Privacy Policy

1. Introduction

Quant Lucid Capital Management ("Quant Lucid," "we," "us," or "our") is committed to protecting the privacy and security of your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website or engage with our services.

2. Information We Collect

2.1 Personal Information

We may collect personally identifiable information that you voluntarily provide to us, including but not limited to:

• Name, email address, phone number
• Physical address and business information
• Financial information and investment history (for accredited investor verification)
• Government-issued identification (as required by KYC/AML regulations)
• Tax identification numbers (for investors)

2.2 Automatic Information Collection

When you visit our website, we automatically collect certain information about your device, including:

• IP address and location data
• Browser type and version
• Pages visited and time spent on pages
• Referring website addresses
• Cookies and similar tracking technologies

3. How We Use Your Information

We use the information we collect to:

• Process and manage investment subscriptions
• Verify accredited investor status as required by SEC regulations
• Comply with KYC (Know Your Customer) and AML (Anti-Money Laundering) requirements
• Communicate with investors about fund performance and updates
• Send quarterly investor letters and annual tax documents
• Improve our website and services
• Respond to inquiries and provide customer support
• Comply with legal obligations and regulatory requirements

4. Information Sharing and Disclosure

We may share your information with:

• Service Providers: Third-party administrators (Allocations.com), custodians (Tradier), auditors, and legal counsel who assist in operating our fund
• Regulatory Bodies: SEC, FINRA, state securities regulators as required by law
• Legal Requirements: When required by subpoena, court order, or other legal process
• Business Transfers: In connection with any merger, sale, or transfer of fund assets

We do not sell your personal information to third parties.

5. Data Security

We implement industry-standard security measures to protect your personal information, including:

• Encryption of sensitive data in transit and at rest (SSL/TLS)
• Secure data centers with access controls
• Regular security audits and penetration testing
• Employee training on data protection and confidentiality
• Multi-factor authentication for account access

However, no method of transmission over the internet is 100% secure. While we strive to protect your personal information, we cannot guarantee absolute security.

6. Data Retention

We retain your personal information for as long as necessary to fulfill the purposes outlined in this policy, comply with legal obligations, resolve disputes, and enforce our agreements. Investment records are retained for a minimum of seven years as required by securities regulations.

7. Your Rights

Depending on your jurisdiction, you may have the following rights:

• Access: Request a copy of the personal information we hold about you
• Correction: Request correction of inaccurate or incomplete information
• Deletion: Request deletion of your personal information (subject to legal retention requirements)
• Opt-Out: Unsubscribe from marketing communications
• Data Portability: Request transfer of your data to another service provider

To exercise these rights, please contact us at privacy@quantlucid.com

8. Cookies and Tracking Technologies

We use cookies and similar technologies to enhance your browsing experience. You can control cookie settings through your browser preferences. Note that disabling cookies may limit certain website functionality.

Types of cookies we use:

• Essential cookies (required for website operation)
• Analytics cookies (Google Analytics for website performance)
• Functional cookies (remember your preferences)

9. Third-Party Links

Our website may contain links to third-party websites, including our fund administrator (Allocations.com) and custodian (Tradier). We are not responsible for the privacy practices of these third parties. We encourage you to review their privacy policies.

10. International Data Transfers

Your information may be transferred to and processed in the United States and other countries where our service providers operate. By using our services, you consent to the transfer of your information to countries that may have different data protection laws than your country of residence.

11. Children's Privacy

Our services are not directed to individuals under the age of 18. We do not knowingly collect personal information from children. If you believe we have collected information from a child, please contact us immediately.

12. California Privacy Rights (CCPA)

California residents have additional rights under the California Consumer Privacy Act (CCPA):

• Right to know what personal information is collected
• Right to know whether personal information is sold or disclosed
• Right to opt-out of the sale of personal information
• Right to deletion of personal information
• Right to non-discrimination for exercising CCPA rights

We do not sell personal information.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by posting the updated policy on our website with a new "Last Updated" date. Your continued use of our services after changes constitutes acceptance of the updated policy.

14. Contact Us

If you have questions or concerns about this Privacy Policy or our data practices, please contact us:

Quant Lucid Capital Management
Email: privacy@quantlucid.com
Subject Line: Privacy Inquiry

15. Regulatory Compliance

Quant Lucid is committed to compliance with:

• Securities Act of 1933 and Securities Exchange Act of 1934
• Investment Advisers Act of 1940
• Bank Secrecy Act and USA PATRIOT Act (AML/KYC)
• Regulation D (506(c)) for accredited investor verification
• State securities regulations (Blue Sky Laws)

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