Privacy Policy and Notice

By sharing this Privacy Policy for Veracor Capital, a division of Veracor Group Holdings, LLC, and its affiliated entities and partners (collectively, "Veracor Capital," "we," "us," or "our"), we hope to help you understand how information is collected, used, and protected in connection with our investment management services, as well as to reassure you that we respect and honor requests to restrict and protect personal information.

This Statement of Privacy applies to Veracor Capital and all Veracor Group Holdings, LLC entities and affiliated partner companies. For the purposes of this Privacy Policy, unless otherwise noted, all references include veracorcapital.com, veracorgroup.com, kurehealth.com, and any related domains that have been created and are operated by Veracor Capital, Veracor Group Holdings, LLC, and its affiliated companies.

We will comply with our Canadian Privacy Policy in our communications with all customers who are Canadian residents. If you reside in the EU, please see "Your Rights Under EU Data Protection Laws" below. If you are a California resident, please see "California Residents" below.

Why We Collect Personal Information

Veracor Capital collects personal information to improve the manner by which we operate, offer our investment products and services, communicate with you about those products and services, and provide effective, timely investor support when needed.

As an investment management firm, we collect personal information for several additional purposes specific to our business:

• To verify your status as an accredited investor or qualified purchaser as required by SEC Regulation D and other applicable securities laws
• To comply with anti-money laundering (AML) and know-your-customer (KYC) requirements under the Bank Secrecy Act and USA PATRIOT Act
• To process subscription agreements and investment transactions
• To issue capital call notices and distribute investment returns
• To provide required investor communications, including Schedule K-1s and other tax documents
• To respond to regulatory inquiries and examinations by the SEC, FINRA, or state securities regulators
• To maintain accurate records as required by the Investment Advisers Act of 1940

We will never rent or sell any of the personal information we collect from you to third parties, including messaging consent and opt-in data, and we do not share your personal information except as set forth in this Privacy Policy or as required by law.

Categories of Personal Information We Collect

Veracor Capital collects personal information in a variety of ways when you interact with us, including when you:

• Register or create an investor account with Veracor Capital
• Submit a subscription agreement or other investment documentation
• Complete accredited investor verification or qualification documentation
• Make capital contributions or receive distributions
• Visit Veracor Capital pages or pages of our partners
• Request investor materials such as Private Placement Memoranda (PPMs)
• Subscribe to newsletters or request to be added to our mailing lists
• Correspond or otherwise interact with us
• Attend investor events or webinars
• Provide feedback in any of our online surveys

Identification Information

Name, email address, phone number, mailing address, date of birth, Social Security Number or Tax Identification Number (TIN), government-issued identification documents (driver's license, passport), and signature.

Financial Information

Income and net worth information for accredited investor verification; bank account information for capital contributions and distributions; investment preferences and risk tolerance; source of funds documentation; tax filing status; and employment information.

Investor Qualification Information

Documentation to verify accredited investor or qualified purchaser status, including tax returns, W-2 forms, bank statements, brokerage statements, professional license documentation (Series 7, 65, 82), verification letters from CPAs, attorneys, or registered investment advisers, and self-certification forms.

Investment Account Information

Fund interests held, capital account balances, capital call and distribution history, K-1 tax information, subscription and redemption records, and beneficial ownership information.

Technical and Usage Information

IP address, browser type, device information, pages visited, time spent on pages, and other analytics data when you visit our websites.

Communication Information

Records of correspondence with our investor relations team, including emails, phone calls, and meeting notes.

Investor Verification and Regulatory Compliance

Accredited Investor Verification

Under SEC Regulation D Rule 506(c), we are required to take "reasonable steps" to verify that each investor in our funds is an accredited investor. This may include collecting and reviewing:

• Tax returns, W-2 forms, or other documentation of income
• Bank statements, brokerage statements, or other documentation of assets
• Written confirmation from a registered broker-dealer, SEC-registered investment adviser, licensed attorney, or certified public accountant that they have taken reasonable steps to verify your accredited investor status within the prior three months
• Verification of professional certifications (Series 7, Series 65, or Series 82)

Anti-Money Laundering (AML) Compliance

We are committed to complying with all applicable anti-money laundering laws and regulations, including the Bank Secrecy Act and the USA PATRIOT Act. As part of our AML program, we may:

• Verify your identity using government-issued identification documents
• Conduct background checks and screen against government sanctions lists (OFAC)
• Request documentation regarding the source of investment funds
• Monitor transactions for suspicious activity
• File Suspicious Activity Reports (SARs) with FinCEN when required
• Retain records as required by the Bank Secrecy Act

Beneficial Ownership Information

For entity investors (corporations, LLCs, partnerships, trusts), we are required to collect beneficial ownership information to identify individuals who own 25% or more of the entity or who exercise significant control over the entity. This information is collected pursuant to FinCEN's Customer Due Diligence Rule.

