Privacy Policy.

1. Introduction

Alpha Tactical Partners (“ATP,” “we,” “our,” or “us”) is committed to protecting the privacy and confidentiality of information provided by visitors to our website at atphedgefunds.com (the “Site”) and by current and prospective investors and counterparties (collectively, “you” or “your”).

This Privacy Policy describes how we collect, use, disclose, and safeguard personal information in connection with your use of our Site and our business operations. By accessing or using our Site, you acknowledge that you have read and understood this Privacy Policy.

Alpha Tactical Partners operates as an investment management firm offering hedge fund and alternative investment strategies. As a financial services firm, we are subject to various regulatory obligations that govern our handling of personal and financial information.

2. Information We Collect

2.1 Information You Provide Directly

We may collect personal information that you voluntarily provide when you:

• Complete contact forms or request information on our Site
• Communicate with us via email, telephone, or other channels
• Submit investor qualification or accreditation documentation
• Execute subscription agreements, side letters, or other fund documents
• Register for investor portals or online account access
• Attend events, conferences, or meetings hosted or attended by ATP

This information may include your name, title, employer, mailing address, email address, telephone number, tax identification numbers, financial information, investment history, and other details necessary for onboarding and fund administration.

2.2 Information Collected Automatically

When you visit our Site, we may automatically collect certain technical and usage information, including:

• IP address, browser type, and operating system
• Pages visited, time spent on pages, and navigation paths
• Referring URLs and search terms used to find our Site
• Device identifiers and general geographic location based on IP address
• Cookies, web beacons, and similar tracking technologies (see Section 7)

2.3 Information from Third Parties

We may receive personal information about you from third parties, including:

• Placement agents, financial intermediaries, and introducing brokers
• Fund administrators, prime brokers, and custodians
• Anti-money laundering (AML) and know-your-customer (KYC) service providers
• Publicly available databases, regulatory filings, and credit bureaus
• Background check providers and compliance screening services

3. How We Use Your Information

Alpha Tactical Partners uses the personal information we collect for the following purposes:

3.1 Fund Operations and Investor Relations

• Processing subscription applications and investor onboarding
• Administering investor accounts and processing capital calls, distributions, and redemptions
• Providing account statements, reports, and performance updates
• Communicating material information regarding fund activities and strategy
• Responding to investor inquiries and requests

3.2 Regulatory and Legal Compliance

• Conducting AML, KYC, and OFAC screening as required by applicable law
• Fulfilling reporting obligations to regulatory authorities including the SEC and CFTC
• Complying with tax reporting requirements (Form 1099, Schedule K-1, FATCA, CRS)
• Maintaining books and records as required under the Investment Advisers Act of 1940
• Responding to regulatory inquiries, examinations, or investigations
• Enforcing our legal rights and obligations under fund agreements

3.3 Business Development and Prospective Investors

• Evaluating investor suitability and accreditation status
• Providing information about our investment strategies and fund offerings
• Communicating market commentary, research, and investor updates
• Managing relationships with placement agents and distribution partners

3.4 Site Operation and Security

• Administering, maintaining, and improving the functionality of our Site
• Monitoring for fraudulent activity, unauthorized access, and security threats
• Analyzing Site usage to enhance user experience
• Diagnosing technical problems and ensuring Site performance

4. Legal Basis for Processing Personal Information

We process your personal information on the following legal bases:

• Contractual Necessity: Processing required to perform our obligations under subscription agreements and other fund documents
• Legal Obligation: Processing necessary to comply with applicable laws, regulations, and regulatory requirements
• Legitimate Interests: Processing for our legitimate business interests, including risk management, fraud prevention, and business development, provided such interests are not overridden by your rights
• Consent: Where we have obtained your express consent to process your information for a specific purpose

5. Disclosure of Your Information

Alpha Tactical Partners does not sell, rent, or trade personal information to third parties for their marketing purposes. We may share your information in the following limited circumstances:

5.1 Service Providers and Fund Partners

We share information with third-party service providers who assist in our fund operations and business activities, including:

• Fund administrators and accounting firms
• Prime brokers, custodians, and execution brokers
• Legal counsel, auditors, and tax advisors
• Technology and data service providers
• AML/KYC compliance and background screening providers
• Transfer agents and investor portal providers

These service providers are contractually obligated to use personal information only as directed by ATP and in accordance with applicable law.

5.2 Regulatory and Legal Disclosures

We may disclose personal information when required or permitted by law, including:

• In response to a subpoena, court order, or lawful government request
• To comply with regulatory examinations or reporting requirements
• To protect the rights, property, or safety of ATP, our investors, or the public
• In connection with fraud prevention and AML obligations

6. Data Retention

We retain personal information for as long as necessary to fulfill the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law. Our retention practices are guided by the following considerations:

• Investor records and fund documentation are generally retained for a minimum of seven (7) years following the close of a fund or termination of an investor relationship, in accordance with SEC recordkeeping requirements
• AML and KYC records are retained in accordance with applicable Bank Secrecy Act and FinCEN requirements
• Tax records and related documentation are retained for the periods required by applicable federal, state, and international tax authorities
• Website usage data and analytics information is retained for shorter periods consistent with its operational purpose

When personal information is no longer needed, we take reasonable steps to securely destroy or de-identify it.

7. Cookies and Tracking Technologies

Our Site uses cookies and similar technologies to enhance your browsing experience and analyze Site usage. Cookies are small text files stored on your device that help us recognize returning visitors, track usage patterns, and improve Site functionality.

7.1 Types of Cookies We Use

• Essential Cookies: Necessary for the basic functionality of the Site, including navigation and secure areas. These cannot be disabled.
• Analytics Cookies: Used to collect aggregated information about how visitors interact with our Site, enabling us to improve content and user experience.
• Preference Cookies: Allow the Site to remember your choices and settings to provide a more personalized experience.

7.2 Managing Cookies

Most web browsers allow you to control cookies through their settings. You may set your browser to refuse cookies or alert you when cookies are being sent. However, disabling certain cookies may affect the functionality of our Site. Please note that our Site does not currently respond to browser “Do Not Track” signals.

8. Data Security

Alpha Tactical Partners maintains administrative, technical, and physical safeguards designed to protect personal information from unauthorized access, use, disclosure, alteration, or destruction. Our security measures include:

• Encryption of sensitive data in transit and at rest
• Access controls and authentication protocols limiting access to authorized personnel
• Regular security assessments and vulnerability testing
• Employee training on data privacy and security practices
• Incident response procedures for potential data breaches

While we take reasonable precautions, no method of electronic transmission or storage is 100% secure. We cannot guarantee absolute security of your information and encourage you to use caution when transmitting sensitive information electronically.

In the event of a data breach that poses a risk to your rights or freedoms, we will notify you and applicable regulatory authorities as required by law.

9. Your Privacy Rights

Depending on your jurisdiction, you may have certain rights regarding your personal information. These may include:

• Right to Access: The right to request a copy of the personal information we hold about you
• Right to Correction: The right to request correction of inaccurate or incomplete information
• Right to Deletion: The right to request deletion of your personal information, subject to legal and regulatory retention requirements
• Right to Restriction: The right to request that we limit how we use your information in certain circumstances
• Right to Portability: The right to receive your personal information in a structured, machine-readable format
• Right to Object: The right to object to processing based on legitimate interests or for direct marketing purposes
• Right to Withdraw Consent: Where processing is based on consent, the right to withdraw consent at any time without affecting the lawfulness of prior processing

Please note that some of these rights may be limited or overridden by our legal obligations as a regulated investment manager. To exercise any of these rights, please contact us using the information provided in Section 12.

California residents may have additional rights under the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA). For more information, please contact us directly.

10. International Data Transfers

Alpha Tactical Partners is based in the United States. If you are located outside the United States, please be aware that your personal information will be transferred to, stored, and processed in the United States, where privacy laws may differ from those in your home country.

When we transfer personal information from the European Economic Area, the United Kingdom, or Switzerland to countries that have not been deemed to provide an adequate level of protection, we rely on appropriate safeguards such as Standard Contractual Clauses approved by the European Commission, or other lawful transfer mechanisms.

11. Third-Party Websites and Services

Our Site may contain links to third-party websites, publications, or services that are not operated by Alpha Tactical Partners. We are not responsible for the privacy practices of such third parties and encourage you to review the privacy policies of any third-party sites you visit. This Privacy Policy applies solely to information collected by our Site and in the course of our business operations.

12. Contact Information

If you have questions about this Privacy Policy, wish to exercise your privacy rights, or have concerns about how we handle your personal information, please contact us:

Alpha Tactical Partners

Website: atphedgefunds.com

For general inquiries, please use the contact form available at atphedgefunds.com/contact.

We will endeavor to respond to verified requests within thirty (30) days. In certain circumstances, we may require additional time to respond and will notify you accordingly.

13. Amendments to This Privacy Policy

Alpha Tactical Partners reserves the right to update or modify this Privacy Policy at any time. If we make material changes, we will notify you by posting the updated policy on our Site with a revised effective date. We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information.

Your continued use of our Site or maintenance of an investor relationship with us following the posting of changes constitutes your acceptance of the revised Privacy Policy.