Privacy Policy

Last Updated: April 2026

1. Introduction and Entity Identity

This Privacy Policy is issued by Raze Reserve SPC Ltd (hereinafter referred to as "Raze Reserve," "we," "us," or "our"), a company incorporated in the British Virgin Islands under the BVI Business Companies Act, 2004 (as amended). Our registered address is c/o Captiva Global Ltd., Caribbean Chambers, P.O. Box 4428, Road Town, Tortola, British Virgin Islands.

This Privacy Policy governs the collection, use, retention, and disclosure of personal data obtained through razereserve.com (the "Website") and any related institutional inquiry processes conducted by or on behalf of Raze Reserve. By accessing or using this Website, you acknowledge that you have read, understood, and agree to the practices described in this policy.

2. Information We Collect

We collect the following categories of information in connection with your use of this Website:

2.1 Information Submitted Through the Contact Form

When you submit an inquiry through our institutional contact form, we collect the information you voluntarily provide, including your name, organization or fund affiliation, email address, and the content of your message. This information is collected solely for the purpose of responding to your inquiry and maintaining a record of institutional engagement.

2.2 Technical Data

We automatically collect certain technical data when you access this Website, including your Internet Protocol (IP) address, browser type and version, device information, operating system, pages visited, referring URL, and the date and time of each access. This data is collected through standard server logging mechanisms and is used exclusively for security monitoring and website performance optimization.

2.3 Information We Do Not Collect

This Website does not collect investment account information, financial transaction data, payment card details, or any information related to investment activities. We do not use cookies beyond those strictly necessary for essential session functionality. We do not deploy third-party advertising, behavioral tracking, or analytics cookies. We do not knowingly collect personal data from individuals under the age of eighteen (18).

3. How We Use Information

We use the information collected through this Website for the following purposes:

  • To respond to institutional inquiries, partnership discussions, and requests for compliance documentation;
  • To maintain records of institutional engagement as required under applicable law and regulatory obligations;
  • To monitor, maintain, and improve the functionality, security, and integrity of this Website;
  • To comply with applicable legal and regulatory requirements, including anti-money laundering and counter-terrorism financing obligations as may apply under BVI law.

We do not sell, rent, license, or otherwise make available your personal information to third parties for their marketing or commercial purposes. We do not use personal information collected through this Website for unsolicited marketing, advertising, or promotional communications.

4. Legal Basis for Processing

Our processing of personal data is conducted on the following legal bases:

  • Legitimate interests: We process personal data submitted through institutional inquiries on the basis of our legitimate interest in evaluating and responding to prospective institutional relationships. We have assessed that this processing does not override the fundamental rights and freedoms of data subjects given the institutional nature of such inquiries.
  • Consent: Where required under the General Data Protection Regulation (EU) 2016/679 ("GDPR") or equivalent data protection frameworks applicable to the data subject's jurisdiction of residence, we process personal data on the basis of the data subject's freely given, specific, informed, and unambiguous consent.
  • Legal obligation: We may process and retain personal data where required to comply with applicable legal, regulatory, or judicial obligations.

[Note for counsel: Confirm specific BVI Data Protection Act references and the scope of GDPR applicability given BVI domicile with EU-resident qualified investor exposure. Assess whether the BVI Data Protection Act 2021 imposes additional controller obligations relevant to this processing.]

5. Data Retention

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, subject to applicable legal and regulatory retention requirements:

  • Contact form submissions: Retained for a period of twenty-four (24) months from the date of submission, unless a continuing institutional relationship requires extended retention.
  • Technical log data: Retained for a period of twelve (12) months from the date of collection.
  • Extended retention: Data may be retained beyond the periods specified above where required by applicable law, regulatory obligation, or in connection with the establishment, exercise, or defense of legal claims.

Upon expiration of the applicable retention period, personal data is securely deleted or irreversibly anonymized.

6. International Data Transfers

This Website is operated from the British Virgin Islands. Personal data submitted through this Website may be processed in jurisdictions outside the data subject's country of residence, including jurisdictions that may not provide an equivalent level of data protection to that afforded under the data subject's domestic law.

Where personal data is transferred to jurisdictions outside the European Economic Area or the United Kingdom, we implement appropriate safeguards to ensure that such transfers comply with applicable data protection laws, including where applicable the execution of standard contractual clauses approved by the European Commission or reliance on other recognized transfer mechanisms.

[Note for counsel: Confirm adequacy mechanisms applicable to BVI-EU and BVI-UK data transfers. Determine whether standard contractual clauses or alternative transfer mechanisms are required given the entity's domicile and investor base.]

7. Data Subject Rights

Subject to applicable law and the jurisdiction in which you reside, you may have the following rights with respect to your personal data:

  • Right of access: The right to obtain confirmation as to whether personal data concerning you is being processed and, where applicable, to access such data.
  • Right to rectification: The right to request correction of inaccurate personal data.
  • Right to erasure: The right to request deletion of personal data, subject to applicable legal retention obligations.
  • Right to restriction: The right to request restriction of processing in certain circumstances.
  • Right to object: The right to object to processing based on legitimate interests.
  • Right to data portability: Where technically feasible and required under applicable law, the right to receive your personal data in a structured, commonly used, and machine-readable format.

To exercise any of these rights, please contact us at info@razereserve.com. We will respond to verifiable requests within thirty (30) days or such other period as required by applicable law.

[Note for counsel: Confirm the scope of data subject rights applicable under BVI law versus GDPR versus CCPA depending on the domicile of the data subject. Determine whether a formal data subject access request procedure is required.]

8. Security

We implement industry-standard technical and organizational measures designed to protect personal data against unauthorized access, alteration, disclosure, or destruction. These measures include encryption of data in transit, access controls, and regular security monitoring.

Notwithstanding the foregoing, no method of transmission over the Internet and no method of electronic storage is completely secure. We cannot guarantee the absolute security of personal data transmitted to or stored by us. In the event of a data breach that is reasonably likely to result in a risk to the rights and freedoms of affected individuals, we will notify affected parties and applicable supervisory authorities as required by law.

9. Third-Party Services

This Website may utilize third-party infrastructure and service providers in connection with its hosting, email delivery, and operational functions. Such providers process personal data solely on our behalf and in accordance with our instructions, subject to appropriate contractual safeguards.

We do not integrate third-party advertising networks, social media tracking pixels, behavioral analytics platforms, or any other third-party services that independently collect or process personal data obtained through this Website.

[Note for counsel: Insert specific sub-processor list once confirmed. Anticipated processors include SiteGround (hosting), Google Workspace (email), and WP Mail SMTP (form delivery). Confirm whether a formal sub-processor register is required.]

10. Changes to This Policy

We reserve the right to amend this Privacy Policy at any time. Material changes will be reflected on this page with an updated "Last Updated" date. We encourage you to review this page periodically. Your continued use of this Website following the posting of any changes constitutes your acceptance of such changes.

11. Contact

For questions, concerns, or requests relating to your personal data or this Privacy Policy, please contact:

Raze Reserve SPC Ltd
c/o Captiva Global Ltd.
Caribbean Chambers, P.O. Box 4428
Road Town, Tortola
British Virgin Islands
Email: info@razereserve.com