ERISA and Plan Asset Considerations

If you are investing on behalf of an employee benefit plan subject to ERISA, we may collect additional information to ensure compliance with ERISA regulations and to determine whether our funds would be subject to the "plan asset" regulations.

How We Protect Your Personal Information

Veracor Capital safeguards the security of the data you send us with physical, electronic, and managerial procedures. We understand that as an investment firm, we hold particularly sensitive financial and personal information, and we take this responsibility seriously.

Security Measures

Our security program includes:

• Industry-standard Secure Sockets Layer (SSL) encryption for all data transmitted over the internet
• Encryption of sensitive data at rest, including Social Security Numbers, financial account information, and investor verification documents
• Multi-factor authentication for access to investor portals and sensitive systems
• Regular security assessments and penetration testing
• Access controls limiting employee access to personal information on a need-to-know basis
• Employee training on data security and privacy practices
• Physical security measures for our offices and data storage facilities
• Secure disposal of physical documents containing personal information

Regulation S-P Compliance

In accordance with SEC Regulation S-P (Privacy of Consumer Financial Information), we maintain written policies and procedures addressing administrative, technical, and physical safeguards for the protection of customer records and information. These safeguards are designed to:

• Ensure the security and confidentiality of customer records and information
• Protect against anticipated threats or hazards to the security or integrity of customer records and information
• Protect against unauthorized access to or use of customer records or information that could result in substantial harm or inconvenience to any customer

Your Responsibility

While Veracor Capital takes precautions to ensure the security of your data, no one can completely guarantee the safety of data transmitted over the internet. It is important that you take steps to ensure the safety and security of your personal information, for example by not sharing passwords or other registration data, using strong passwords, and keeping your contact information current.

Investor Portal Security

Our secure Investor Portal provides accredited investors with access to their capital account information, fund documents, and transaction history. Given the sensitive nature of this information, we have implemented enhanced security measures specific to the portal:

Authentication and Access Controls

• Email verification required before account activation
• Secure password requirements enforcing minimum complexity standards
• Session timeout after periods of inactivity to prevent unauthorized access on shared devices
• Automatic account lockout after multiple failed login attempts
• Role-based access controls ensuring investors can only view their own account information
• Secure password reset procedures with email verification

Banking and Wire Transfer Information

We take special precautions when handling banking information for capital calls and distributions:

• Wire transfer instructions are displayed only within authenticated portal sessions
• Banking account details are protected by Row Level Security, ensuring only authorized investors can access fund-specific wire instructions
• Partial masking of sensitive account numbers in confirmations and statements
• Capital call and distribution processing through verified banking relationships only
• All changes to banking information require verification through our investor relations team
• Wire fraud prevention protocols including callback verification for large transactions

Data Room and Document Security

• NDA acceptance required before accessing confidential fund materials
• Tiered access levels restricting sensitive documents to qualified investors
• Comprehensive audit logging of all document views and downloads
• Watermarking capabilities for highly confidential documents
• Engagement monitoring to detect unusual access patterns

Infrastructure Security

Our Investor Portal is built on enterprise-grade cloud infrastructure with the following protections:

• SOC 2 Type II certified hosting infrastructure
• Web Application Firewall (WAF) protection against common attack vectors
• Leaked credentials monitoring to detect login attempts using compromised passwords
• DDoS protection and rate limiting
• All data encrypted in transit (TLS 1.3) and at rest (AES-256)
• Geographic redundancy and automated backups
• Regular vulnerability scanning and security assessments

Data Breach Notification

In the unlikely event of a security incident affecting your personal or financial information, Veracor Capital is committed to transparent and timely notification:

• We will notify affected investors within 72 hours of confirming a breach that poses a risk of harm
• Notification will include a description of the incident, types of information potentially affected, and steps we are taking to address the situation
• We will provide guidance on protective measures you can take, such as monitoring financial accounts or placing fraud alerts
• Where required by state breach notification laws, we will notify relevant state attorneys general
• If the breach involves tax identification numbers or financial account information, we may offer complimentary credit monitoring services

Incident Response

Veracor Capital maintains a formal incident response plan that includes identification and containment procedures, forensic investigation protocols, regulatory notification requirements (including SEC Form ADV amendment if material), remediation steps, and post-incident review. Our team conducts regular tabletop exercises to ensure readiness.

