Privacy Policy

Effective Date: July 21, 2026

The Criterion Fund ("The Criterion Fund," "we," "our," or "us") respects your privacy and is committed to protecting the personal information you provide when using our website, communicating with us, or interacting with our services.

This Privacy Policy explains what information we collect, how we use it, how we protect it, and the choices available to you.

Information We Collect

We may collect personal information that you voluntarily provide to The Criterion Fund, including:

  • Name

  • Email address

  • Telephone or mobile number

  • Mailing address

  • Company name

  • Investment interests

  • Communication preferences

  • Information submitted through website forms, emails, telephone calls, event registrations, or other communications

  • Information necessary to respond to inquiries, schedule calls, provide requested information, or maintain our relationship with investors and prospective investors

When you visit our website, we or our service providers may automatically collect certain information, including:

  • IP address

  • Browser type

  • Device type and device identifiers

  • Operating system

  • Referring website or source

  • Pages viewed and interactions with our website

  • General location information derived from an IP address

  • Cookie, analytics, and advertising information

Investor Information

Individuals who choose to pursue an investment may be directed to a third-party investment-management platform. Through that platform, investors may be asked to provide information required to establish and administer an investor account, verify identity, evaluate eligibility or suitability, complete an investment, satisfy tax-reporting requirements, or comply with legal and regulatory obligations.

Depending on the investment and applicable requirements, this information may include:

  • Full legal name and contact information

  • Date of birth

  • Social Security number or other taxpayer-identification number

  • Government-issued identification

  • Mailing address and residency information

  • Employment or professional information

  • Bank-account or other financial information

  • Internal Revenue Service Form W-9 information

  • Net-worth, income, accreditation, suitability, or other investor-qualification information

  • Investment elections, transaction records, and account information

This information may be collected and maintained directly by the applicable third-party investment-management, financial, custodial, escrow, banking, identity-verification, or administrative provider rather than by The Criterion Fund through this website. The handling of information submitted directly to a third-party platform is also subject to that provider’s privacy policy and terms.

Sources of Personal Information

We may collect personal information:

  • Directly from you when you submit a form, contact us, register for an event, subscribe to communications, or otherwise provide information

  • Automatically through your use of our website

  • From our service providers, investor-management platform, analytics providers, advertising providers, or other business systems

  • From affiliates or companies involved in administering an investment or maintaining an investor relationship

  • From publicly available sources or social-media platforms when permitted by applicable law

How We Use Your Information

We may use personal information to:

  • Respond to inquiries and provide requested information

  • Schedule calls, meetings, or events

  • Communicate with investors and prospective investors

  • Maintain contact and investor records

  • Provide newsletters, company updates, educational materials, and marketing communications according to your preferences and consent

  • Provide transactional or informational communications

  • Evaluate investor eligibility or suitability

  • Facilitate access to third-party investor-management systems

  • Administer investments and investor relationships

  • Fulfill tax, accounting, legal, regulatory, and recordkeeping obligations

  • Operate, maintain, analyze, secure, and improve our website and services

  • Measure website traffic and the effectiveness of our communications and advertising

  • Detect and prevent fraud, misuse, security incidents, or unlawful activity

  • Enforce our agreements and protect our legal rights

  • Complete a merger, acquisition, financing, reorganization, sale, or other business transaction

  • Carry out any other purpose disclosed when the information is collected or permitted by law

SMS Communications

If you choose to opt in to receive SMS communications from The Criterion Fund, we may send you transactional, informational, and/or marketing text messages based on the consent you provide.

Transactional or informational messages may include appointment reminders, responses to inquiries, investor communications, account notifications, or other information you request.

Marketing messages may include investment opportunities, company news, educational content, event announcements, and other promotional communications.

Consent to receive marketing text messages is not a condition of purchasing any product or service or participating in an investment opportunity.

Message frequency may vary. Message and data rates may apply.

You may opt out at any time by replying STOP. For assistance, reply HELP or contact us at invest@thecriterionfund.com.

How We Share Personal Information

We do not sell personal information in exchange for money.

We may disclose personal information to service providers and other parties that help us operate our business or administer investor relationships, including:

  • Website-hosting and technology providers

  • Email and communications providers

  • SMS messaging providers

  • Customer-relationship-management providers

  • Investor-management and investor-portal providers

  • Analytics and advertising providers

  • Information-technology and cybersecurity providers

  • Professional advisers, including attorneys, accountants, auditors, consultants, and tax professionals

  • Banking, custodial, escrow, identity-verification, compliance, or administrative providers involved in an investment

  • Affiliates and business partners involved in providing requested services or administering an investment

  • Government agencies, regulators, courts, law-enforcement authorities, or other parties when required by law or reasonably necessary to protect legal rights

  • A successor or prospective successor in connection with a merger, acquisition, financing, reorganization, sale of assets, or similar business transaction

  • Other parties at your direction or with your authorization

Service providers are permitted to use personal information only as necessary to provide services on our behalf, subject to their contractual obligations and applicable law.

Notwithstanding anything else in this Privacy Policy, mobile information, text-messaging originator opt-in data, and SMS consent will not be shared, sold, rented, or disclosed to third parties or affiliates for marketing or promotional purposes. All categories of information sharing described in this Privacy Policy exclude text-messaging originator opt-in data and consent.

Mobile information may be disclosed to communications providers solely as necessary to operate and deliver our text-messaging program. Those providers may use the information only to perform services on our behalf and not for their own marketing or promotional purposes.

By using our website, you acknowledge that you have read and understand this Privacy Policy.