Privacy Policy

Chayne Global Management LLC  ·  Effective Date: March 31, 2026

Introduction

Chayne Global Management LLC ("Chayne," "we," "us," or "our") is committed to protecting the privacy and security of the personal information of our website visitors, prospective investors, and fund investors. This Privacy Policy describes how we collect, use, disclose, and safeguard your information when you visit chayne.com and any related services or engage with our investment management services.

Information We Collect

Information You Provide

  • Contact Information: name, email, phone, mailing address
  • Identity Verification Information: government-issued ID, SSN/TIN, date of birth — collected through our identity verification provider Persona for identity verification and KYC/AML compliance
  • Investment Information: accredited investor status, investment amounts, subscription documents, investor questionnaires
  • Business Information for entity investors: entity name, formation documents, beneficial ownership information
  • Blockchain and Digital Asset Information: Public wallet addresses, transaction history, token holdings, and on-chain settlement records associated with your investment. This data may be recorded on public blockchain networks and cannot be modified or deleted. Blockchain data is publicly visible and persists even after account termination. We recommend carefully considering what information you submit for on-chain recording.

Information Collected Automatically

  • Usage Data: IP address, browser type, operating system, pages visited, time/date of visits, referring URLs
  • Cookies and similar tracking technologies used to operate the Site, analyze usage, and improve functionality. Where required by applicable law, we will seek your consent before using non-essential cookies. You can manage cookies through your browser settings, although disabling certain cookies may affect Site functionality.

How We Use Your Information

  • Investor Onboarding: identity verification, accredited investor confirmation, subscription processing under SEC Reg D 506(c) and AML requirements
  • Fund Administration: investor accounts, NAV calculation, investor statements, K-1 tax coordination
  • Communications: inquiries, investment updates, quarterly statements, Fund notices
  • Compliance: applicable laws, SEC reporting, AML/KYC, tax reporting
  • Site Operations: operate, maintain, improve the Site

How We Share Your Information

We do not sell your personal information. We may share your information with the following service providers and other service providers acting on our behalf, solely for the purposes described in this Policy. These parties may process information in the United States and other jurisdictions where they operate, subject to appropriate contractual, technical, and organizational safeguards where required by law:

  • Identity Verification: Persona (withpersona.com) for identity verification and KYC/AML compliance
  • Wallet Infrastructure: DFNS for digital asset wallet infrastructure and key management
  • Fiat Settlement: Bridge (bridge.xyz) for fiat currency on-ramp and off-ramp processing
  • Blockchain Settlement: XDC Network for on-chain transaction settlement and record-keeping
  • Fund Administration: Independent third-party fund administrator for NAV verification and investor reporting
  • Tax and Audit: Independent tax preparer for K-1 preparation and GAAP auditor for annual fund audit
  • Legal Counsel: Securities counsel for regulatory compliance and offering document review
  • Regulatory Authorities: SEC, FinCEN, state regulators, or other governmental authorities as required by law or in response to valid legal process
  • Professional Advisors: Attorneys, accountants, and consultants as necessary for Fund operations
  • Email Delivery: Resend (resend.com) for transactional email delivery of inquiry notifications submitted through forms on the Site

Data Security

We implement appropriate technical and organizational measures to protect personal information including encryption, access controls, and regular security assessments of service providers.

Data Retention

We retain personal information as long as necessary to fulfill the purposes described in this Policy and comply with legal obligations. We retain investor and compliance records for at least the period required by applicable law and regulation, which in many cases is no less than five (5) years, and in some cases longer depending on the nature of the record, the date the record was created, and our legal, tax, regulatory, and operational needs.

Blockchain Data Permanence

Important Notice: Certain data associated with your investment may be permanently recorded on blockchain networks, including wallet addresses, transaction history, and token ownership records. This data is publicly visible on the blockchain and cannot be modified, deleted, or removed by Chayne or any third party. This limitation applies even if you terminate your investment in the Fund or request deletion of your personal information. Our ability to fulfill deletion requests is limited with respect to data recorded on public blockchain networks. If you have concerns about blockchain data permanence, please contact us before completing your subscription.

This section describes a technical limitation of blockchain infrastructure and does not limit any other rights you may have under applicable privacy law.

Your Rights

Depending on your jurisdiction, you may have rights regarding your personal information, including rights to access, correct, delete, or obtain information about our processing of your personal information, subject to applicable exceptions and regulatory recordkeeping obligations. You may also opt out of marketing communications at any time by following the unsubscribe instructions in those communications or by contacting us. We will respond to requests in accordance with applicable law.

California residents and certain residents of other U.S. states may have additional privacy rights under applicable law, subject to statutory exemptions and limitations. We do not sell personal information or share personal information for cross-context behavioral advertising as those terms are defined under applicable law.

Children's Privacy

Our services are not directed to individuals under 18. We do not knowingly collect personal information from children.

Third-Party Links

The Site may contain links to third-party websites. We are not responsible for their privacy practices.

Changes to This Policy

We may update this Privacy Policy from time to time. Changes will be posted with an updated effective date.

Contact

Chayne Global Management LLC
777 Brickell Avenue, Suite 500, Miami, FL 33131
Email: ir@chayne.com

Last updated: March 31, 2026