Tensai Holding Company, LLC (“Tensai Holding Co.,” “we,” “us,” or “our”) takes our clients’ and investors’ privacy seriously.
This Privacy Notice describes how we collect, share, and protect personal information in accordance with applicable regulations, including those of the U.S. Securities and Exchange Commission and relevant international data protection laws.
1. Overview
We do not disclose nonpublic personal information about past, current, or prospective clients or investors without prior authorization, except as permitted or required by law and as described below.
2. Personal Information We Collect
We may collect personal information about you in connection with providing advisory services. This information can include, but is not limited to:
- Social Security Number or national identification number
- Contact details (name, address, email, phone number)
- Assets and income
- Investment experience and transaction history
- Bank account information and wire transfer instructions
3. How We Collect This Information
We collect personal information through various means, such as when you:
- Provide us with contact details or documentation
- Enter into an advisory or subscription agreement
- Purchase securities or interests in funds
- Specify payment or transfer instructions
We may also receive information from affiliates or third-party sources (e.g., administrators, brokers, or financial institutions) as part of normal business operations.
4. How We Use This Information
We use personal information to conduct our ordinary business activities, including:
- Providing advisory and investment management services
- Opening and maintaining accounts
- Processing transactions and distributions
- Complying with legal or regulatory obligations
- Responding to lawful requests from authorities
- Communicating with clients and investors
We may also use limited data for marketing our services consistent with applicable law.
5. Disclosure to Others
We may share personal information with:
- Affiliates involved in servicing your account
- Service providers (such as fund administrators, auditors, brokers, and IT providers)
- Regulatory and governmental authorities as required by law
All third parties are required to maintain confidentiality and use the information solely for the intended purposes.
These practices are consistent with federal and international privacy laws. You generally cannot limit these necessary disclosures.
6. How We Protect Personal Information
We implement security measures that comply with federal and international standards, including:
- Secure electronic systems and encryption protocols
- Restricted access to authorized personnel
- Physical safeguards for offices and files
7. International Privacy Notice — Cayman Islands, European Union, and United Kingdom
The Cayman Islands Data Protection Law (2017), the EU General Data Protection Regulation (EU GDPR), and the UK GDPR (as enacted under the Data Protection Act 2018) apply to certain investors and funds managed by Tensai Holding Co. (collectively, the “Applicable Data Protection Laws”).
We and our affiliates may process the following types of personal data in connection with investment or advisory services:
Personal Data Provided by You:
Name, address, contact details, date of birth, nationality, tax identification, financial information, bank and brokerage details, investment experience, and related documents.
Personal Data Collected or Generated by Us:
Records of correspondence, call recordings, subscription documents, and website interaction data.
Personal Data Obtained from Other Sources:
Information obtained through AML/KYC checks, public records, or professional intermediaries.
8. How We Use Personal Data (Cayman, EU, UK)
We process personal data for the following purposes:
- Performance of a Contract: Subscription processing, investor servicing, and reporting.
- Compliance with Legal Obligations: AML/CTF screening, FATCA and CRS reporting, and tax compliance.
- Legitimate Interests: Managing fund operations, ensuring compliance, and maintaining communications.
9. Recipients and International Transfers
Personal data may be shared with:
- Affiliates and service providers involved in fund administration
- Auditors, legal advisors, and IT providers
- Competent authorities as required by law
Due to our international operations, your personal data may be transferred to jurisdictions without equivalent data protection laws. We take appropriate safeguards to ensure ongoing protection and confidentiality.
10. Data Security and Retention
We employ technical and organizational measures to protect data against unauthorized access, loss, destruction, or misuse.
Retention periods vary depending on legal obligations and the purpose of processing.
11. Your Data Rights (EU, UK, Cayman)
You may have the right to:
- Access personal data held about you
- Request correction or deletion of inaccurate data
- Object to or restrict processing in certain cases
- Lodge a complaint with a data protection authority.
For EU/UK residents, visit ico.org.uk for the UK Information Commissioner’s Office.
For Cayman Islands residents, visit ombudsman.ky.
12. Contact Information
If you have questions about this Privacy Policy or wish to exercise your data rights, please contact:
privacy@tensai-holding.com
13. Governing Law
This Privacy Policy and any dispute arising out of or relating to it shall be governed by and construed in accordance with the laws of the State of Delaware, without regard to its conflict of law principles.
14. Effective Date
This Privacy Policy is effective as of December 2025 and may be updated periodically.
The latest version will always be available at www.tensai-holding.com/privacy-policy.