Privacy Policy

Effective date: January 1, 2026. This Privacy Policy describes how Beacon Acquisition and Capital Fund LP (the "Fund") and Portal Capital Management Trust (the General Partner) collect, use, disclose, and safeguard personal information collected through this website, the Investor Portal, the Advisor Portal, and related communications. Each of the Fund and the General Partner is a separate legal entity and, with respect to the personal information it collects in its own capacity, an independent data controller. References below to "we", "us", or "BACF" mean each entity acting in its respective capacity, not a single combined controller. Investment-management arrangements are governed by a separate written agreement; personal information handled by any investment manager in its own capacity is subject to that entity's separate privacy practices. Nothing in this Policy alters the separateness of the entities or the terms of the Limited Partnership Agreement or the Private Placement Memorandum.

Scope. This Policy covers personal information of website visitors, prospective investors, verified accredited investors, authorized advisors, and their authorized representatives. It supplements — and does not replace — the privacy notices delivered with the confidential Private Placement Memorandum, subscription documents, and the Limited Partnership Agreement.

1. Categories of Personal Information We Collect. (a) Identifiers such as legal name, mailing address, email address, telephone number, date of birth, government-issued identification numbers, and tax identification numbers. (b) Financial and accreditation information including bank account and wire instructions, source of funds, net worth and income representations, and accredited-investor verification materials. (c) Commercial information including subscription, capital call, distribution, and redemption activity. (d) Employment and professional information for advisors and authorized representatives. (e) Internet or network activity information including IP address, device identifiers, browser type, pages viewed, referring URLs, timestamps, and portal session logs. (f) Geolocation inferred from IP address at coarse (city/country) resolution. (g) Audio, electronic, or visual information from recorded investor calls and webinars where disclosed. (h) Sensitive personal information including Social Security or taxpayer identification numbers and financial account credentials used solely to administer the investment relationship. (i) Inferences drawn from the above solely to comply with anti-money-laundering, know-your-customer, sanctions-screening, and accredited-investor obligations.

2. Sources. We collect personal information directly from you (through forms, subscription documents, and the portals); from your authorized advisors; from identity-verification, accreditation, and background-check providers; from banks, custodians, and fund administrators; and automatically through cookies and server logs (see the Cookie Policy).

3. Purposes of Processing. We use personal information to: evaluate and administer subscription requests; verify accredited-investor status under Rule 506(c); perform KYC, AML, sanctions, and PEP screening required by the Bank Secrecy Act and USA PATRIOT Act; execute capital calls, distributions, and tax reporting (including Schedule K-1s); maintain investor records and communicate with investors and their advisors; secure the portals, detect and prevent fraud, and monitor for unauthorized access; comply with legal, tax, and regulatory obligations; enforce our agreements; and improve the website and portals in aggregate, de-identified form.

4. Legal Bases (EEA / UK residents — GDPR / UK GDPR). Where GDPR or UK GDPR applies, we rely on the following legal bases: performance of a contract (subscription documents and the Limited Partnership Agreement); compliance with legal obligations (AML/KYC, securities and tax law); our legitimate interests in operating and securing the Fund (balanced against your rights); and, where required, your explicit consent (for example, for optional marketing communications or the use of non-essential cookies).

5. Disclosures of Personal Information. In the preceding twelve months we have disclosed the categories above to: the Fund's administrator, auditor, custodian, prime broker, and legal counsel; identity, accreditation, and background-check vendors; email, hosting, analytics, and cybersecurity service providers acting as processors under written contract; affiliates that provide operational support to the Fund; and governmental and regulatory authorities where required by law, subpoena, or valid legal process. We do not sell personal information, and we do not share personal information for cross-context behavioral advertising as those terms are defined under the CCPA/CPRA.

6. Retention. Personal information is retained for the duration of the investment relationship and for the periods required by applicable law (generally at least five years after the closing of an investor's capital account under Investment Advisers Act recordkeeping rules; longer where required by tax, AML, or litigation-hold obligations). Records containing sensitive personal information are securely destroyed at the end of the applicable retention period.

7. Your Rights (California — CCPA / CPRA). California residents have the right to: (a) know the categories and specific pieces of personal information collected, the sources, purposes, and categories of recipients; (b) request deletion of personal information, subject to legal and regulatory retention exceptions; (c) request correction of inaccurate personal information; (d) limit the use of sensitive personal information to purposes permitted under the CPRA; (e) opt out of the sale or sharing of personal information (we do not sell or share as those terms are defined); and (f) be free from retaliation for exercising these rights. Submit requests to Help@Beaconfund.us or by mail to the address in the Contact page. We will verify your identity before responding and will respond within 45 days (extendable once by 45 days on notice).

8. Your Rights (EEA / UK — GDPR / UK GDPR). Data subjects in the EEA or UK have the right to access, rectify, erase, restrict, or object to processing of personal information; the right to data portability; and the right to withdraw consent where processing is based on consent. You also have the right to lodge a complaint with your local supervisory authority. Contact Help@Beaconfund.us to exercise these rights. We do not transfer EEA/UK personal information to third countries without appropriate safeguards (Standard Contractual Clauses or equivalent).

9. Authorized Agents. California residents may designate an authorized agent to submit requests on their behalf. We will require written proof of the agent's authority and may require you to verify your own identity directly.

10. Children. The website and the portals are not directed to children under 16, and we do not knowingly collect personal information from children.

11. Security. We maintain administrative, technical, and physical safeguards designed to protect personal information, including encryption in transit and at rest, role-based access controls, multi-factor authentication for the portals, audit logging, and vendor-security review. No system is fully secure; we cannot guarantee absolute security.

12. Cookies and Tracking. See the Cookie Policy for a description of cookies used on this website and the choices available to you. This website does not respond to Do-Not-Track browser signals; the Cookie Policy describes the controls we do honor.

13. Changes. We may update this Privacy Policy from time to time. Material changes will be posted on this page with a revised effective date and, where required by law, notified directly to investors of record.

14. Contact. Privacy questions and rights requests: Help@Beaconfund.us. Regulatory or compliance questions: Help@Beaconfund.us. Mailing address is available on the Contact page.