Privacy Policy

Last updated: 22 October 2025

MTF Management LLC (“MTF,” “we,” “us,” or “our”) is committed to maintaining the confidentiality, integrity, and security of personal information in our control. This Privacy Statement explains how we collect, use, disclose, and protect your personal information in accordance with applicable United States federal and state privacy laws, including the California Consumer Privacy Act (“CCPA”).

For any privacy-related inquiries or requests, please contact us at:

DataPrivacy@mtfmanagement.org

  1. Personal Information We Collect

We collect only the personal information necessary for legitimate business purposes related to our investment, management, and administrative services. The categories of personal information we may collect include:

– Identifiers: Name, postal address, email address, phone number, date of birth, passport or ID number, Social Security number, tax identification number, and similar identifiers.

– Financial and transactional data: Bank account details, investment records, billing and payment information, and transaction history.

– Professional information: Employment details, business contact data, and professional credentials.

– Internet and electronic data: IP address, device information, login activity, and website usage data collected via cookies and analytics tools.

– Sensitive personal information: In limited cases, identifiers such as Social Security or driver’s license numbers required for compliance, due diligence, or legal purposes.

We do not knowingly collect personal data from individuals under the age of 18.

  1. Sources of Personal Information

We collect personal information from:

– Clients and investors through subscription, management, or advisory agreements.

– Direct interactions via email, phone, or online forms.

– Website analytics tools such as Google Analytics.

– Client and transaction records in the ordinary course of business.

  1. How We Use Your Personal Information

We handle all personal data confidentially and use it only for lawful business purposes, including:

– Client services and support: Administering accounts, processing transactions, and providing requested services.

– Legal and regulatory compliance: Fulfilling obligations under U.S. law, including anti-money laundering, sanctions, and tax reporting.

– Security and fraud prevention: Protecting systems, assets, and client information from unauthorized access or misuse.

– Analytics and improvement: Enhancing website performance, client experience, and operational efficiency.

– Business operations: Accounting, auditing, internal governance, and corporate management.

– Communications: Providing updates, notices, and information related to your relationship with MTF.

MTF does not sell or share personal information for marketing or cross-context behavioural advertising purposes.

  1. Disclosure of Information

MTF does not sell personal data. We may disclose information only under the following limited circumstances:

– Service providers and vendors performing administrative, financial, or technical services under confidentiality agreements.

– Affiliates and subsidiaries within our network, consistent with this Privacy Statement.

– Regulators, auditors, and legal authorities to comply with applicable laws or respond to lawful requests.

– Corporate transactions, such as mergers, acquisitions, or restructurings, where information may be transferred under confidentiality terms.

– Security and rights protection to detect or prevent fraud, unauthorized access, or illegal activity.

All third parties are contractually required to protect the confidentiality and integrity of personal information.

  1. Cookies and Analytics

MTF and its third-party service providers use cookies and analytics to enhance website functionality and security.

– Cookies: Small data files that improve navigation and user experience. You may disable cookies through browser settings, though some site features may not function properly.

– Analytics: We use Google Analytics to understand user behaviour and improve website performance.

Learn more: https://www.google.com/policies/privacy/partners

  1. Data Retention

We retain personal data only as long as necessary to meet business, contractual, or legal requirements. Generally, we maintain relevant information for seven (7) years from the last date of activity or as otherwise required by law.

  1. California Privacy Rights (CCPA)

California residents are entitled to the following rights, subject to verification and legal limitations:

– Right to Know: Request details of the personal information collected and disclosed.

– Right to Delete: Request deletion of personal information, except where retention is required by law.

– Right to Correct: Request correction of inaccurate personal information.

– Right to Non-Discrimination: You will not be treated differently for exercising your rights.

MTF does not sell or share personal information or use sensitive personal data beyond permitted business purposes.

Requests may be submitted by emailing DataPrivacy@mtfmanagement.org

Authorized agents may submit requests on behalf of consumers with valid authorization.

  1. Security Measures

MTF implements physical, electronic, and procedural safeguards designed to protect personal data against unauthorized access, alteration, or destruction. While we maintain strong security measures, no system can guarantee absolute protection.

  1. Access, Updates, and Contact

You may request access to, correction of, or information about the personal data we hold by contacting:

DataPrivacy@mtfmanagement.org

  1. Changes to This Privacy Statement

We may update this Privacy Statement periodically to refiect legal, operational, or regulatory changes. Updated versions will be posted on our website with a revised “Last Updated” date.  Continued use of our services constitutes acceptance of the updated policy.