Privacy Policy

1. Scope and Applicability

This Privacy Policy applies exclusively to information processed through the Portal. It does not apply to:

• the public marketing website at www.phoenixagentics.com, which is governed by a separate privacy notice;
• information you provide directly to Opus Fund Services (the Fund's independent administrator) in connection with subscriptions, redemptions, AML/KYC, or account servicing — Opus maintains its own privacy practices;
• information processed by Marex Capital Markets (the Fund's Futures Commission Merchant) in connection with futures trading on behalf of the Master Fund; or
• information collected in any in-person, telephone, or email communication outside the Portal interface, which is governed by applicable fund counsel-reviewed agreements and notices.

"Funds" refers collectively to Phoenix Agentics Master Fund LP, Phoenix Agentics Fund LP (U.S. Feeder), and Phoenix Agentics Cayman Feeder Fund Ltd (Cayman Feeder). "Personal Information" means information that identifies, relates to, describes, or is reasonably capable of being associated with a natural person.

2. Information We Collect

2.1 Information You Provide

• QEP Attestation Information: Your full legal name, email address, the qualifying category under CFTC Rule 4.7(a) you assert, and acknowledgments of the five attestation statements presented on the entry page.
• Authentication Credentials: The username and password you use to access the Portal. Passwords are not stored in plaintext by the Portal and, in production deployments, are authenticated against an external identity provider.
• Voluntary Communications: Any information you send to investors@phoenixagentics.com or otherwise voluntarily provide.

2.2 Information Collected Automatically

• Audit Log Events: The Portal records the timestamp, event type (attestation, login, login failure, page view, upload, data clearing, logout), the user identifier, the page accessed, and additional structured detail. These records are required under NFA Compliance Rule 2-10 and CFTC Regulation 1.31.
• Session Information: Your browser session token, which is held in your browser's sessionStorage and expires after eight (8) hours of activity.
• Technical Information: Server logs may record IP address, user-agent string, referring URL, and timestamps. We do not use third-party analytics, advertising trackers, behavioral profiling tools, or social-media pixels on the Portal.

2.3 Information We Do Not Collect

The Portal does not request or collect Social Security numbers, taxpayer identification numbers, bank account or brokerage account numbers, dates of birth, government-issued identification, residential addresses, biometric identifiers, geolocation data beyond IP-derived approximate location, or sensitive personal information as defined under California's CPRA. Information of those types, where required for subscription, is collected by Opus Fund Services through its own subscription-document workflow and is not processed through the Portal.

3. Purposes of Processing

We process information only for the following purposes:

1. To verify that persons accessing performance materials are Qualified Eligible Persons within the meaning of CFTC Rule 4.7;
2. To authenticate users and maintain authorized access;
3. To produce, retain, and make available compliance records required by NFA Compliance Rule 2-10, CFTC Regulation 1.31, and related guidance;
4. To respond to investor inquiries;
5. To detect, investigate, and prevent unauthorized access, fraudulent activity, and breaches of the Terms of Use;
6. To comply with applicable law, regulatory request, subpoena, or court order; and
7. To perform internal operational, auditing, and security functions reasonably necessary to operate the Portal.

We do not use Portal information for marketing the Funds to persons who did not initiate contact with us, for cross-marketing other products, for sale or rental to third parties, or for advertising of any kind.

4. Financial Privacy (Gramm-Leach-Bliley Act)

The CPO is a "financial institution" within the meaning of the Gramm-Leach-Bliley Act ("GLBA") and Regulation S-P. To the extent any information processed through the Portal constitutes "nonpublic personal information" under GLBA — for example, the fact that a particular person is a current or prospective investor in the Funds — the following applies:

• We collect such information solely to provide and administer the Portal and the Funds.
• We do not disclose nonpublic personal information to nonaffiliated third parties except as permitted by GLBA exceptions — including disclosures to the Fund's administrator (Opus Fund Services), Futures Commission Merchant (Marex Capital Markets), independent auditors, fund counsel, and regulators, in each case in connection with administration of the Funds.
• You have no GLBA "opt-out" decision to make because we make no opt-out-eligible disclosures.
• Our information-security program is reasonably designed under Regulation S-P §248.30 to safeguard the security and confidentiality of records and information.

5. When We Share Information

We disclose information collected through the Portal only:

• To service providers identified in Section 6, under contractual obligations of confidentiality and use limitation;
• To affiliates within the Phoenix Agentics group (Phoenix Agentics Capital Partners LLC, Phoenix Agentics Operations LLC) on a need-to-know basis;
• To independent auditors engaged to audit the Funds or the CPO;
• To regulators and self-regulatory organizations including the National Futures Association and the Commodity Futures Trading Commission, in response to examination, inquiry, subpoena, or as otherwise required;
• To law enforcement in response to lawful process or where we have a good-faith belief that disclosure is necessary to investigate or address suspected fraud, security incidents, or violations of law; and
• In connection with a corporate transaction involving the CPO, the General Partner, or the Funds, subject to confidentiality undertakings from any acquirer.

We do not sell Personal Information. We do not share Personal Information for cross-context behavioral advertising.

6. Third-Party Service Providers

The following third parties may process information on our behalf in connection with the Portal:

• Opus Fund Services — independent fund administrator. Receives official NAV, subscription, redemption, and capital-account information. Does not receive Portal-only data such as audit-log events unless requested in connection with administration.
• Marex Capital Markets — Futures Commission Merchant. Receives master-fund trading account information. Does not receive investor-identifying Portal data.
• Hosting and authentication providers — the infrastructure on which the Portal is deployed and the authentication backend (if external) process technical data necessary to deliver the Portal.
• Google Fonts and content delivery networks — typography assets and JavaScript libraries are served from public content delivery networks. These providers may receive your IP address and user-agent string as part of routine network delivery. No identifying information is sent to them by us.

