Privacy Policy

1. Purpose and Scope

This Privacy Policy (“Policy”) outlines how Quiq Capital LLC (“Quiq,” “the Firm,” “we,” or “us”) collects, uses, stores, and protects personal and confidential information related to its investors, partners, borrowers, employees, and counterparties. The Policy applies to all business units of Quiq Capital, including its investment funds, advisory services, and managed accounts, and governs both online and offline data handling practices.

2. Commitment to Data Privacy

Quiq Capital is committed to maintaining the confidentiality, integrity, and security of all non-public personal information (“NPI”) it receives in the course of its business. The Firm upholds privacy standards consistent with:

• The Gramm-Leach-Bliley Act (GLBA).
• The California Consumer Privacy Act (CCPA) (where applicable).
• Other relevant federal and state privacy and data-protection laws.

3. Information We Collect

The Firm may collect and maintain the following categories of information:

• Investor Information: Name, address, contact details, tax identification numbers, banking instructions, investment amounts, and accreditation documents.
• Borrower Information: Business ownership, financial statements, tax returns, collateral documentation, and payment details.
• Employee and Vendor Information: Identification data, background checks, payroll details, and contact information.
• Website and Digital Interactions: Limited usage data (e.g., IP addresses, access logs) to improve system performance and security.
• Derived and Analytical Information: Internal analyses, summaries, risk assessments, underwriting notes, servicing records, portfolio monitoring data, fraud-prevention indicators, and other information generated from or relating to information collected by Quiq Capital.

‍

All data is collected solely for legitimate business, operational, and compliance purposes.

4. How We Use Information

Quiq Capital uses collected information for the following purposes:

• Administering investor accounts and processing capital transactions.
• Evaluating and underwriting borrower credit requests.
• Fulfilling regulatory, tax, and legal obligations.
• Conducting internal analytics, due diligence, and risk management.
• Communicating with investors, partners, and borrowers.
• Detecting and preventing fraud, money laundering, or unauthorized activity.

‍

Personal information is not sold or rented to any third party.

5. Use of Technology, Automation, and Artificial Intelligence

Quiq Capital may use third-party software, data platforms, automation tools, artificial intelligence, machine learning, analytics tools, and other technologies to support and improve its business operations, due diligence, underwriting, portfolio monitoring, loan servicing, compliance, fraud prevention, recordkeeping, communications, and investor relations.

These tools may assist the Firm in receiving, organizing, analyzing, summarizing, validating, and processing information provided by current or prospective borrowers, partners, employees, vendors, counterparties, or other third-party sources. Such technologies may also be used to generate internal analyses, reports, summaries, risk assessments, workflow recommendations, servicing updates, or other business-support materials.

Quiq Capital does not sell or rent personal information. Quiq Capital’s use of technology and artificial intelligence is intended to support its internal business processes and decision-making, subject to applicable law, confidentiality obligations, this Privacy Policy, and any applicable transaction documents. Quiq Capital retains discretion over its underwriting, credit, investment, servicing, and other business decisions.

6. Information Sharing and Disclosure

Quiq Capital may disclose limited non-public information only as permitted by law and under strict confidentiality obligations. Such disclosures may include:

• Service Providers: Fund administrators, custodians, accountants, technology providers, software vendors, cloud service providers, data analytics providers, artificial intelligence or automation tool providers, consultants, or legal counsel assisting in operations, underwriting, loan servicing, compliance, reporting, cybersecurity, or other legitimate business functions.
• Regulatory or Legal Requests: Government or regulatory authorities as required by law, subpoena, or court order.
• Transaction Counterparties: Limited data sharing for transaction due diligence, subject to confidentiality undertakings.

‍

All third parties with access to confidential information must adhere to Quiq’s privacy and cybersecurity policies.

7. Data Protection and Security

Quiq Capital employs administrative, physical, and technological safeguards to protect personal information. These include:

• Encryption of sensitive electronic data.
• Access controls restricted to authorized personnel only.
• Multi-factor authentication and password protection.
• Regular system monitoring and intrusion detection.
• Secure data backups and off-site replication.

‍

These practices align with Quiq Capital’s Cybersecurity Policy and are guided by the ISO/IEC 27032 framework.

7. Retention and Disposal

Personal and financial information is retained only for as long as necessary to meet legal, regulatory, and business obligations. When no longer required, information is securely deleted or destroyed using industry-standard data disposal methods.

8. Rights of Data Subjects

Where applicable by law, individuals have the right to:

• Access the personal data held by Quiq Capital.
• Request corrections or updates to their information.
• Request deletion of personal data, subject to regulatory record-keeping requirements.
• Opt out of non-essential communications.

‍

Requests can be submitted by contacting accounting@quiqcapital.com.

9. Third-Party Websites

Quiq Capital’s website and digital materials may contain links to third-party platforms. The Firm is not responsible for the privacy practices or content of such external websites and encourages users to review their respective privacy policies.

10. Cybersecurity and Incident Response

In the event of a data breach involving personal or confidential information:

• Quiq will immediately investigate and contain the incident;
• Notify affected individuals or entities as required by law; and
• Coordinate with its third-party technology provider and cyber insurance carrier to manage response and remediation.

11. Policy Review and Updates

This Policy is reviewed annually or upon material change in business operations, regulatory requirements, or data-handling processes. Updates are approved by the General Partner and distributed to all relevant stakeholders.

12. Contact Information

For questions or concerns regarding this Privacy Policy or Quiq Capital’s data-handling practices, please contact:

Quiq Capital LLC

Attn: Compliance Department

Email: accounting@quiqcapital.com

Website: www.quiqcapital.com

13. Confidentiality Statement

All information handled by Quiq Capital is treated as strictly confidential. Unauthorized use or disclosure of non-public information may result in disciplinary action and potential legal liability.