How We Use Your Personal Information

Investment Services

• Processing subscription agreements and investor onboarding
• Verifying accredited investor or qualified purchaser status
• Conducting anti-money laundering and know-your-customer checks
• Processing capital contributions and distributions
• Issuing capital call notices and distribution notices
• Maintaining your investor account and capital account records
• Preparing and delivering Schedule K-1s and other tax documents
• Providing quarterly and annual investor reports

Communications

• Communicating with you concerning your investment account and investor service matters
• Providing you with fund updates, performance reports, and portfolio company news
• Inviting you to investor meetings, webinars, and events
• Sending newsletters, market commentary, and thought leadership content
• Notifying you of new investment opportunities

Compliance and Legal

• Complying with applicable laws, regulations, and legal processes
• Responding to regulatory examinations and inquiries from the SEC, FINRA, or state securities regulators
• Maintaining books and records as required by the Investment Advisers Act of 1940
• Preparing and filing required regulatory reports

Business Operations

• Improving our investment products and services
• Understanding how our websites and investor portals are used
• Providing anonymous or aggregated reporting for internal analysis

How and When We Disclose the Information We Collect

Service Providers

Veracor Capital may share your personal information with trusted vendors, service providers, and partners who work with us to provide investment management services. These may include:

• Fund administrators who maintain investor records and process capital transactions
• Transfer agents who maintain investor registries
• Accounting firms who prepare fund financial statements and tax documents
• Legal counsel who provide fund-related legal services
• Third-party accredited investor verification services
• Background check and AML screening providers
• Custodians and banks who hold fund assets
• Technology providers who support our investor portal and communications

These service providers are contractually required to keep personal information secure, to use it only for the purposes for which it is provided, and to comply with applicable privacy laws and regulations.

Affiliated Entities

We may share your information with Veracor Group Holdings, LLC and its affiliated entities, including Kure Health, KureCare, EliteMD, and other portfolio companies, for the purposes described in this Privacy Policy. These affiliates are bound by this Privacy Policy or have their own privacy policies that provide similar protections.

Regulatory Disclosures

Veracor Capital may disclose your personal information to regulatory authorities when required by law, including:

• The Securities and Exchange Commission (SEC)
• Financial Industry Regulatory Authority (FINRA)
• State securities regulators
• Financial Crimes Enforcement Network (FinCEN)
• Internal Revenue Service (IRS)
• Other governmental or regulatory bodies as required by law

Legal Requirements and Protection of Rights

Veracor Capital may also disclose your personal information if required to do so by law or in the good faith belief that such action is necessary to:

• Comply with law or legal process or if requested by duly authorized public authorities
• Comply with the order of a competent judicial authority in any jurisdiction
• Comply with legal process served on Veracor Capital
• Protect and defend the rights or property of Veracor Capital, Veracor Group Holdings, LLC, or our affiliated companies, their employees, and agents
• Enforce our terms of use, subscription agreements, or other agreements
• Protect against fraud, money laundering, or other illegal activity, or for risk management purposes
• Permit us to pursue available remedies or limit the damages that we may sustain
• Act in urgent circumstances to protect the personal safety of users of Veracor Capital products or the public at large

Business Transactions

If Veracor Capital or Veracor Group Holdings, LLC should ever file for bankruptcy, become insolvent, be acquired by a third party, merge with a third party, sell all or part of its assets, or transfer substantially all or part of its relevant assets to a third party, then Veracor Capital is entitled to share the personal information and all other information you have provided through our products and services to potential and subsequent business and merger partners, subject to confidentiality obligations.

Cookies and Tracking Technologies

Cookies and How We Use Them

Cookies are small data files that write to your hard drive for record-keeping purposes when you visit a website. Cookies allow Veracor Capital to measure traffic activity as well as to improve your user experience, for example by remembering your preferences and login status. Like other major financial services websites, Veracor Capital uses cookies to provide you with a tailored experience when visiting our websites and using our investor portal.

We treat any personal information that may be contained in cookies with the same level of confidentiality as other information you provide to us. If you wish to disable cookie functionality, you may do so by changing the security settings on your browser. However, portions of our websites may not function, or may not function as efficiently, without them.

Google and Adobe Analytics

We use tools called "Google Analytics" and "Adobe Analytics" to collect some information about your use of our websites and investor portal. We use the information we get from these analytics services to improve our services. We do not combine the information collected through the use of these analytics tools with personally identifiable investor information.

Social Media Widgets

Our websites may include social media features, such as the LinkedIn "Share" button or other interactive features. These features may collect your IP address, which page you are visiting, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our websites. Your interactions with these features are governed by the privacy statement of the companies that provide them.

