Privacy Notice

Moto Capital Group, Inc. (“we” or “Moto”) We have adopted this Privacy Notice with recognition that protecting the privacy and security of the nonpublic personal information we obtain from you is an important responsibility. We do not disclose nonpublic personal information about you to third parties other than as described below. This notice is to provide you with information on our use of your personal data in accordance with US state and federal privacy laws as well as the Data Protection Law, 2017 of the Cayman Islands (“DPL”). Specifically under the DPL, in our use of your data, Moto will be characterized as a "data controller". Moto’s affiliates, delegates and service providers may act as "data processors" for the purposes of the DPL.

WHAT INFORMATION WE COLLECT – We collect nonpublic personal information about you (such as name, address, social security number, tax ID number, assets, income, investment objectives and experience, transaction history, wire instructions etc.) through various means in connection with our providing services to you. For example, we may collect this information through communication with you, from documents you deliver to us and in the course of providing services to you. We may also collect this information electronically through your use of this website. We may also collect your personal information from other sources, such as our affiliates or other non-affiliated companies.

HOW WE USE THIS INFORMATION – We may use the nonpublic personal information we collect from you for our everyday business purposes. These purposes may include responding to your inquiries, providing services to you, opening an account for you, processing transactions for your account, marketing products and services to you, or otherwise in furtherance of our business. Moto does not disclose nonpublic personal information about you other than as described herein. We have not sold nonpublic personal information within the last 12 months. Employees of Moto are provided access to such nonpublic investor information on a need-to-know basis.

WHAT INFORMATION WE DISCLOSE – We may provide your nonpublic personal information to our affiliates and to firms that assist us in servicing your account, such as a broker or fund administrator. We may also disclose such information to service providers and financial institutions with whom we have joint marketing arrangements (i.e., a formal agreement between nonaffiliated financial companies that together market financial products or services to you, such as placement agents). We require third-party service providers and financial institutions with which we have joint marketing arrangements to protect the confidentiality of your information and to use the information only for the purposes for which we disclose the information to them. Additionally, we may provide information to relevant government agencies including, but not necessary limited to, the Internal Revenue Service, the Securities and Exchange Commission, or the Cayman Islands Monetary Authority. We do not otherwise provide information about you to outside parties, except to our attorneys, accountants and auditors and as permitted by law. When we do share information, this may be to certain entities located outside your jurisdiction, including the US, the Cayman Islands or the Europe. Any transfer of data by us or our duly authorized delegates outside of the Cayman Islands shall be in accordance with the requirements of the DPL and other applicable privacy laws.

OPTING OUT – These above sharing practices are consistent with Federal privacy and related laws as well as similar laws in the Cayman Islands. In general, you may not limit our use of your’s personal information for these purposes under such laws. We note that the Federal privacy laws only give you the right to limit the certain types of information sharing that we do not engage in (e.g., sharing with our affiliates certain information relating to your transaction history or creditworthiness for their use in marketing to you, or sharing any personal information with non-affiliates for them to market to you).

SECURITY OF YOUR INFORMATION – To protect your nonpublic personal information from unauthorized access and use, we use security measures that comply with Federal law. These measures include physical, electronic and procedural safeguards. In addition to Federal private and related laws, certain states have adopted consumer privacy laws that may be applicable to investment advisers with clients who are residents of those states.

CHANGES TO OUR PRIVACY POLICY OR RELATIONSHIP WITH YOU – Our policy regarding obtaining and disclosing information may change from time to time. We will provide you notice of any material change to this policy before we implement the change.

WHO IS PROVIDING THIS POLICY NOTICE – This Privacy Notice is furnished to you by Moto Capital Group, Inc. and its affiliated entities.

Last updated July 1, 2020.