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Privacy

Privacy policy

What we collect, why, and how it is protected — stated plainly. Effective 10 August 2026.

Who we are

This website is operated for Equisculpt Novem Fund (the brand name of Novem Prime Incorporated VCC Sub-Fund, Mauritius). Contact for privacy matters: ir@novemfund.com.

What we collect, and why

We collect personal information only when you give it to us through this website’s forms, and we use it solely for the purpose you gave it:

  • Meeting requests — name, email, investor type, country, indicative amount: to arrange and follow up the meeting.
  • Deck requests — name, email, phone: to deliver the document and follow up your interest.
  • Qualification requests — the details and declarations you submit: to assess eligibility and respond.
  • Data-room access — email, sign-in events, document access: to control access, watermark documents and maintain the fund’s audit trail.
  • Onboarding / KYC — identity, tax and source-of-funds information and documents, where you proceed to subscribe: to meet the fund’s legal AML/KYC, FATCA and CRS obligations.

What we do not do

We run no advertising, no third-party trackers, no social pixels, and we do not sell or rent personal information. Site usage measurement is first-party and minimal (page paths only — see the cookie policy).

Sharing

Information is shared only with the fund’s service providers where necessary to serve you (the administrator for KYC verification, the investment manager for investor relations), and with regulators or authorities where the law requires it. All providers are bound by confidentiality.

Security & retention

Data is transmitted over TLS, stored on access-controlled infrastructure, and sensitive documents are held outside the public web space with access logged. We retain information for as long as needed for the purpose collected, and longer where fund regulation requires records to be kept (AML/KYC records in particular carry statutory retention periods).

Your rights

You may ask what personal information we hold about you, ask for corrections, or ask for deletion (which we will honour except where regulation requires retention). Write to ir@novemfund.com and we will respond within a reasonable period. Rights under the law of your own jurisdiction may also apply.

This policy is maintained under the fund’s compliance review and may be updated; the effective date above changes when it is.