Privacy Policy

1. Who We Are

Kasu Capital is the general partner of Kasu Capital US Real Estate Fund LP (the "Canadian Fund") and the managing member of Kasu Capital US Real Estate Fund II LLC (the "American Fund", and together the "Funds"). Our principal office is at 25 Main St W, Unit 500, Hamilton, ON L8P 1H6, Canada.

2. Information We Collect

We collect personal information in connection with your investment in, or interest in investing in, the Funds, including:

• Identity information: full legal name, date of birth, government-issued ID
• Entity information: corporation / partnership name and registration details
• Tax identification: SIN, BN, SSN, or EIN (encrypted at rest)
• Contact information: email address, phone number, mailing address
• Financial information: investment amount, banking details for distributions
• Accreditation information: income, net worth, or third-party verification letters
• AML/KYC information: PEP/HIO status, sanctions screening results
• Usage data: login activity, portal session data

3. How We Use Your Information

We use your personal information to:

• Verify your identity and accredited investor status
• Comply with anti-money laundering obligations (FINTRAC / PCMLTFA; FinCEN / BSA)
• Administer your investment account and process distributions
• Issue tax reporting documents (T5, K-1)
• Communicate fund updates, distribution notices, and investor reports
• Meet our legal obligations under applicable securities laws
• Detect and prevent fraud or unauthorized access

4. Sharing Your Information

We do not sell your personal information. We share it only:

• With our service providers (fund administrator, transfer agent, legal counsel, auditors, tax preparers) who are contractually bound to protect it
• With regulators, tax authorities, or law enforcement where required by law
• As necessary to process wire transfers or ACH payments (banking partners)
• With your consent for any other purpose

US investors (Reg S-P): We do not share your nonpublic personal information with non-affiliated third parties for marketing purposes. You have the right to opt out of sharing with affiliated entities for marketing by contacting us at privacy@kasucapital.com.

5. Data Retention

We retain your personal information for the duration of your investment and for seven (7) years thereafter, or longer if required by applicable law or regulation (e.g., FINTRAC requires a minimum of 5 years for AML records; securities regulations may require longer retention).

6. Security

We implement administrative, technical, and physical safeguards to protect your personal information, including encryption of sensitive fields (tax IDs) at rest, TLS in transit, role-based access controls, and row-level security on our database. No system is 100% secure; please notify us immediately if you suspect unauthorized access.

7. Your Rights

Canadian investors (PIPEDA): You have the right to access your personal information, request corrections, and withdraw consent (subject to legal and contractual restrictions).

US investors (Reg S-P): You have the right to receive this privacy notice annually and to opt out of certain information sharing as described above.

To exercise any of these rights, contact us at privacy@kasucapital.com.

8. Cookies

Our website uses session cookies required for authentication. We do not use third-party advertising or tracking cookies. Analytics, if any, are privacy-preserving and do not transmit personal identifiers to third parties.

9. Changes to This Policy

We will notify investors of material changes to this policy by email and by updating the version date above. Continued use of this website after a policy update constitutes acknowledgement of the new version.

10. Contact

For privacy-related inquiries or to exercise your rights, contact our Privacy Officer at privacy@kasucapital.com or write to: Kasu Capital, 25 Main St W, Unit 500, Hamilton, ON L8P 1H6, Canada. We will respond to access requests within 30 days.