Privacy Policy

1. Introduction

This Privacy Policy describes how 6116 Partners LLC, a Delaware limited liability company (“6116 Partners,” “we,” “us,” or “our”), collects, uses, and discloses information about you when you visit our website at 6116partners.com (the “Site”) or otherwise interact with us.

Our Site is intended exclusively for individuals who qualify as “Accredited Investors” as defined in Rule 501(a) of Regulation D under the U.S. Securities Act of 1933. By accessing or using our Site, you acknowledge that you have read and understand this Privacy Policy.

2. Information We Collect

Information You Provide Directly

When you submit our contact form, request offering documents, or otherwise communicate with us, we collect information you choose to provide, which may include:

• Full legal name
• Email address
• Firm or family office name
• Stated investment interest and inquiry message
• Accreditation status attestation
• Information you provide during subsequent communications, including identity verification documents and accreditation evidence (such as tax returns, brokerage statements, or letters from a CPA, attorney, or registered investment adviser) submitted in connection with verifying your status as an Accredited Investor

Information We Collect Automatically

When you visit our Site, we and our service providers may automatically collect certain information, including:

• IP address and approximate geographic location
• Browser type, operating system, and device characteristics
• Pages visited, time spent, and referring URLs
• Date and time of visits

Cookies and Similar Technologies

Our Site uses strictly necessary technologies (browser session storage) to record your acknowledgement of accreditation eligibility for the duration of your browser session. We do not currently use advertising cookies, third-party analytics tracking cookies, or other technologies that require explicit consent under applicable law.

3. How We Use Information

We use the information we collect for purposes including:

• Responding to your inquiry and communicating with you
• Verifying your status as an Accredited Investor as required by SEC Rule 506(c)
• Providing offering documents, including Private Placement Memoranda and subscription documents, where eligible
• Maintaining records required by securities, anti-money-laundering, and tax laws and regulations
• Detecting and preventing fraud, security threats, and prohibited activity
• Complying with legal, regulatory, and contractual obligations
• Operating, maintaining, and improving our Site

4. How We Share Information

We may share your information in the following circumstances:

Service Providers

With third-party service providers who perform services on our behalf, including fund administrators, accreditation verification services, identity verification providers, cloud hosting and email services, accounting and tax advisors, and legal counsel. These providers are contractually obligated to use information solely for the purposes of providing services to us.

Affiliates

With our affiliates, including the investment vehicles managed by 6116 Partners and affiliated technology service providers (such as 6116.AI LLC), where appropriate for operational, compliance, and reporting purposes.

Legal and Regulatory Disclosures

To regulators, courts, or government authorities where we believe in good faith that disclosure is required by applicable law, regulation, legal process, or governmental request, including disclosures to the U.S. Securities and Exchange Commission, the Commodity Futures Trading Commission, the Financial Crimes Enforcement Network, or state securities regulators.

Business Transfers

In connection with a merger, acquisition, financing, reorganization, sale of assets, or similar transaction, where information may be transferred to a successor entity subject to terms substantially similar to this Policy.

We do not sell personal information for monetary or other valuable consideration.

5. Data Retention

We retain personal information for as long as necessary to fulfil the purposes for which it was collected and to satisfy legal, regulatory, accounting, and reporting requirements. Information related to investor relationships, accreditation verification, and subscription activity is generally retained for at least seven (7) years following the conclusion of any relationship, in accordance with SEC and IRS recordkeeping requirements applicable to private investment funds.

6. Data Security

We implement reasonable administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, disclosure, alteration, and destruction. No method of internet transmission or electronic storage is fully secure, and we cannot guarantee absolute security. You acknowledge that you transmit information to us at your own risk.

7. Your Rights

U.S. Residents

Depending on the U.S. state in which you reside, you may have certain rights regarding personal information, which may include rights to access, correct, delete, or obtain a copy of your personal information, and to opt out of certain processing activities. California residents may have additional rights under the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA).

EEA, UK, and Other Jurisdictions

Although our Site is directed to U.S. Accredited Investors, residents of the European Economic Area, United Kingdom, and certain other jurisdictions may have additional rights under local data protection laws. Please contact us if you wish to exercise such rights.

To exercise your rights, please contact us using the information in Section 11. We may require verification of your identity before responding to a request, and certain rights may be limited where information is required to be retained for legal or regulatory reasons.

8. International Transfers

We are based in the United States and process information in the United States. If you access our Site from outside the United States, you understand that your information will be transferred to and processed in the United States, which may have data protection laws that differ from those in your country of residence.

9. Children’s Privacy

Our Site and services are intended exclusively for adult Accredited Investors. We do not knowingly collect personal information from individuals under the age of 18, and if we learn that we have collected such information, we will delete it.

10. Changes to This Policy

We may update this Privacy Policy from time to time. When we do, we will revise the “Effective” date at the top of this Policy. Material changes will be communicated through a notice on our Site or, where required, by direct communication to known investors. Your continued use of the Site after the effective date of any update constitutes acceptance of the updated Policy.

11. Contact Us

For questions about this Privacy Policy, to exercise your rights, or to make any privacy-related request, please contact us through the contact form on our home page. Inquiries are routed to our General Partners.