PRIVACYPOLICY

Dated:[●], 2024

Introduction

SPVdot Co., a  Delaware corporation ("Company"or "We"or “our”or “us”or “SPV”)respect your privacy and are committed to protecting it through ourcompliance with this policy.

This policy describes thetypes of information we may collect from you or that you may providewhen you visit our websites or use the SPV platform or other servicesprovided through our websites, including those at www.spv.co(collectively, our "Website"),or when you interact with content, emails, messages, texts and othercommunications sent by us or users of our Website, and our practicesfor collecting, using, maintaining, protecting, and disclosing thatinformation.

This policy applies to information we collect:

• On this Website, as a guest, visitor, or registered user.
• In email, text, and other electronic messages between you and the Company, this Website, or users of this Website;
• Through mobile and desktop applications you download from this Website, which provide dedicated non-browser-based interaction between you and this Website.
• When you interact with our advertising and applications on third-party websites and services if those applications or advertising include links to this policy.

It does not apply to information collected by:

• Us offline; or
• Any third party, including through any application or content that may link to or be accessible from or on the Website.

Please read this policy carefully to understand our policies andpractices regarding your information and how we will treat it. If youdo not agree with our policies and practices, your choice is not touse our Website. By accessing or using this Website, you agree tothis privacy policy. This policy may change from time to time (seebelow under the heading “Changes to Our Privacy Polity”). Yourcontinued use of this Website after we make changes is deemed to beacceptance of those changes, so please check the policy periodicallyfor updates.

Children Under the Age of 18

Our Website is not intended for children under 18 years of age. Noone under age 18 may provide any information to or on the Website. Wedo not knowingly collect personal information from children under 18.If you are under 18, do not use or provide any information on thisWebsite or through any of its features, register on the Website, orprovide any information about yourself to us, including your name,address, telephone number, email address, or any screen name orusername. If we learn we have collected or received personalinformation from a child under 18 without verification of parentalconsent, we will delete that information. If you believe we mighthave any information from or about a child under 18, please contactus at [●].

Information We Collect About You and How We Collect It

We collect several types ofinformation from and about users of our Website ("personalinformation"),including information:

• By which you may be personally identified, such as name, user name, home address, work address, gender, e-mail address, marital status, telephone number, social security number, tax ID number, employer ID number, government ID number, passport information, picture, billing address, professional history, copies of identification forms, money transfer instructions, funds transfer accounts, investment documents, credit reports and history, and other identifiers by which you may be contacted online or offline;
• Financial information such as bank account information, financial objectives, transaction history, salary, investment documents, financial statements, assets, investments, estate planning information, and ownership and control affiliations and relationships; and/or
• About your internet connection, the equipment you use to access our Website, and usage details.

We collect this information:

• Directly from you when you provide it to us.
• From third parties, for example, our business partners.
• Automatically as you navigate through the Website. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.

Information You Provide to Us

The information we collect on or through our Website may include:

• Information that you provide by filling in forms on our Website. This includes information provided at the time of registering to use our Website, subscribing to our service, posting material, or requesting further services. We may also ask you for information when you report a problem with our Website.
• Information contained in documents that you upload to us.
• Records and copies of your correspondence (including email addresses) if you contact us.
• Your responses to surveys that we might ask you to complete for research purposes.
• Details of transactions you carry out through our Website.

You also may provideinformation to be published or displayed (hereinafter, "posted")on the Website, or transmitted to other users of the Website or thirdparties (collectively, "UserContributions").Your User Contributions are posted on and transmitted to others atyour own risk. Although we limit access to certain pages, please beaware that no security measures are perfect or impenetrable.Additionally, we cannot control the actions of other users of theWebsite with whom you may choose to share your User Contributions.Therefore, we cannot and do not guarantee that your UserContributions will not be viewed by unauthorized persons.

From Third Parties

We obtain information from third parties that we work with orengage in connection with our services, including partners such asbanks and payment processors, background verification services,credit reporting agencies, government databases, identityverification services, and third parties that may assist with theassessment of your eligibility or suitability to participate incertain opportunities or services.

Information We Collect Through Automatic Data CollectionTechnologies

As you navigate through and interact with our Website or interactwith content sent to you by users of our Website, we may useautomatic data collection technologies to collect certain informationabout your equipment, browsing actions, and patterns, including:

• Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
• Information that tracks when and how you interact with content sent by us and by other users of the Website;
• Information about your computer and internet connection, including your IP address, operating system, and browser type.