Data Retention

Retention Periods

Veracor Capital retains personal information for as long as necessary to fulfill the purposes for which it was collected, to comply with our legal and regulatory obligations, and to protect our legal interests. Retention periods may include:

• Investment records: Maintained for the life of the fund plus a minimum of six years following fund termination, as required by the Investment Advisers Act of 1940
• Investor verification documents: Maintained for a minimum of five years following the termination of the investor relationship, as required by AML regulations
• Tax records and K-1 information: Maintained for a minimum of seven years as required by IRS regulations
• Communications records: Maintained for a minimum of five years as required by the Investment Advisers Act
• Marketing and prospective investor information: Maintained until you request deletion or for a reasonable period following our last communication with you

Account Deletion

If you are not currently an investor and wish to have your prospective investor information deleted, you may request deletion by contacting us at privacy@veracorcapital.com. Note that we may be required to retain certain information for regulatory compliance purposes even after you request deletion.

If you are a current or former investor, we are required by law to maintain certain records for the periods described above, even if you request deletion. We will delete or anonymize your information at the end of the applicable retention period.

Rights You Have Regarding Your Data

You always have the right to request information about your stored data, its origin, its recipients, and the purpose of its collection at no charge. You also have the right to request that it be corrected, blocked, or deleted, subject to our legal and regulatory obligations to retain certain information.

You can contact us at any time using the contact information below if you have further questions about the issue of privacy and data protection. Many data processing operations are only possible with your express consent. You may revoke your consent at any time with future effect. An informal email making this request is sufficient. The data processed before we receive your request may still be legally processed.

Opt-Out Rights

If you no longer wish to receive marketing communications from Veracor Capital, you can opt-out from receiving such messages in the future by:

• Following the unsubscribe instructions in any marketing email
• Contacting us at privacy@veracorcapital.com

Please note that even if you opt out of marketing communications, we may still send you transactional and regulatory communications related to your investments, including capital call notices, distribution notices, tax documents, and required investor disclosures.

Your Rights Under EU Data Protection Laws (GDPR)

If EU data protection laws apply to our processing of your information, you are entitled by law to access, correct, amend, or delete personal information about you that we hold. Your rights include:

• Right of access – the right to request a copy of the information that we hold about you
• Right of rectification – the right to correct data that we hold about you that is inaccurate or incomplete
• Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records
• Right to restriction of processing – where certain conditions apply, to have a right to restrict the processing
• Right of portability – the right to have the data we hold about you transferred to another organization
• Right to object – the right to object to certain types of processing such as direct marketing
• Right to object to automated processing – the right to not be subject to a decision based solely on automated decision making, including profiling

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

California Residents (CCPA/CPRA)

If you are a California resident, the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA) provide you with specific rights regarding your personal information, including:

• The right to know what personal information we collect, use, disclose, and sell
• The right to delete personal information we have collected from you, subject to certain exceptions
• The right to correct inaccurate personal information
• The right to opt out of the sale or sharing of personal information
• The right to non-discrimination for exercising your privacy rights

Veracor Capital does not sell personal information. We do not sell investor information to third parties for monetary consideration.

To exercise your California privacy rights, please email us at privacy@veracorcapital.com.

Additional Provisions

Transmission of Data to Other Countries

Your Personal Data is processed in the United States, where privacy laws may be less stringent than the laws in your country and where the government, courts, or law enforcement may be able to access your data. By submitting your Personal Data to us, you agree to the transfer, storage, and processing of your Personal Data in the United States.

Canada Anti-Spam Law

We comply with the Canada Anti-Spam Law. Consumers who provide us a Canadian mailing address will not receive unauthorized Commercial Electronic Messages (as defined under the Canada Anti-Spam Law) unless these individuals have "opted-in" to receive Commercial Electronic Messages.

Children's Privacy

Veracor Capital's investment products and services are not directed at, marketed to, or intended for individuals under the age of 18. We do not knowingly collect personal information from children under the age of 18. Securities laws generally require that investors be of legal age to enter into contracts. If you become aware that a minor has provided us with personal information, please contact us at privacy@veracorcapital.com.

Do Not Track Signals

Some web browsers may transmit "do not track" signals to websites. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they are aware of them. We currently do not take action in response to these signals.

Third-Party Websites

Our websites may contain links to third-party websites, including portfolio company websites, news sources, and service provider sites. We are not responsible for the privacy practices of these third-party sites. We encourage you to review the privacy policies of any third-party sites you visit.

Changes to This Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this policy, we will notify you by updating the "Last Updated" date at the top of this policy and, where appropriate, providing additional notice (such as by email or through our investor portal). Your continued use of our services after such modifications will constitute your acknowledgment of the modified policy and agreement to abide by it.

Contact Us

If you would like to contact us for any reason regarding our privacy practices, please contact us at:

Be sure to return to this Policy periodically to review the most current version. We reserve the right at any time, at our sole discretion, to change or otherwise modify this Policy without prior notice; however, the date of any effective changes shall be reflected at the top of this page.

© 2025 Veracor Capital, a division of Veracor Group Holdings, LLC. All Rights Reserved.