8 December 2025

Privacy Policy

Oceancrest Capital (“Oceancrest,” “we,” “us,” or “the firm”) is committed to protecting the privacy of individuals whose personal data we process. This policy explains how we collect, use, store, and protect personal data in connection with our website and our asset management services, and the rights available to you under the Cayman Islands Data Protection Act (2021 Revision) (the “DPA”).


01 Who we are




Oceancrest Capital is an asset management firm domiciled in the Cayman Islands and regulated by the Cayman Islands Monetary Authority (CIMA). For the purposes of the DPA, Oceancrest acts as a data controller in respect of the personal data described in this policy. Our registered office is at [REGISTERED ADDRESS], Cayman Islands.


02 The data we collect




Depending on your relationship with us, we may collect and process the following categories of personal data:
  • Identity and contact data — name, job title, organisation, email address, telephone number, and postal address.
  • Investor due diligence data — information collected to meet our regulatory and anti-money-laundering obligations, including identification documents, source of funds information, and investor qualification status.
  • Correspondence data — records of your communications with us, including enquiries submitted through our website.
  • Technical data — IP address, browser type, device information, and website usage data collected through cookies and similar technologies.



03 How we use your data




We process personal data for the following purposes:

To respond to enquiries and provide information about the Total Return Fund and our services to qualified and institutional investors. To carry out investor onboarding, suitability assessment, and ongoing relationship management. To comply with our legal and regulatory obligations, including those administered by CIMA and applicable anti-money-laundering legislation. To operate, maintain, and improve our website. Under the DPA, our processing is justified on the basis of one or more lawful conditions, including the performance of a contract, compliance with a legal obligation, and our legitimate interests in operating and promoting the firm to eligible investors.


04 Disclosure of your data




We may share personal data with [SERVICE PROVIDERS — e.g. fund administrator, auditor, legal advisors, IT providers] where necessary for the purposes set out above. Where we engage third parties to process personal data on our behalf, we require them to do so under appropriate contractual safeguards. We may also disclose personal data where required to do so by law or by a regulatory authority.


05 International transfers




Given the international nature of our investor base and service providers, personal data may be transferred to, and processed in, jurisdictions outside the Cayman Islands. Where such transfers occur, we take steps intended to ensure your personal data continues to be protected to a standard consistent with the DPA.


06 Data retention




We retain personal data for as long as necessary to fulfil the purposes for which it was collected, including to satisfy any legal, regulatory, accounting, or reporting requirements. Retention periods for investor records are determined by applicable Cayman Islands regulatory requirements.


07 Your rights under the DPA




Subject to the conditions and exemptions set out in the DPA, you have the right to: Be informed about how your personal data is used. Request access to the personal data we hold about you. Request the correction of inaccurate or incomplete data. Request that we stop or restrict processing in certain circumstances. Require that we do not make decisions about you based solely on automated processing. Complain to the Office of the Ombudsman, which oversees data protection in the Cayman Islands.


08 Cookies




Our website uses cookies and similar technologies to function and to help us understand how the site is used. You can manage your cookie preferences through your browser settings or our cookie consent tool. For more detail, see our [COOKIE POLICY LINK].


09 Changes to this policy




We may update this policy from time to time. The current version will always be available on this page, with the “last updated” date revised accordingly.


10 Contact us




For any questions about this policy, or to exercise your rights under the DPA, please contact us:

Oceancrest Capital Attn: Data Protection contact

[PRIVACY CONTACT EMAIL] [REGISTERED ADDRESS] Cayman Islands

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