We also may use these technologies to collect information aboutyour online activities over time and across third-party websites orother online services (behavioral tracking). See below under heading“Choices About How We Use and Disclose Your Information” forinformation on how you can opt out of behavioral tracking on theWebsite and how we respond to web browser signals and othermechanisms that enable consumers to exercise choice about behavioraltracking.

The information we collect automatically may include personalinformation, or we may maintain it or associate it with personalinformation we collect in other ways or receive from third parties.It helps us to improve our Website and to deliver a better and morepersonalized service, including by enabling us to:

• Estimate our audience size and usage patterns.
• Store information about your preferences, allowing us to customize our Website according to your individual interests.
• Provide services to you through the platform offered through the Website.
• Recognize you when you return to our Website.

The technologies we use for this automatic data collection mayinclude:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
• Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see below under heading “Choices About How We Use and Disclose Your Information.”
• Web Beacons. Pages of the Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the

Company, for example, to count users who have visited those pagesor opened an email and for other related website statistics (forexample, recording the popularity of certain website content andverifying system and server integrity).

How We Use Your Information

We use and disclose information that we collect about you or thatyou provide to us, including any personal information:

• To present, develop, improve, maintain, and deliver our Website and its contents and services to you.
• To provide you with the fund formation, special purpose vehicle, fund management and other services provided through the Website.
• To allow fund sponsors, investment leads and other investors to discover and communicate with potentially qualified investors.
• To allow users of the Website to communicate with each other.
• To allow users of the Website to track how, when and by whom content sent from the Website is interacted with;
• To determine your eligibility or suitability for various services and opportunities.
• To provide you with information, products, or services that you request from us.
• To fulfill any other purpose for which you provide it.
• To provide you with notices about your account.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us.
• To notify you about changes to our Website or any products or services we offer or provide though it.
• To comply with regulations requiring us to identify our users and customers and related parties to regulatory, oversight, government, industry, or compliance bodies.
• To make and file tax and other compliance reports.
• In any other way we may describe when you provide the information.
• For any other purpose with your consent.

We may also use your information to contact you about our servicesthat may be of interest to you. If you do not want us to use yourinformation in this way, please check the relevant box located on theform on which we collect your data. For more information, see belowunder the heading “Choices About How We Use and Disclose YourInformation.”

Disclosure of Your Information

We may disclose aggregated information about our users, andinformation that does not identify any individual, withoutrestriction.

We may disclose personal information that we collect or youprovide:

• To our subsidiaries and affiliates.
• To other users of the Website where we have obtained your information at their request or initiation, through their use of the Website or where they have contacted you and asked you to provide such information.
• To users of the Website that send content from the Website to you.
• To fund sponsors and investment leads on the Website.
• To other users of the Website that you interact with on the Website, such as fund sponsors, investment leads, and other users and investors, and employees, agents, directors, representatives, and affiliates of such persons, including administrators, attorneys, advisors, accountants, and other third-party service providers.
• To third parties that you invite to access the Website, such as investment advisors, accountants, attorneys, administrators, and tax advisors.
• To auditors, accountants, certification providers, and other financial, accounting, security, and process auditing, attestation, and certification groups.
• To contractors, service providers, and other third parties, including data centers, website application developers, hosting providers, maintenance services providers, backup services, storage application and facility providers, infrastructure providers, investment advisors, investment management services providers, software licensors, database providers, data security providers, privacy services providers, financial institutions, banking partners, credit reporting agencies, verification services, background and screening services, compliance review services, legal and accounting service providers, insurers and brokers, payment processors, and other third parties we use to support our business and the services we provide to you and our other customers.
• To international, state, federal, and local governments, quasi-governmental bodies, self-regulatory agencies, industry oversight, regulatory and governance bodies, tax and revenue agencies, securities regulatory agencies, professional groups and associations, corporate oversight regulators, securities regulators, banking regulators and other regulators.
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by the Company about our Website users is among the assets transferred.
• To fulfill the purpose for which you provide it.
• For any other purpose disclosed by us when you provide the information.
• With your consent.

