Privacy Policy

1. Scope and Controller

This Policy applies to personal data processed by RSFM in connection with our capital advisory mandates, thought leadership, events, and platforms located at radiantsoaringfm.com. Radiant Soaring Fund Management LLC, headquartered at 30 N Gould St Ste R, Sheridan, WY 82801, acts as the data controller unless we state otherwise.

We operate in multiple jurisdictions and maintain governance procedures to align with the privacy expectations of institutional investors, corporate counterparties, and regulatory authorities.

2. Categories of Personal Data

The data we process depends on how you engage with us and may include the following categories:

• Professional identifiers: name, title, organisation, contact details, and jurisdiction of residence.
• Engagement records: notes from consultations, mandate documentation, diligence materials, and communications history.
• Digital interaction data: device, browser, and IP information, site usage analytics, and preferences derived from cookies or similar technologies.
• Third-party insights: compliance screening outputs, public and proprietary database checks, and professional references obtained in accordance with law.

3. Purposes of Processing

We use personal data to:

• structure and execute investment or corporate finance mandates;
• communicate analyses, reporting updates, and market intelligence;
• perform diligence, suitability, anti-money-laundering, and sanctions checks;
• manage events, subscriptions, and professional networks;
• administer, secure, and enhance our digital interfaces; and
• meet legal, regulatory, audit, and risk governance obligations.

4. Lawful Bases

Where required, processing is grounded in one or more lawful bases: performance of a contract, legitimate interest in operating our advisory practice, compliance with legal duties, protection of vital interests, or your explicit consent. We evaluate and balance legitimate interests against potential impacts on your rights.

5. Information Sharing

We disclose personal data to trusted recipients subject to confidentiality:

• affiliates and portfolio entities assisting with mandate execution or risk oversight;
• professional advisers, placement agents, technology vendors, data hosts, and analytics partners that support our operations;
• regulators, auditors, and legal authorities where required or to safeguard our rights; and
• potential transaction counterparties under strict confidentiality frameworks.

We do not sell personal data, nor do we allow service providers to use it for their own unrelated marketing.

6. International Data Transfers

Transfers outside your home jurisdiction may occur when leveraging our global infrastructure or third-party platforms. We apply safeguards such as standard contractual clauses, intra-group agreements, or other mechanisms recognised by the relevant authorities to protect transferred data.

7. Safeguards

RSFM maintains layered administrative, technical, and physical controls to protect personal data against unauthorised access, alteration, or loss. These measures include restricted access, secure infrastructure, encryption, incident response protocols, and continual monitoring of cyber and operational risks.

8. Retention

We retain personal data only as long as required to fulfil the purposes described in this Policy, satisfy legal or regulatory obligations, maintain accurate records, and resolve disputes. Retention schedules differ depending on mandate type and regional requirements.

9. Marketing Preferences

We may send briefings or event invitations aligned with your role or interests. You can adjust preferences or opt out at any time via unsubscribe links or by emailing privacy@radiantsoaringfm.com. Transactional or service notices will continue where permitted by law.

10. Your Rights

Depending on your jurisdiction, you may have rights to access, correct, restrict, delete, or object to the processing of your personal data, as well as to request data portability. We will respond to verifiable requests within the timelines required by applicable regulation and may request supporting information to confirm your identity.

11. Cookies and Analytics

We use cookies, pixels, and related technologies to deliver secure functionality and measure engagement. More detail, including ways to manage your preferences, is available in our Cookie Policy.

12. Updates

We review this Policy periodically. Significant changes will be communicated through our website or, where appropriate, through direct outreach. The "Last updated" date reflects the latest revision.

13. Contact

Questions regarding this Policy or your personal data can be directed to our privacy office using the details below.