Privacy Policy

Tensai Holding Company, LLC (“Tensai Holding Co.,” “we,” “us,” or “our”) is committed to protecting the privacy and confidentiality of personal information entrusted to us.

This Privacy Notice describes how we collect, use, disclose, and protect personal information in accordance with applicable privacy and data protection laws.

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1. Overview

We treat nonpublic personal information as confidential and disclose it only as described in this Privacy Notice or as otherwise permitted or required by applicable law.

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2. Personal Information We Collect

We may collect personal information in connection with our investment activities, strategic relationships, transactions, and ordinary business operations. Depending on the nature of the relationship, this information may include:

• Social Security numbers or other national identification numbers
• Contact details, including name, address, email address, and telephone number
• Financial information, including assets and income
• Investment experience and transaction history
• Bank account details and payment instructions
• Professional information and relevant identification documentation
• Correspondence and other information provided in the course of our activities

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3. How We Collect This Information

We may collect personal information directly from you when you:

• Provide contact details or documentation
• Enter into an investment, contractual, or other professional relationship with us
• Participate in investment activities or transactions
• Provide payment or transfer instructions
• Communicate with us through our website or other authorized channels

We may also obtain information from affiliates, professional intermediaries, financial institutions, service providers, public records, or other relevant third parties in connection with our business activities.

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4. How We Use This Information

We use personal information in connection with our investment activities, professional relationships, and ordinary business operations, including:

• Evaluating, executing, and administering investments and transactions
• Establishing and maintaining investment and professional relationships
• Opening and maintaining accounts, where applicable
• Processing payments, transfers, and distributions
• Conducting due diligence and relevant verification procedures
• Complying with applicable legal and regulatory obligations
• Responding to lawful requests from competent authorities
• Communicating with relevant individuals and counterparties
• Maintaining the security and integrity of our operations

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5. Disclosure to Others

We may disclose personal information, where appropriate and in accordance with applicable law, to:

• Affiliates involved in our investment activities and business operations
• Professional advisers and service providers, including administrators, auditors, legal advisers, brokers, and technology providers
• Financial institutions and counterparties involved in relevant transactions
• Regulatory, judicial, and governmental authorities, where required or permitted by law

We take appropriate steps to ensure that service providers handling personal information on our behalf maintain confidentiality and suitable data protection safeguards.

Such disclosures are subject to applicable legal requirements and individual data protection rights.

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6. How We Protect Personal Information

We maintain technical, administrative, and physical safeguards designed to protect personal information against unauthorized access, disclosure, alteration, loss, or misuse.

These measures may include:

• Secure electronic systems and appropriate encryption protocols
• Restricted access to authorized personnel
• Physical safeguards for offices, records, and documentation
• Internal procedures governing the handling of confidential information

Our safeguards are reviewed and adapted as appropriate to the nature and sensitivity of the information processed.

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7. International Privacy Notice — Cayman Islands, European Union, and United Kingdom

Depending on the circumstances and nature of our activities, the Cayman Islands Data Protection Act, the European Union General Data Protection Regulation (EU GDPR), and the United Kingdom General Data Protection Regulation (UK GDPR) may apply to certain processing of personal information.

Where applicable, we and our affiliates may process the following categories of personal data in connection with our investment activities, professional relationships, and business operations:

• Personal Data Provided by You: Name, address, contact information, date of birth, nationality, tax identification details, financial information, banking and brokerage information, investment experience, and relevant documentation.
• Personal Data Collected or Generated by Us: Records of correspondence, transaction documentation, contractual records, communications, and website interaction information, where collected.
• Personal Data Obtained from Other Sources: Information obtained through identification and verification procedures, anti-money laundering and know-your-customer checks, public records, financial institutions, or professional intermediaries.

The collection and processing of such information depend on the nature of the relevant activity and applicable legal requirements.

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8. How We Use Personal Data (Cayman Islands, EU, UK)

Where applicable data protection laws require a lawful basis for processing, we process personal data on one or more of the following grounds:

• Performance of a Contract: Establishing, administering, and fulfilling contractual or investment-related relationships.
• Compliance with Legal Obligations: Meeting applicable regulatory, financial reporting, tax, anti-money laundering, and other legal requirements.
• Legitimate Interests: Conducting investment activities, managing business operations, maintaining professional relationships, protecting our interests, and ensuring operational security, subject to applicable individual rights.
• Consent: Processing personal data for specific purposes where consent is required or otherwise relied upon under applicable law.

We may also process personal information where necessary for the establishment, exercise, or defense of legal claims, subject to applicable legal requirements.

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9. Recipients and International Transfers

In connection with our international activities, personal information may be disclosed to relevant affiliates, professional advisers, financial institutions, service providers, counterparties, and competent authorities.

Personal information may be processed or transferred across jurisdictions, including jurisdictions with different data protection standards.

Where required by applicable law, we implement appropriate safeguards or rely on other legally recognized mechanisms to protect personal information transferred internationally.

Further information concerning applicable transfer safeguards may be requested using the contact details provided below.

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10. Data Security and Retention

We maintain appropriate technical and organizational measures designed to protect personal information against unauthorized access, disclosure, alteration, destruction, or loss.

Personal information is retained for as long as reasonably necessary to fulfill the purposes for which it was collected, including applicable contractual, operational, legal, regulatory, and recordkeeping requirements.

Retention periods are determined by the nature of the information, the relevant business relationship, applicable legal obligations, and any legitimate need to establish, exercise, or defend legal claims.

When personal information is no longer required, we take appropriate steps to delete, anonymize, or securely dispose of it, subject to applicable requirements.

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11. Your Data Rights (EU, UK, Cayman Islands)

Depending on your jurisdiction and the applicable data protection laws, you may have rights concerning your personal information, including the right to:

• Request access to personal information held about you
• Request the correction of inaccurate or incomplete information
• Request the deletion of personal information in certain circumstances
• Object to or request restrictions on certain processing activities
• Request the portability of personal information, where applicable
• Withdraw consent where processing is based on consent
• Lodge a complaint with an appropriate data protection authority

These rights are subject to applicable legal conditions, limitations, and exemptions.

For information about relevant data protection authorities:

• United Kingdom: Information Commissioner's Office — www.ico.org.uk
• Cayman Islands: Office of the Ombudsman — www.ombudsman.ky
• European Union: The competent supervisory authority in the relevant EU member state

Additional privacy rights may apply under other relevant jurisdictions.

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12. Contact Information

If you have questions concerning this Privacy Notice or wish to exercise applicable data protection rights, please contact:

Tensai Holding Company, LLC

privacy@tensai-holding.com

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13. Changes to This Privacy Notice

We may update this Privacy Notice periodically to reflect changes in our activities, operational practices, or applicable legal and regulatory requirements.

Any updated version will be published on our official website. Material changes will be communicated where required by applicable law.

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14. Effective Date

This Privacy Notice is effective as of September 1, 2026.

The latest version will be available at:

www.tensai-holding.com/privacy-policy

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