We may also disclose your personal information:

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• To enforce or apply our terms of use (See our Terms of Service) and other agreements.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection, credit risk reduction and increased privacy security.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personalinformation you provide to us. We have created mechanisms to provideyou with the following control over your information:

• Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe's website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
• Promotional Offers from the Company. If you do not wish to have your contact information used by the Company to promote our products or services, you can opt-out by checking the relevant box located on the form on which we collect your data or by sending us an email stating your request to [●]. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions.

California residents may have additional personal informationrights and choices. Please see below under the heading “YourCalifornia Privacy Rights” for more information.

Nevada residents who wish to exercise their sale opt-out rightsunder Nevada Revised Statutes Chapter 603A may submit a request to:

[●]
Email: [●]

However, please know we do not currently sell data triggering thatstatute's opt-out requirements.

Accessing and Correcting Your Information

You can review and change your personal information by logginginto the Website and visiting your account profile page.

You may also send us an email at [●] to request access to,correct or delete any personal information that you have provided tous. We may not be able to delete your personal information except byalso deleting your user account. We may not accommodate a request tochange information if we believe the change would violate any law orlegal requirement or cause the information to be incorrect.

We are not responsible for revising or removing your personal dataobtained by any third party who has previously been provided yourinformation by us in accordance with this policy or any third partyto whom you have provided such information (whether by sharing yourlogin and password, or otherwise).

Your California Privacy Rights

This Section applies solely toall visitors, users, and others who reside in the State of California("consumers"or "you").We adopt this notice to comply with the California Consumer PrivacyAct of 2018 (“CCPA”)and any terms defined in the CCPA have the same meaning when used inthis Policy.

This Policy does not apply to workforce-related personalinformation collected from California-based employees, jobapplicants, contractors, or similar individuals.

Where noted in this Policy,the CCPA temporarily exempts personal information reflecting awritten or verbal business-to-business communication ("B2Bpersonal information")from some its requirements.

Information We Collect

We collect information thatidentifies, relates to, describes, references, is reasonably capableof being associated with, or could reasonably be linked, directly orindirectly, with a particular consumer, household, or device ("CAPersonal Information").CA Personal Information does not include:

• Publicly available information from government records.
• Deidentified or aggregated consumer information.
• Information excluded from the CCPA's scope, like:
  • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 and the California Confidentiality of Medical Information Act, clinical trial data, or other qualifying research data;
  • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act, the Gramm-Leach-Bliley Act or California Financial Information Privacy Act, and the Driver's Privacy Protection Act of 1994.

In particular, we have collected the following categories of CAPersonal Information from consumers within the last twelve (12)months:

We obtain, use, disclose and share the categories of CA PersonalInformation listed above as described elsewhere in this policy.

Sharing CA Personal Information

In the preceding twelve (12) months, Company has disclosed CAPersonal Information for a business purpose to the categories ofthird parties indicated in the chart below.

We do not sell CA Personal Information. In the preceding twelve(12) months, Company has not sold CA Personal Information to thecategories of third parties indicated in the chart below. For more onyour CA Personal Information sale rights, see below under heading “CAPersonal Information Sales Opt-Out and Opt-In Rights.”

CA Personal Information Category

Business Purpose Disclosure

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Your Rights and Choices

The CCPA provides consumers (California residents) with specificrights regarding their CA Personal Information. This sectiondescribes CCPA rights of California residents and explains how toexercise those rights.

Right to Know and Data Portability

You have the right to requestthat we disclose certain information to you about our collection anduse of your CA Personal Information over the past 12 months (the"right to know").Once we receive your request and confirm your identity (see belowunder the heading “Exercising Your Rights to Know or Delete”), wewill disclose to you:

• The categories of CA Personal Information we collected about you.
• The categories of sources for the CA Personal Information we collected about you.
• Our business or commercial purpose for collecting or selling that CA Personal Information.
• The categories of third parties with whom we share that CA Personal Information.
• If we sold or disclosed your CA Personal Information for a business purpose, two separate lists disclosing:
  • sales, identifying the CA Personal Information categories that each category of recipient purchased; and
  • disclosures for a business purpose, identifying the CA Personal Information categories that each category of recipient obtained.
• The specific pieces of CA Personal Information we collected about you (also called a data portability request).

We do not provide a right to know or data portability disclosurefor B2B personal information.

