Personal Data Privacy Policy

We collect the following personal information depending on your type of interaction
with the Mitrax Website:

1. Visitors
While portions of the Mitrax Website may be used without registration, your
use of the Services and much of the content on the Mitrax Website requires
registration. You may choose not to provide us with any personal information.
However, you may not use the portions of the Mitrax Website that require
your personal information and registration.
If you use our website as a visitor without registering or submitting inquiry
information to us, the only information we collect will be automatic tracking
information and information collected by cookies, which helps us understand
what you are seeing and responding to on our website.

1.1. Information We Collect Automatically

Even if you do not register on the Mitrax Website, we collect information
about your use of our Mitrax Website in order to further personalize the
content and information we present to you.

1.1.1. Cookies: “Cookies” are small computer files that are transferred to
your computer, mobile device or tablet and contain information such as:
a. User ID and User Preferences
b. pages you have visited and the activities you have performed while
using the website.
We use “session cookies” to personalize your experience on the website
and, if you create a password, we use “persistent cookies” to store your
password so that you do not have to re-enter it each time you visit the
website. We do not link the information stored in cookies to any of your
personal information that you submit while on the website. You can
block cookies or delete them from your browser; However, by disabling
cookies, you may not have access to all of the website’s features. You also
have the option to browse our website using free cookie blockers or the
“Incognito Mode” feature in Chrome. We do not have access to or control
over these cookies.

1.1.2. Traffic Data: We automatically track and collect the following
categories of information when you visit our website: (1) Internet Protocol
(IP) addresses; (2) domain servers; (3) computer, device, and connection
information, such as browser type and version, operating system, mobile
platform, and unique device identifier (UDID) and other technical
identifiers; (4) Uniform Resource Locator (URL) clickstream data,
including date and time stamp, referring and exit URLs, search terms
you used, and pages you visited or searched for on the Service; (5) in the
case of location-aware Services, the region, city, or town where your
device is located in order to provide you with content that is more
relevant to where in the world you are located; (5) referral source that
may have submitted you to the Mitrax Website; and (6) other
information associated with your browser and website interaction. If you
are using a mobile device or other device to visit the Mitrax Website, we
may collect device-related hardware information about you.

1.2. Registered users and prospects.

Registered users are those visitors to our website who register their personal
information to receive information and commercial communications
regarding our products and services.
By prospects, we mean those individuals or companies who have shared their
contact information with us, either through a form on the website, from
information collected at a commercial or marketing event, or have contacted
us directly.
For both prospects and registered users, we may collect the following
information:

1. Contact Information: Information that can personally identify you,
including, but not limited to, name, email address, telephone number,
and other contact information.
2. Professional Information: Information related to your work experience,
education, position, organization, management, among others.
3. Demographic Information: Your age, gender, country of residence, and
other demographic information.
4. Information of interest: To collect general information relating to your
business objectives, your investment interests, financial objectives and
user preferences and information about participation on the website
and at events.
We may also collect information that personally identifies you when you send
us emails or communicate with us (for example, when you send us email
communications or send us letters, or make inquiries on our website)

Use of Personal Information:

a. We use personal information to manage our relationship with you, including
responding to your questions and communicating on social media, providing
you with the specific Services you select.
b. Assessing your suitability as an investor: We collect and use your personal
information to assess whether you meet the Fund’s investment criteria.
c. Communicate: We collect and use your personal information to communicate
with you about our investment opportunities, events, and other relevant
information.
d. Comply with our legal and regulatory obligations: We collect and use your
personal information to comply with our legal and regulatory obligations.

1.3. Partners/Investors – Consumers

Partners or investors (the “Consumers”) are those persons who are
contractually or legally bound to the fund, so they have shared personal
information, by any means provided by Mitrax, mail, communications, form on
the website, or documents.

The personal information collected for Consumers is:

1. Contact Information: Information that can personally identify you,
including, but not limited to, name, email address, telephone number, and
other contact information,
2. Professional Information: Information related to your work experience,
education, position, organization, management, among others.
3. Information of interest: To collect general information relating to your
business objectives, your investment interests, financial objectives and user
preferences and information about participation on the website and at
events.
4. Financial information: Net worth, income, investors, and other financial
information.
5. Demographic Information: Your age, gender, country of residence, and
other demographic information.

