Privacy Policy

FUND 41 ("we," "us," or "our") operates the website located at www.fund41.com (the "Site"). This Privacy Policy describes how we collect, use, disclose, and safeguard personal information about visitors to our Site and individuals who contact us in connection with our investment activities.

This policy applies to all personal data processed by FUND 41 in connection with the Site and our business operations. It is designed to comply with applicable data protection laws, including the General Data Protection Regulation (GDPR) (EU) 2016/679, the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA), and other applicable U.S. state privacy laws.

By accessing or using our Site, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with the terms of this policy, please do not access the Site.

We collect the following categories of personal information:

2.1 Information You Provide Directly

• Contact Information: Name, email address, phone number, company name, and job title when you submit our contact form or reach out via email.
• Investment Inquiry Data: Information about your investment interests, accredited investor status, and professional background when you express interest in FUND 41.
• Correspondence: Records of communications you send to us, including emails, messages, and attachments.
• Newsletter Subscriptions: Email address and preferences if you subscribe to our communications.

2.2 Information Collected Automatically

• Log Data: IP address, browser type and version, operating system, referring URLs, pages visited, time and date of visit, and time spent on pages.
• Device Information: Device type, unique device identifiers, and mobile network information.
• Usage Data: Information about how you interact with our Site, including links clicked, scroll depth, and navigation patterns.
• Cookies and Tracking Technologies: See Section 6 for detailed information about our use of cookies.

2.3 Information from Third Parties

• Analytics Providers: Aggregated and anonymized data from analytics services such as Google Analytics.
• Professional Networks: Publicly available professional information from LinkedIn or similar platforms when you connect with us professionally.
• Business Partners: Information shared by co-investors, referral partners, or industry contacts in connection with potential investment opportunities.

We use the personal information we collect for the following purposes:

• Responding to Inquiries: To respond to your questions, investment inquiries, and requests for information about FUND 41.
• Investor Relations: To communicate with prospective and existing investors about fund activities, performance updates, and investment opportunities.
• Due Diligence: To verify accredited investor status and conduct required regulatory compliance checks.
• Marketing Communications: To send newsletters, fund updates, and industry insights to individuals who have opted in to receive such communications.
• Site Analytics: To analyze Site usage, improve our content and user experience, and understand how visitors interact with our Site.
• Legal Compliance: To comply with applicable laws, regulations, and legal processes, including anti-money laundering (AML) and know-your-customer (KYC) requirements.
• Security: To detect, prevent, and address fraud, security breaches, and other potentially prohibited or illegal activities.
• Business Operations: To manage our business relationships, maintain records, and fulfill contractual obligations.

For individuals located in the European Economic Area (EEA), United Kingdom, or Switzerland, we process your personal data on the following legal bases under Article 6 of the GDPR:

We do not sell, rent, or trade your personal information to third parties for their own marketing purposes. We may share your information in the following limited circumstances:

• Service Providers: We engage trusted third-party vendors who assist us in operating our Site and business (e.g., email service providers, analytics platforms, legal counsel, compliance services). These parties are contractually bound to use your data only as directed by us and in accordance with this policy.
• Legal Requirements: We may disclose your information if required by law, court order, or governmental authority, or if we believe disclosure is necessary to protect our rights, your safety, or the safety of others.
• Business Transfers: In the event of a merger, acquisition, reorganization, or sale of assets, your information may be transferred as part of that transaction. We will notify you of any such change in ownership or control.
• Co-Investors and Partners: With your consent, we may share relevant information with co-investors or strategic partners in connection with specific investment opportunities.
• Professional Advisors: With attorneys, accountants, auditors, and other professional advisors who are bound by confidentiality obligations.

Our Site uses cookies and similar tracking technologies to enhance your browsing experience, analyze Site traffic, and understand where our visitors are coming from.

Types of Cookies We Use

Managing Cookies

You can control and manage cookies through your browser settings. Most browsers allow you to refuse cookies, delete existing cookies, or be notified when a cookie is set. Please note that disabling certain cookies may affect the functionality of our Site. For more information about managing cookies, visit www.allaboutcookies.org.

For Google Analytics specifically, you can opt out by installing the Google Analytics Opt-out Browser Add-on.

