Privacy Policy

Effective Date: January 1, 2026

This Privacy Policy applies to information collected through embarkfunds.com in connection with your use of the Site or your interactions with Embark MGMT, LLC ("Embark," "we," "us," or "our").

2.1 Scope

This Privacy Policy applies to information collected through embarkfunds.com in connection with your use of the Site or your interactions with Embark.

2.2 Information We Collect

We may collect the following categories of information:

Information You Provide:

  • Name, email, phone number
  • Investor accreditation status
  • Subscription materials, KYC/AML documentation
  • Investment preferences and capital commitment details

Automatically Collected Information:

  • Browser type, IP address, device identifiers
  • Pages visited and Site interaction data
  • Time and date of access

We do not knowingly collect personal data from children under 13.

2.3 How We Use Personal Information

  • To assess investor eligibility
  • To conduct anti-money laundering (AML) and compliance screening
  • To fulfill regulatory and reporting obligations
  • To manage fund communications and investor relations
  • To operate and improve Site performance

We do not sell your personal data, and we do not use it for advertising or marketing by third parties.

2.4 Sharing and Disclosure

We may share personal information with:

  • Fund service providers (e.g., custodians, administrators, auditors)
  • Government or regulatory bodies (e.g., IRS, SEC) as legally required
  • Our affiliates and consultants (e.g., ProFlex Finance, LLC) as needed for fund operations

All disclosures are subject to confidentiality safeguards and purpose limitations.

2.5 Data Security

We maintain reasonable technical, administrative, and physical security measures to protect your data, including:

  • Encrypted communications and secure document submission
  • Restricted access to sensitive information
  • Use of U.S.-based qualified custodians

2.6 Data Retention

We retain personal data only as long as necessary for legal, regulatory, or operational purposes. When no longer needed, data is securely destroyed.

2.7 California Privacy Rights (CPRA)

Embark MGMT LLC is not currently subject to the California Consumer Privacy Act (CCPA/CPRA). However, in the interest of transparency, we provide the following rights to California residents where applicable:

You may request:

  • Access to the categories of personal data we collect
  • Deletion or correction of your personal data
  • Information about third parties with whom we've shared data

Submit requests to: privacy@embarkfunds.com. We will verify identity before responding and will not discriminate based on your request.

2.8 Cookies & Tracking

We use only functional cookies for Site performance and session management. No advertising or tracking cookies are used. You may disable cookies in your browser settings, but the Site may not function properly.

2.9 International Users

This Site is intended for U.S. users only. If you access it from outside the U.S., you consent to your information being transferred and stored in the United States.

2.10 Policy Updates

This Privacy Policy may be updated periodically. We will post all updates to this page and revise the effective date accordingly.

Contact Information

For any questions about this Privacy Policy, please contact us:

Embark MGMT, LLC

8 The Green, Suite #24538

Dover, DE 19901

Email: privacy@embarkfunds.com

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