How Cotra collects and handles personal information.

Scope

This policy applies to information collected through TheCotra.com, the Cotra LP Portal, investor diligence processes, and email or telephone communications with the firm.

Information we collect

We collect personal information you provide directly (name, firm, role, contact details, investor category, KYC/AML documentation) and technical information related to your use of our website (IP address, device and browser type, pages accessed, referring URLs).

How we use information

• To evaluate investor eligibility and complete subscription documentation
• To communicate about fund activity, reports, and firm materials
• To operate the LP Portal and secure diligence exchange
• To meet legal, regulatory, and audit obligations
• To detect and prevent fraud or unauthorized access

How we share information

We share information with fund administrators, auditors (PwC), legal counsel (LePore Law Group), custodians, banks, and technology service providers, in each case subject to confidentiality obligations. We do not sell personal information.

Data security

We maintain administrative, technical, and physical safeguards designed to protect personal information. Access to the LP Portal is credentialed, logged, and reviewed by the Compliance function.

Retention

We retain personal information for the periods required by applicable law, our regulatory obligations, and the ongoing servicing of our fund relationships.

Your rights

Depending on your jurisdiction, you may have rights to access, correct, delete, or restrict processing of your personal information. Requests should be directed to [email protected].

Cookies and analytics

We use functional and analytics cookies to operate the website and understand usage patterns. You can manage cookies through your browser settings.

Regulation S-P and Regulation S-ID

Cotra maintains policies and procedures reasonably designed to comply with SEC Regulation S-P (Privacy) and Regulation S-ID (Identity Theft Red Flags), including access controls, incident response, and vendor oversight.

Contact

Privacy inquiries: [email protected].