We retain personal information for as long as necessary to fulfill the purposes for which it was collected, comply with our legal obligations, resolve disputes, and enforce our agreements. Specific retention periods include:

• Contact and Inquiry Data: Retained for up to 3 years from the date of last contact, unless a longer period is required for legal or regulatory purposes.
• Investor Records: Retained for a minimum of 7 years following the end of the investment relationship, as required by applicable securities and financial regulations.
• AML/KYC Records: Retained for a minimum of 5 years following the end of the business relationship, as required by applicable anti-money laundering laws.
• Marketing Data: Retained until you unsubscribe or withdraw consent, plus an additional 30 days for processing.
• Website Analytics Data: Retained in anonymized or aggregated form for up to 26 months.
• Legal Hold Data: Retained for the duration of any legal proceedings or regulatory investigations, plus applicable statutes of limitations.

When personal data is no longer required, we securely delete or anonymize it in accordance with our data retention and destruction policies.

Depending on your location and applicable law, you may have the following rights with respect to your personal information. To exercise any of these rights, please contact us at privacy@fund41.com.

We will respond to all verified requests within 30 days (or 45 days where permitted by law with notice). We may need to verify your identity before processing your request. We will not discriminate against you for exercising your privacy rights.

If you are located in the European Economic Area (EEA), United Kingdom, or Switzerland, you have additional rights under the GDPR and applicable national data protection laws.

Data Controller

FUND 41 acts as the data controller for personal data collected through this Site. Our contact details are provided in Section 15 below.

Right to Lodge a Complaint

You have the right to lodge a complaint with your local data protection supervisory authority if you believe we have processed your personal data in violation of applicable law. A list of EEA supervisory authorities is available at edpb.europa.eu. For UK residents, the relevant authority is the Information Commissioner's Office (ICO).

Data Protection Officer

We have designated a Data Protection Officer (DPO) who can be contacted at privacy@fund41.com for any GDPR-related inquiries.

If you are a California resident, the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), provides you with specific rights regarding your personal information.

Categories of Personal Information Collected

In the preceding 12 months, we have collected the following categories of personal information as defined by the CCPA:

• Identifiers (name, email address, IP address)
• Professional or employment-related information
• Internet or other electronic network activity information
• Inferences drawn from the above to create a profile

Your CCPA Rights

• Right to Know: You may request disclosure of the categories and specific pieces of personal information we have collected about you, the sources, our business purposes, and the categories of third parties with whom we share it.
• Right to Delete: You may request deletion of personal information we have collected from you, subject to certain exceptions.
• Right to Correct: You may request correction of inaccurate personal information we maintain about you.
• Right to Opt-Out of Sale/Sharing: We do not sell or share personal information for cross-context behavioral advertising. No opt-out is required, but you may contact us to confirm.
• Right to Limit Use of Sensitive Personal Information: We do not use sensitive personal information for purposes beyond those permitted by the CPRA.
• Right to Non-Discrimination: We will not discriminate against you for exercising your CCPA rights.

How to Submit a CCPA Request

To submit a verifiable consumer request, contact us at privacy@fund41.com with the subject line "CCPA Privacy Request." You may also designate an authorized agent to make a request on your behalf, subject to identity verification requirements. We will respond within 45 days of receiving a verifiable request.

FUND 41 is based in the United States. If you are located outside the United States, please be aware that your personal information will be transferred to, stored, and processed in the United States, where data protection laws may differ from those in your country.

For transfers of personal data from the EEA, UK, or Switzerland to the United States, we rely on appropriate safeguards, including:

• Standard Contractual Clauses (SCCs) approved by the European Commission
• UK International Data Transfer Agreements (IDTAs) for transfers from the UK
• Adequacy decisions where applicable

By using our Site or providing us with your personal information, you acknowledge and consent to the transfer of your information to the United States as described in this policy.

We implement appropriate technical and organizational measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include:

• Encryption of data in transit using TLS/SSL protocols
• Access controls and authentication requirements for systems containing personal data
• Regular security assessments and vulnerability testing
• Employee training on data protection and security practices
• Incident response procedures for data breaches

However, no method of transmission over the Internet or electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security. In the event of a data breach that is likely to result in a high risk to your rights and freedoms, we will notify you and relevant authorities as required by applicable law.

Our Site is not directed to individuals under the age of 18, and we do not knowingly collect personal information from children under 18. If we become aware that we have inadvertently collected personal information from a child under 18, we will take steps to delete such information promptly. If you believe we have collected information from a child under 18, please contact us at privacy@fund41.com.

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes, we will:

• Update the "Last Updated" date at the top of this policy
• Post a notice on our Site for a reasonable period
• Where required by law, notify you directly via email

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information. Your continued use of the Site after any changes constitutes your acceptance of the updated policy.

If you have any questions, concerns, or requests regarding this Privacy Policy or our data processing practices, please contact us:

We will acknowledge your request within 5 business days and provide a substantive response within 30 days (or as required by applicable law). For complex requests, we may extend this period by an additional 30 days with prior notice.