email address, telephone number, date of birth, Social Security or tax identification number and government-issued ID.

  • Financial and eligibility information, such as income, net worth, investable assets, accredited investor, qualified purchaser and qualified client status, investment experience and investment objectives.

  • Investment information, such as subscription documents, capital contributions, redemptions, account balances, tax forms and bank account or wire transfer details.

  • Entity investor information, if you invest through or on behalf of an entity, such as information about its beneficial owners, control persons and authorized signatories.

  • Website information, such as IP address, browser type, pages visited and information collected through cookies and similar technologies.

  • Professional information, if you are a business contact, service provider or applicant for employment with Hondius, including information required for background checks and regulatory filings.

We collect this information directly from you (for example, through forms, subscription documents and correspondence), automatically when you use the Website, and from third parties such as the Funds' administrator, placement agents, identity verification services and public sources.

How We Use Information

We use personal information to:

  • process subscriptions, redemptions and other transactions and administer your investment in the Funds;

  • verify your identity and eligibility, including anti-money laundering (AML), know-your-customer (KYC) and investor eligibility requirements;

  • provide investor reports and tax information, communicate with you and respond to your inquiries;

  • operate, secure and improve the Website;

  • comply with legal, regulatory, tax reporting and recordkeeping obligations and respond to requests from regulators; and

  • protect against fraud and enforce our rights.

How We Share Information

We do not sell or share your personal information with affiliates or unaffiliated third parties for their own use or for marketing. We disclose personal information only where necessary to administer your investment and operate the Funds (for example, to the Funds' administrator, auditors, legal counsel, prime brokers, custodians and banks), to service providers who support our operations under confidentiality obligations, with your consent or at your direction (for example, to your financial advisor), or as required by law, such as in response to requests from the SEC, CFTC, NFA or other regulators, tax authorities, law enforcement or courts.

How We Protect Information

We maintain administrative, technical and physical safeguards designed to protect personal information, including access limited to personnel who need it and oversight of our service providers. We maintain an incident response program, and if sensitive customer information is, or is reasonably likely to have been, accessed or used without authorization, we will notify affected individuals as required by Regulation S-P, CFTC rules and applicable state law. No method of transmission over the internet is completely secure, so please do not send sensitive information to us by unencrypted email.

Cookies

The Website uses cookies and similar technologies to operate the site and understand how it is used. You can set your browser to refuse cookies, although some features may not work properly. The Website is hosted by a third-party platform that may also collect usage information under its own privacy policy.

Retention

We keep personal information for as long as needed to administer your investment and as required by law. The Investment Advisers Act of 1940 generally requires investment advisers to retain records for at least five years, and CFTC rules, AML and tax laws may require longer retention.

Your Choices and Rights

You may request access to or correction of your personal information by contacting us. Because we are required to keep certain records by law, we may not be able to delete all information on request. Residents of certain states may have additional rights under state privacy laws; many of these laws do not apply to information we hold under the Gramm-Leach-Bliley Act, but we will respond to requests as required by applicable law. You may opt out of marketing emails at any time by using the unsubscribe link or contacting us.

Children

The Website is not intended for anyone under 18, and we do not knowingly collect personal information from children.

Changes to This Policy

We may update this Privacy Policy from time to time. The updated version will be posted on the Website with a new effective date and, where required, provided to Fund investors.

Contact Us

For questions about this Privacy Policy or to make a request, contact: Hondius Capital Management, LP, Attention: Steve Bischoff, Chief Compliance Officer, 85 Washington Street, 1st Floor, Norwalk, Connecticut 06854; telephone (203) 930-2200; email info@hondiuscapital.com.