Right to Delete

You have the right to requestthat we delete any of your CA Personal Information that we collectedfrom you and retained, subject to certain exceptions (the "rightto delete"). Oncewe receive your request and confirm your identity (see below underthe heading “Exercising Your Rights to Know or Delete”), we willreview your request to see if an exception allowing us to retain theinformation applies. We may deny your deletion request if retainingthe information is necessary for us or our service provider(s) to:

1. Complete the transaction for which we collected the CA Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
8. Comply with a legal obligation.
9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

We will delete or deidentify personal information not subject toone of these exceptions from our records and will direct our serviceproviders to take similar action.

We do not provide these deletion rights for B2B personalinformation.

Exercising Your Rights to Know or Delete

To exercise your rights to know or delete described above, pleasesubmit a request:

• Emailing us at [●].

Only you, or someone legally authorized to act on your behalf, maymake a request to know or delete related to your CA PersonalInformation.

You may only submit a request to know twice within a 12-monthperiod. Your request to know or delete must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected CA Personal Information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with CA PersonalInformation if we cannot verify your identity or authority to makethe request and confirm the CA Personal Information relates to you.

You do not need to create an account with us to submit a requestto know or delete. We will only use CA Personal Information providedin the request to verify the requestor's identity or authority tomake it.

For instructions on exercising your sale opt-out or opt-in rights,see below under the heading “CA Personal Information Sales Opt-Outand Opt-In Rights.”

Response Timing and Format

We will confirm receipt of your request within ten (10) businessdays. If you do not receive confirmation within the 10-day timeframe,please contact [●].

We endeavor to substantively respond to a verifiable consumerrequest within forty-five (45) days of its receipt. If we requiremore time (up to another 45 days), we will inform you of the reasonand extension period in writing.

If you have an account with us, we will deliver our writtenresponse to that account. If you do not have an account with us, wewill deliver our written response by mail or electronically, at youroption.

Any disclosures we provide will only cover the 12-month periodpreceding our receipt of your request. The response we provide willalso explain the reasons we cannot comply with a request, ifapplicable. For data portability requests, we will select a format toprovide your CA Personal Information that is readily useable andshould allow you to transmit the information from one entity toanother entity without hindrance.

We do not charge a fee to process or respond to your verifiableconsumer request unless it is excessive, repetitive, or manifestlyunfounded. If we determine that the request warrants a fee, we willtell you why we made that decision and provide you with a costestimate before completing your request.

CA Personal Information Sales Opt-Out and Opt-In Rights

We do not sell the CA Personal Information of consumers. You donot need to take any action to Opt Out of sales of CA PersonalInformation.

Non-Discrimination

We will not discriminate against you for exercising any of yourCCPA rights. Unless permitted by the CCPA, 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.

However, we may offer you certain financial incentives permittedby the CCPA that can result in different prices, rates, or qualitylevels. Any CCPA-permitted financial incentive we offer willreasonably relate to your CA Personal Information value and containwritten terms that describe the program's material aspects.Participation in a financial incentive program requires your prioropt-in consent, which you may revoke at any time.

Other California Privacy Rights

California's "Shine the Light" law (Civil Code Section §1798.83) permits users of our Website that are California residentsto request certain information regarding our disclosure of personalinformation to third parties for their direct marketing purposes. Tomake such a request, please send an email to [●].

EU Data Rights

The information provided inthis section applies only to individuals in the European EconomicArea, United Kingdom, and Switzerland (collectively, “Europe”)and explains our practices regarding personal information that wecollect from you or which we have obtained about you from a thirdparty and the legal basis for processing for your personalinformation. It also sets out your rights in respect of ourprocessing of your personal information.

EU Personal Information.References to “EUPersonal Information”in this EU Data Rights section are equivalent to “personaldata” governed bythe General Data Protection Regulation.

Controller or Processor.We may be either the controller or processor of your EU PersonalInformation covered by this Privacy Policy, as stated under theheading “Information We Get From Others.”

Data protection officer.Our data protection officer can be contacted at:

SPV dot Co. 

[●]
Email: [●]

Legal basis for processing.The legal bases of our processing of your EU Personal Informationwill depend on the type of EU Personal Information and the specificcontext in which we process it. However, the legal bases we typicallyrely on are set out in the table below. We use your EU PersonalInformation only as permitted by law.