Use of Personal Information:

a. We use personal information to manage our relationship with you,
including responding to your questions and communicating on social
media, providing you with the specific Services you select.
b. Communicate: We collect and use your personal information to
communicate with you about our investment opportunities, events, and
other relevant information.
c. Managing Our Investor Relations: We collect and use your personal
information to manage our existing investor relationships.
d. Comply with our legal and regulatory obligations: We collect and use
your personal information to comply with our legal and regulatory
obligations.

IV. Legal basis for processing

We will only process your personal data lawfully and will explain the specific
legal basis for which we process your data within this privacy policy. We will
not process your personal data further in a way that is incompatible with those
purposes.

Please note that in accordance with applicable Data Protection Law, your
personal data can be processed if:

● you have given us your consent for the purposes of the processing; or
● it is necessary for the performance of a contract to which you are a party;
or
● we have a legitimate interest that is not outbalanced by your privacy
rights; or
● it is required under a legal obligation to which we are bound.

For the avoidance of doubt, you will always have the right to withdraw
your consent at any time.

V. DISCLOSURE OF YOUR INFORMATION

By registering on our website, you agree that we may share certain categories
of information we collect from you in the ways described in this Privacy Policy.

We share personal information and traffic data with our business partners who
help us perform basic services (such as website hosting, data storage, and
security) related to our operation of the website and/or by making certain
services available to our users. Those business partners will be required to
maintain the same standards of security and confidentiality that we have
promised you in this Privacy Policy, and will only use your contact details and
other personal information to fulfill their specific business obligations and
provide you with website-related services, Mitrax does not share, sell, rent, or
trade your personal information with third parties for promotional purposes.

We reserve the right to disclose your personally identifiable information as
required by law and when we believe disclosure is necessary to protect our
rights or property, to mitigate our liability in an actual or potential lawsuit, to
comply with a judicial proceeding, court order, or legal process served on our
website, to enforce this Privacy Policy or our Terms of Use or any other
agreement in effect between you and Mitrax, or to investigate and prevent
unauthorized transactions or other illegal activities.

VI. PERIOD OF PROCESSING OF PERSONAL DATA.

Mitrax will only keep your personal data for as long as necessary for the
purposes for which we process your personal data or to comply with the law.
For information on how long certain personal data is likely to be kept before
being removed from our systems and databases, please contact us at the Data
Protection Contact.

VII. DECLARATIONS OF THE PROCESSING OF PERSONAL DATA.

Mitrax processes data under this Privacy Policy on the basis of (a) the user’s
consent as a condition of accessing this website; (b) the need for the data to
enter into a contract for Services; and/or (c) the need for the data for the
provision of the Services. IF YOU DO NOT CONSENT TO THE PROCESSING OF
YOUR DATA FOR THE PURPOSE OF ACCESSING AND USING THE WEBSITE,
PLEASE DO NOT USE OR INTERACT WITH THE WEBSITE.

7.1. Cross-border transfer.

The data centers that host your data under this Privacy Policy are located
inside and outside the United States. Accordingly, you consent to the
cross-border transfer of your data in order to receive access to the Mitrax
Website and/or Services.

VIII. HOW YOU CAN ACCESS, AMEND, OR DELETE YOUR PERSONAL DATA

If you wish to review, correct, update, delete, delete, or otherwise limit our use
of the personal data you have provided to us, you may submit a request by
contacting us using the email thrivecapital@mitraxcapital.com. For your
protection, we may need to verify that the request is valid. We will attempt to
comply with your request within a time consistent with applicable law.

If you completely delete all of this information, your account may be
deactivated. Please note that we may need to retain certain information for
recordkeeping purposes and/or to complete any transactions that are pending

IX. CHANGES TO THIS PRIVACY POLICY

We may occasionally make alterations to this policy which will reflect how we
process and look after your data. We reserve the right, at any time, to add,
change, update, or modify this Privacy Policy, so please review it frequently. If
we make a material change to our Privacy Policy, we will notify you by email,
here on this page, as well as by posting a notice on our website. In all cases, the
use of the information we collect is subject to the Privacy Policy in effect at the
time such information is collected. If you do not agree with any changes or
modifications to the Privacy Policy, please do not continue to use the Mitrax
Website. You will be deemed to have consented to any modification to the
Privacy Policy when you use the Mitrax Website after the effective date of the
modification.

X. CONTACT INFORMATION

If you have any questions about this Privacy Policy, or about your dealings with
this website, or would like to request access to or changes to our processing of
your data, or make a complaint, please contact us at
thrivecapital@mitraxcapital.com

Version 1, January 2025.