Each service provider is contractually limited to using the information solely to perform services for us and is required to maintain reasonable security safeguards.

7. Retention and Recordkeeping

Records are retained for the periods set by applicable law and regulation:

• Audit-log events: retained for at least five (5) years from the date of the event, with the first two (2) years readily accessible, as required by NFA Compliance Rule 2-10 and CFTC Regulation 1.31.
• QEP attestations and acknowledgments: retained for the duration of any investor relationship plus seven (7) years thereafter, or such longer period as required by NFA, CFTC, or fund-counsel guidance.
• Session and authentication records: retained only for the duration of the session and as needed to investigate security events.
• Email and voluntary communications: retained per the CPO's general communications-retention policy, which conforms to NFA recordkeeping standards.

Retention may be extended where information is the subject of a legal hold, pending or anticipated litigation, regulatory inquiry, or audit.

8. Security

We maintain administrative, technical, and physical safeguards reasonably designed to protect information against unauthorized access, alteration, disclosure, and destruction. These safeguards include access controls, session expiration, audit logging, encrypted transport (TLS), and limited internal access on a need-to-know basis.

No method of transmission over the Internet and no method of electronic storage is one-hundred-percent secure. While we strive to use commercially reasonable means to protect information, we cannot guarantee absolute security. If we become aware of a security incident affecting Personal Information processed through the Portal, we will provide notice as required by applicable law.

9. Local Storage and Cookies

The Portal uses your browser's sessionStorage and localStorage to operate:

• Session token (sessionStorage) — required for authenticated access; expires on browser close or after eight hours.
• QEP attestation record (localStorage) — stored on your device so you do not have to re-attest on each visit. Valid for 365 days from the date of attestation. You may clear this at any time using your browser's privacy controls.
• Audit-log buffer and parsed performance data (localStorage) — administrative caches used by the Portal itself, not used for tracking.

The Portal does not use cookies for advertising, behavioral profiling, cross-site tracking, or analytics. Disabling localStorage will prevent the Portal from operating but will not be used as a basis for any tracking.

10. Access, Correction, and Deletion

You may request that we:

• provide access to Portal-held information about you;
• correct inaccurate information;
• delete information that is not subject to a regulatory retention obligation or active legal hold; or
• provide a portable copy of information you provided directly to us.

Requests should be sent to investors@phoenixagentics.com. We will respond within forty-five (45) days, or such shorter period as applicable law requires. We may decline requests to the extent compliance would violate a recordkeeping obligation, prejudice an investigation, breach a confidentiality obligation, or where we cannot reasonably verify your identity.

11. California Residents

If you are a California resident, the California Consumer Privacy Act, as amended by the California Privacy Rights Act ("CCPA/CPRA"), provides additional rights. The CCPA/CPRA generally does not apply to information processed under GLBA; most information we process through the Portal falls into that exception. To the extent any information we process is not GLBA-exempt:

• You have the right to know what categories of Personal Information we have collected, the categories of sources, the business purposes for collection, and the categories of third parties to whom we disclose Personal Information — each of which is described in Sections 2, 3, 5, and 6 above.
• You have the right to request access, correction, deletion, and (where applicable) portability.
• You have the right not to be discriminated against for exercising your rights.
• We do not "sell" or "share" Personal Information as those terms are defined in CCPA/CPRA. We do not use or disclose sensitive personal information for purposes other than those permitted under CCPA/CPRA without limitation.

To exercise rights, contact investors@phoenixagentics.com. You may also designate an authorized agent. We will verify your identity through commercially reasonable means before fulfilling a request.

12. Investors Outside the United States

The Funds are offered only to Qualified Eligible Persons in the United States and, in respect of the Cayman Feeder, to non-U.S. investors in jurisdictions where the offering complies with local law. The CPO does not solicit investors in the European Union, the United Kingdom, or any other jurisdiction where doing so would constitute a regulated cross-border activity.

If you initiated contact with us on your own initiative (a "reverse solicitation") and reside in the European Union, the United Kingdom, the Cayman Islands, or another jurisdiction with applicable data-protection law:

• The CPO acts as the controller of your Personal Information for purposes of the EU General Data Protection Regulation, the UK GDPR, and analogous laws as applicable.
• Our legal bases for processing are (i) your consent to use the Portal under the attestation; (ii) our legitimate interest in operating a secure investor information system; and (iii) compliance with U.S. legal and regulatory obligations.
• Personal Information will be transferred to and stored in the United States. By using the Portal, you acknowledge this transfer.
• You may have rights of access, rectification, erasure, restriction, objection, and portability, and the right to lodge a complaint with your local supervisory authority.
• You can exercise these rights by contacting investors@phoenixagentics.com.

Nothing in this section constitutes an offer or solicitation in any jurisdiction in which such an offer or solicitation would be unlawful.

13. Children

The Portal is not directed to, and we do not knowingly collect information from, persons under the age of eighteen (18). The eligibility standards under CFTC Rule 4.7 require investors to be adults. If you believe a minor has provided information to us, please contact investors@phoenixagentics.com and we will delete it.

14. Changes to This Policy

We may amend this Privacy Policy from time to time. Material changes will be indicated by an updated Effective Date and Version number at the top of this page. Authenticated users may be required to re-acknowledge the policy following a material change. Your continued use of the Portal following the Effective Date of a change constitutes acceptance of the changes to the extent permitted by applicable law.

15. Contact

Questions about this Privacy Policy or our information practices should be directed to:

Phoenix Agentics Capital Management LLC
Attn: Investor Relations
investors@phoenixagentics.com