Use for new purposes.We may use your EU Personal Information for reasons not described inthis Privacy Policy where permitted by law and the reason iscompatible with the purpose for which we collected it. If we need touse your personal information for an unrelated purpose, we willnotify you and provide the applicable legal basis.

Sensitive personalinformation. If youprovide us with any sensitive EU Personal Information to us when youuse the Website, you must consent to our processing and use of suchsensitive EU Personal Information in accordance with this PrivacyPolicy. If you do not consent to our processing and use of suchsensitive EU Personal Information, you must not submit such sensitiveEU Personal Information through our Services.

Your rights.You have the following rights in relation to the EU PersonalInformation we hold about you:

• Right of access: You can ask us if we are processing your EU Personal Information and to provide you with a copy of it (along with certain details). If you require additional copies, we may need to charge a reasonable fee.
• Right to rectification: If the EU Personal Information we hold about you is inaccurate or incomplete, you are entitled to request to have it rectified.
• Right to erasure: You can ask us to delete or remove your EU Personal Information in some circumstances such as where we no longer need it or if you withdraw your consent to our processing of your EU Personal Information (where applicable).
• Right to restrict processing: You can ask us to “block” or suppress the processing of your EU Personal Information in certain circumstances, such as where you contest the accuracy of that EU Personal Information.
• Right to data portability: You have the right, in certain circumstances, to obtain EU Personal Information you have provided us with (in a structured, commonly used and machine readable format) and to reuse it elsewhere or to ask us to transfer this to a third party of your choice.
• Right to object: You can ask us to stop processing your EU Personal Information, and we will do so, if we are:
  • relying on our own or someone else’s legitimate interests to process your EU Personal Information, unless we can demonstrate compelling legal grounds for the processing; or
  • processing your EU Personal Information for direct marketing purposes.
• Right to withdraw consent: If we rely on your consent (or explicit consent) as our legal basis for processing your EU Personal Information, you have the right to withdraw that consent at any time.
• Right to lodge a complaint with the supervisory authority: If you have a concern about any aspect of our privacy practices, including the way we have handled your personal information, you can report it to the relevant Supervisory Authority.

You may submit these requests by email to [●]. We may requestspecific information from you to help us confirm your identity andprocess your request. Applicable law may require or permit us todecline your request. If we decline your request, we will tell youwhy, subject to legal restrictions.

Cross-border data transfer.If we transfer your EU Personal Information out of Europe to acountry not deemed to provide an adequate level of personalinformation protection for purposes of applicable data protectionlaws such that additional safeguards are required, the transfer willbe performed:

• pursuant to the recipient’s compliance with Standard Contractual Clauses;
• pursuant to the consent of the individual to whom the EU Personal Information pertains; or
• as otherwise permitted by applicable laws.

You may contact us if you want further information on the specificmechanism used by us when transferring your EU Personal Informationout of Europe.

Data Security

We have implemented measures designed to secure your personalinformation from accidental loss and from unauthorized access, use,alteration, and disclosure. All information you provide to us isstored on secure servers behind firewalls. Any personal information,including any financial transactions, will be encrypted either by usor by our privacy security provider. We have retained a third-partyprivacy security provider, to securely store your financial andcertain non-public personal information. Our access to informationstored with our privacy security provider is limited to display-onlyand never stored locally.

The safety and security of your information also depends on you.Where we have given you (or where you have chosen) a password foraccess to certain parts of our Website, you are responsible forkeeping this password confidential. We ask you not to share yourpassword with anyone.

Unfortunately, the transmission of information via the internet isnot 100% secure. Although we do our best to protect your personalinformation, we cannot guarantee the security of your personalinformation transmitted to our Website. Any transmission of personalinformation is at your own risk. We are not responsible forcircumvention of any privacy settings or security measures containedon the Website.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policyon this page. If we make material changes to how we treat our users'personal information, we will notify you by email to the primaryemail address specified in your account or through a notice on theWebsite home page. The date the privacy policy was last revised isidentified at the top of the page. You are responsible for ensuringwe have an up-to-date active and deliverable email address for you,and for periodically visiting our Website and this privacy policy tocheck for any changes.

Contact Information

To ask questions or comment about this privacy policy and ourprivacy practices, contact us at:

Email: support@spv.com

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