Privacy Policy

Polaris Reach Capital LLC (“Polaris Reach Capital,” “we,” “us,” or “our”) operates a private, invitation-only portal through which qualified investors track their participation in our lending program. This Privacy Policy explains what information we collect, how we use and protect it, and the choices you have. It applies to your use of this portal and related communications.

1. Information we collect

• Identity & contact: name, email address, phone number, and mailing address.
• Verification & eligibility: information needed to confirm your identity and investor status (e.g. government identification and accreditation or qualification details), where required.
• Financial & transactional: banking or payment details you provide, contributions, distributions, positions, and transaction history.
• Account & usage: login credentials (stored in hashed form), authentication factors, IP address, device and browser data, and activity within the portal.
• Communications: messages, requests, and documents you send to us.

2. How we use your information

• To administer your account and your participation in the lending program.
• To verify your identity and eligibility and to comply with anti-money-laundering (AML), know-your-customer (KYC), tax, and other legal obligations.
• To process contributions, distributions, and withdrawal requests.
• To communicate with you about your account, transactions, and material updates.
• To secure the platform, prevent fraud, and enforce our terms.
• To operate, maintain, and improve the portal.

3. Legal bases

Where applicable law requires a legal basis, we rely on: performance of our agreement with you; compliance with legal obligations; our legitimate interests in operating and securing the service; and, where required, your consent.

4. How we share information

We do not sell your personal information. We share it only as needed to operate the service and comply with law, including with:

• Service providers who host and support the platform (for example, our cloud and database infrastructure), under confidentiality obligations.
• Identity, banking, and payment partners used to verify investors and move funds.
• Professional advisors such as auditors, accountants, and lawyers.
• Authorities and regulators where required by law, legal process, or to protect our rights.
• Successors in connection with a merger, financing, or transfer of the business.

5. Data security

We use administrative, technical, and organizational safeguards designed to protect your information, including encryption in transit, access controls, row-level data isolation, and support for two-factor authentication. No system is completely secure, and we cannot guarantee absolute security.

6. Data retention

We retain your information for as long as your account is active and thereafter as needed to meet legal, tax, accounting, and regulatory requirements, resolve disputes, and enforce our agreements.

7. Your rights

Depending on your location, you may have the right to access, correct, delete, or receive a copy of your personal information, and to object to or restrict certain processing or withdraw consent. To exercise these rights, contact us at privacy@polaris-reach.com. We may need to verify your identity, and some data must be retained where the law requires.

8. Cookies

We use strictly necessary cookies to keep you signed in and to secure your session. We do not use advertising cookies. Disabling essential cookies may prevent the portal from functioning.

9. Children

The portal is intended solely for qualified investors and is not directed to anyone under 18. We do not knowingly collect information from children.

10. Changes to this policy

We may update this policy from time to time. Material changes will be posted here with a revised effective date, and where required we will notify you.

11. Contact us

Questions about this policy or your information? Contact Polaris Reach Capital LLC at privacy@polaris-reach.com.