Privacy Policy

1. Who we are
2. What we collect
3. Where it comes from
4. How we use it
5. Who we share it with
6. We do not sell your information
7. Cookies and analytics
8. Email and text messages
9. How long we keep it
10. Security
11. Your choices and rights
12. State privacy rights
13. Visitors outside the United States
14. Children
15. Changes
16. Contact

1. Who we are

This site is operated by EquiDeFi Prometheus AI SPV, LLC, a Delaware limited liability company, acting through its manager, EDF Manager, LLC ("we", "us"). We are the party responsible for the personal information described in this policy. Contact details are in section 16.

2. What we collect

Contact information	Name, email address, phone number, and state or country, when you submit a form or contact us.
Investor qualification	Whether you identify as an accredited investor, your estimated commitment size, and, during subscription, the documentation needed to verify accredited status — which may include tax returns, brokerage or bank statements, or a written confirmation from a licensed attorney, CPA, broker-dealer or investment adviser.
Identity and screening	Legal name, address, date of birth, taxpayer or Social Security number, government-issued identification, and the results of identity, sanctions, anti-money-laundering and background screening.
Entity information	Where you invest through an entity, trust or retirement account: formation and authority documents, taxpayer identification number, and information about beneficial owners and authorised signatories.
Financial information	Income, net worth and source-of-funds information collected in the subscription documents, and the details of any transfer, wire, card, ACH or cryptocurrency payment. Full payment card numbers are handled by our payment processors and are not stored by us.
Communications	Messages you send us, and records of calls or meetings with investor relations.
Technical information	IP address, browser and device type, pages viewed, referring page, and time and date of access.

3. Where it comes from

Most of it comes from you directly. Some comes from third parties acting on our behalf or on behalf of the offering — identity verification and screening vendors, the EquiDeFi subscription platform, the placement agent, payment processors, and our hosting and email providers. Some technical information is collected automatically when you visit the site.

4. How we use it

We use personal information to respond to your enquiries; to determine and verify your eligibility to invest; to process and administer a subscription; to comply with legal obligations, including securities, anti-money-laundering, sanctions, tax and recordkeeping requirements; to communicate with you about the offering and, if you invest, about the Fund; to operate, secure and improve the site; and to establish, exercise or defend legal claims.

Verification of accredited investor status is not optional. Rule 506(c) requires us to take reasonable steps to verify that status, and to retain records demonstrating that we did so.

5. Who we share it with

We share personal information only as needed for the purposes above, with: the Manager and its affiliates, including EquiDeFi, Ltd.; the placement agent, Dominari Securities LLC; the manager and administrator of the third-party fund into which the Fund invests; identity verification, screening and accreditation vendors; payment processors, banks and any escrow agent; the Fund's accountants, auditors, tax preparers and legal counsel; technology providers that host the site, deliver email or provide analytics; and regulators, law enforcement or other parties where required by law, subpoena or legal process, or to protect our rights.

We may also share information in connection with a reorganisation, transfer or winding up of the Fund. We do not otherwise disclose personal information to third parties for their own purposes.

6. We do not sell your information

We do not sell personal information, and we do not share it for cross-context behavioural advertising. We do not rent or trade investor lists.

7. Cookies and analytics

The site uses cookies and similar technologies that are necessary for it to function and to keep it secure, and may use analytics to understand how the site is used in aggregate. You can block or delete cookies in your browser settings, though parts of the site may not work correctly if you do. Because we do not serve targeted advertising, we do not respond to browser "do not track" signals; where required by law, we honour opt-out preference signals such as Global Privacy Control.

8. Email and text messages

If you give us your email address we may send you information about this offering. Every marketing email includes an unsubscribe link. If you consent to text messages, message frequency varies, message and data rates may apply, and you can reply STOP to opt out or HELP for help. Phone numbers collected for text messaging are not shared with third parties for their marketing purposes. Opting out of marketing does not stop transactional messages about a subscription you have made.

9. How long we keep it

We keep personal information for as long as needed for the purposes described above and to meet legal, regulatory, tax and recordkeeping obligations, which for securities offerings and anti-money-laundering compliance generally extend for several years after the end of the relationship. Where we no longer need information, we delete it or de-identify it.

10. Security

We use administrative, technical and physical safeguards designed to protect personal information, including encryption in transit, access controls and vendor diligence. No method of transmission or storage is completely secure, and we cannot guarantee absolute security. Please do not send sensitive information such as taxpayer identification numbers or account numbers by unencrypted email; use the subscription platform instead.

11. Your choices and rights

You can decline to provide information, though we may then be unable to respond to you or accept a subscription. You can unsubscribe from marketing at any time. You may ask us to access, correct or delete personal information we hold about you, and we will honour those requests to the extent the law allows — but information we are required to retain for securities, tax or anti-money-laundering purposes cannot be deleted on request. We will not discriminate against you for exercising any privacy right.

12. State privacy rights

Residents of California, Colorado, Connecticut, Virginia and other states with comprehensive privacy laws may have rights to know what personal information we collect, to access or obtain a copy of it, to correct inaccuracies, to request deletion, and to appeal a denial. To exercise a right, contact us at [email protected]. We will verify your identity before responding, and you may use an authorised agent where the law permits.

Note that much of the information we collect in connection with a subscription is subject to the Gramm-Leach-Bliley Act and related financial privacy rules, and is exempt from certain state privacy law rights. Where an exemption applies, we will tell you.

13. Visitors outside the United States

This site is operated in the United States and is directed to United States investors. If you access it from elsewhere, your information will be transferred to and processed in the United States, where data protection law may differ from that of your jurisdiction. Nothing on this site is an offer in any jurisdiction where such an offer would be unlawful.

14. Children

This site is not directed to anyone under 18, and we do not knowingly collect personal information from children. If you believe a child has provided us information, contact us and we will delete it.

15. Changes to this policy

We may update this policy by posting a revised version with a new effective date. Where changes are material, we will take reasonable steps to notify you.

16. Contact

Privacy questions and requests: [email protected], EquiDeFi Prometheus AI SPV, LLC, c/o EDF Manager, LLC.