Privacy Policy

Last Updated: January 2026

1. Introduction

Ciel de Jade ("the Fund", "we", "us", or "our") is committed to protecting the privacy and confidentiality of personal information in accordance with applicable data protection laws and regulations, including the British Virgin Islands Data Protection Act, 2021.

2. Information We Collect

We may collect and process the following categories of personal information:

  • Identity information (name, date of birth, nationality)
  • Contact information (address, email, telephone)
  • Financial information (investment amounts, bank details, source of funds)
  • Tax information (tax identification numbers, residency status)
  • Professional information (employment, business activities)

3. How We Use Your Information

We use personal information for the following purposes:

  • Processing subscription and redemption requests
  • Managing investor accounts and relationships
  • Complying with legal and regulatory obligations (AML/KYC requirements)
  • Reporting to regulatory authorities as required by law
  • Communicating with investors about the Fund

4. Information Sharing

We may share personal information with:

  • Service providers (administrators, custodians, auditors)
  • Professional advisors (legal counsel, tax advisors)
  • Regulatory authorities (BVI FSC, tax authorities)
  • Other parties as required by law or with your consent

5. Data Security

We implement appropriate technical and organizational measures to protect personal information against unauthorized access, alteration, disclosure, or destruction.

6. Data Retention

We retain personal information for as long as necessary to fulfill the purposes outlined in this policy and to comply with legal and regulatory requirements, typically for a minimum of seven years following the termination of the investor relationship.

7. Your Rights

Subject to applicable law, you have the right to:

  • Access your personal information
  • Request correction of inaccurate information
  • Request deletion of personal information in certain circumstances
  • Object to processing of personal information
  • Lodge a complaint with the relevant data protection authority

8. Contact Information

For questions about this Privacy Policy or to exercise your rights, please contact us at the details provided in the Contact section of our website.