Privacy Policy
Last Updated: December 2, 2025
Pan Capital (“Pan Capital,” “we,” “us,” or “our”) is committed to protecting the privacy, confidentiality, and security of personal information. This Privacy Policy describes how we collect, use, protect, and disclose information obtained through this website (the “Site”). It also outlines how we handle information relating to current and prospective investors in our managed funds and accounts.
This Privacy Policy applies solely to information collected through the Site.
Privacy practices applicable to investors in Pan Capital-managed funds or accounts are separately described in the applicable private placement memoranda, subscription agreements, and investor privacy notices delivered to those investors pursuant to Regulation S-P, CFTC Regulation 160, and other applicable laws.
1. Information We Collect Through the Site
We may collect the following categories of information when you visit or interact with the Site:
1.1. Information You Provide Voluntarily
When you submit information through a contact form or request materials, we may collect:
Name
Email address
Company or professional affiliation
Any other information you choose to provide
This information is used solely to respond to your inquiry or to provide requested information.
1.2. Information Collected Automatically
We may collect limited technical information about your visit, including:
IP address
Browser type and version
Device identifiers
Pages visited and referring sources
Time and duration of visits
We may also use third-party platforms to support investor communications, event registration, and secure document sharing, which may collect limited engagement data subject to contractual confidentiality and applicable privacy laws.
We use this information to maintain the performance, security, and usability of the Site.
We do not sell personal information or use cookies for targeted advertising. Certain third-party service providers may categorize cookies under standard advertising or analytics frameworks.
Cookie preferences may be managed through the cookie banner presented upon visiting the Site.
2. Information We Do Not Collect Through the Site
Pan Capital does not collect, request, or process:
Social Security numbers
Financial account numbers
Passport or government identification numbers
Non-public personal financial information
Subscription documents or investor onboarding information
Any such information is handled through secure channels subject to applicable privacy frameworks.
3. How We Use Information
We may use information collected through the Site to:
Respond to inquiries and provide requested information
Operate, maintain, and improve the Site
Ensure cybersecurity and detect fraudulent activity
Comply with applicable laws, regulations, or legal process
We do not sell personal information, share it for advertising purposes, or use it for automated decision-making.
4. Disclosure of Information
We may disclose information collected through the Site only to:
Service providers that assist in operating the Site (e.g., hosting, email services)
Regulators or legal authorities, if required by law
Professional advisors (e.g., counsel or compliance consultants), where appropriate
We do not sell or disclose personal information to third parties for marketing or commercial purposes.
5. Investor Privacy
For current or prospective investors in Pan Capital-managed funds or accounts:
We are required under Regulation S-P (SEC) and CFTC Regulation 160 to protect non-public personal information (“NPPI”).
NPPI is collected only through subscription agreements, investor questionnaires, and related documentation—not through this Site.
Detailed investor privacy practices are included in fund offering documents and the investor privacy notices delivered to investors as required under applicable law.
If you are an investor, please refer to those documents for complete information.
6. Data Security
We maintain commercially reasonable physical, technical, and administrative safeguards designed to:
Protect information from unauthorized access
Ensure confidentiality and integrity
Prevent accidental loss or misuse
No method of electronic transmission or storage is completely secure, and we cannot guarantee absolute security.
7. Data Retention
We retain information collected through the Site only for as long as necessary to:
Fulfill the purposes described in this Policy
Comply with legal and regulatory obligations
Maintain appropriate business records
Information that is no longer required is securely deleted or anonymized.
8. Your Rights and Choices
Depending on your jurisdiction, you may have certain rights regarding your personal information, including:
Access
Correction
Deletion
Restriction of processing
Objection to processing
To exercise these rights, please contact us at the email below.
We may need to verify your identity before responding.
9. International Users and Jurisdiction-Specific Rights
Pan Capital is an institutional investment manager that may communicate with investors and prospective investors globally, including in the United States, the United Kingdom, the European Union, Switzerland, Hong Kong, Singapore, and other jurisdictions.
If you access the Site from outside the United States, your information may be transferred to and processed in the United States or other jurisdictions where Pan Capital or its service providers operate. Privacy laws in those jurisdictions may differ from the laws of your country of residence.
Depending on your jurisdiction, additional privacy rights may apply, as described below.
9.1 European Economic Area, United Kingdom, and Switzerland
If you are located in the EEA, UK, or Switzerland, Pan Capital processes personal information in accordance with applicable data protection laws, including the GDPR and UK GDPR. You may have rights to:
Access and obtain a copy of your personal information
Request correction or deletion
Object to certain processing
Request restrictions on processing
Lodge a complaint with a supervisory authority
Where required, Pan Capital relies on lawful bases such as legitimate interests, contractual necessity, or consent.
9.2 United States (California and Other States)
Certain U.S. state privacy laws (including California) may provide residents with rights regarding personal information, including:
The right to know what categories of information are collected
The right to request deletion, subject to legal exceptions
The right to opt out of certain data sharing
Pan Capital does not sell personal information.
9.3 Asia-Pacific Jurisdictions
Where applicable, Pan Capital will comply with privacy and data protection laws in jurisdictions in which it operates or markets to institutional investors, including Hong Kong and Singapore.
10. Children’s Privacy
The Site is not directed to—and we do not knowingly collect personal information from—children under 13 years of age.
11. Third-Party Websites
The Site may contain links to third-party websites.
We are not responsible for the privacy practices or content of those websites and encourage you to review their privacy policies separately.
12. Changes to This Privacy Policy
We may update this Privacy Policy from time to time.
Any changes will be posted on the Site with an updated “Last Updated” date, and such changes become effective when posted.
13. Contact Us
If you have any questions about this Privacy Policy or our privacy practices, please contact us at: