1. Overview
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This Privacy Notice describes how Moon Rock Capital Ltd., a company incorporated in the British Virgin Islands (the “Company”, “we”, “us”, or “our”), collects, uses, and discloses personal information in connection with:
- its investment management activities,
- investor onboarding and administration, and
- operation of its website and related services.
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This Notice applies to investors, prospective investors, counterparties, service providers, and website users.

2. Categories of Personal Information
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We collect personal information necessary to operate an investment fund and comply with applicable laws and regulations.
(a) Identification Data
- Full name, email address, phone number
- Residential or business address
- IP address and device identifiers
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(b) Investor & Financial Data
- Bank account and payment details
- Investment history and transaction records
- Source of wealth and source of funds
- Wallet addresses and blockchain-related identifiers
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(c) Compliance & Regulatory Data
- Government-issued identification (passport, ID)
- Tax identification numbers
- KYC/AML documentation
- Screening results (sanctions, PEP, adverse media)
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(d) Commercial Information
- Subscription and redemption records
- Communications with the Company
- Investor preferences
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(e) Technical & Usage Data
- Website interaction data
- Device and browser information
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(f) Professional Information
- Employment, role, and business affiliations
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(g) Sensitive Personal Data
- Where required by law or regulatory obligations:
- Identification numbers
- Financial credentials
- Compliance-related data

3. Sources of Information
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We obtain personal information from:
- Direct interactions with you
- Fund administrators and placement agents
- Financial institutions and custodians
- Third-party KYC/AML providersLegal, tax, and compliance advisors
- Public databases and regulatory sources

4. Purpose of Processing
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We process personal information for purposes including:
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Fund Operations
- Investor onboarding and account administration
- Processing subscriptions, capital calls, and distributions
- Maintaining investor registers
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Compliance & Risk Management
- Anti-money laundering (AML) and counter-terrorist financing (CTF) checks
- Know-your-customer (KYC) procedures
- Regulatory reporting and compliance
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Business Operations
- Managing relationships with investors and counterparties
- Internal reporting, analytics, and performance monitoring
- Improving systems and infrastructure
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Security & Integrity
- Fraud detection and prevention
- Cybersecurity monitoring
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Communications
- Providing fund updates, reporting, and investor communications

5. Legal Basis (EEA / UK Investors)
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Where applicable, we rely on:
- Legal obligations (AML/KYC, regulatory compliance)
- Contractual necessity (investment relationship)
- Legitimate interests (fund operations, risk management)
- Consent, where required

6. Disclosure of Personal Information
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We may disclose personal information to:
- Fund administrators, custodians, and transfer agents
- Banks, brokers, and liquidity providers
- Legal, tax, and audit advisors
- KYC/AML and compliance service providers
- Affiliates and related entities
- Regulatory authorities and law enforcement
- Transaction counterparties
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We do not sell personal information.

7. International Transfers
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Due to the global nature of our operations, personal information may be transferred to jurisdictions outside the British Virgin Islands, including the United States and other financial centers.
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We implement appropriate safeguards, including contractual protections, to ensure data is processed securely.

8. Data Retention
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We retain personal information:
- For the duration of the investor relationship
- As required by applicable laws (including AML and regulatory retention requirements)
- As necessary to protect legal rights and interests

9. Your Rights
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Subject to applicable law, you may have the right to:
- Access your personal data
- Request correction of inaccurate information
- Request deletion (where legally permissible)
- Restrict or object to processing
-Request data portability
- Withdraw consent (where applicable)
- Lodge a complaint with a competent authority

10. Cookies & Website Data
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We use cookies and similar technologies to:
- Ensure proper website functionality
- Analyze usage and improve performance
- You may manage cookie preferences through your browser settings.

11. Data Security
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We implement appropriate technical and organizational measures designed to protect personal information against unauthorized access, loss, misuse, or alteration.

12. Children
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Our services are not directed to individuals under the age of 18, and we do not knowingly collect their personal data.

13. Amendments
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We may update this Privacy
Notice from time to time. The most current version will be made available through our website or upon request.

14. Contact
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‍Moon Rock Capital Ltd.
British Virgin Islands
Email: askme@moonrock.capital