Privacy Policy

Effective Date: 26/11/2025

Our Commitment to Your Privacy

This Privacy Notice sets out how Cloudberry I LP and any other funds that may be established and managed from time to time (together, the “Funds”), Allocator One Limited (the “Manager”), Cloudberry Ventures and certain other parties, including the Funds’ administrators (the “Administrators”) and any providers of know-your-customer and anti-money laundering services (the “KYC/AML Service Providers”), will process your personal data in connection with the Funds.

The Funds, the Manager, Cloudberry Ventures, the Administrators and the KYC/AML Service Providers (in their capacity as such with respect to the Funds) are collectively referred to in this Privacy Notice as “Cloudberry”, “we”, “us” or “our”.

This Privacy Notice is intended for individual investors, as well as certain individuals associated with investors who are not individual investors, in the Funds. This Privacy Notice also applies to visitors to our website, www.cloudberry.ventures, our investor portal, and any other website that we own or control and which posts this Privacy Notice (collectively, the “Sites”).

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As used herein, the term “personal data” includes “personal information” as defined in the California Consumer Privacy Act, as amended by the California Privacy Rights Act (the “CCPA”), and “personal data” as defined in the EU General Data Protection Regulation (the “EU GDPR”) and the EU GDPR as incorporated into the laws of the United Kingdom (the “UK GDPR” and, together with the EU GDPR, the “GDPR”). Personal data will be processed in compliance with the requirements of the GDPR, the CCPA and any other relevant data protection legislation which may be applicable (together, the “Data Protection Laws”).

Where your details are provided to Cloudberry as a consequence of your investment in the Funds, the relevant Fund, acting as a data controller, may itself or through a third party such as the Manager, a KYC/AML Service Provider or the Administrators, process your personal data or that of your directors, officers, employees and/or beneficial owners. When processing such personal data, there may also be times where the Manager, the Administrators or a KYC/AML Service Provider will act as a data controller.

We are sensitive to the privacy concerns of our investors. We are providing this Privacy Notice to investors who are individuals (whether they invest directly in their own names or through entities) to help them better understand why and how we collect certain personal data, how we protect the information we collect, and under what circumstances we may share or otherwise use such information. We will only use such personal data as set out in this Privacy Notice.

If you are not an individual investor, please provide this Privacy Notice to any and all individuals whose personal data is provided in connection with your investment (for example, directors, officers, employees and/or beneficial owners).

Where we require your personal data to comply with anti-money laundering or other legal or regulatory requirements, failure to provide this information means that Cloudberry may not (or may no longer) be able to accept you as an investor in the Funds.

Personal Data Collected

Cloudberry and its respective service providers will collect and process personal data provided by investors in relation to an investment in the Funds (including through completion of subscription documentation) and/or in the course of operating the Funds or the Sites, including, without limitation:

first name, last name and other identifiers;
residential or business address, e-mail address, telephone number and other contact details;
demographic information;
correspondence with you;
date and place of birth, citizenship and profession;
identity documents (such as passports, national identity cards, driving licences, proof of address);
information relating to assets, income, sources of wealth and tax status;
tax identification numbers and other tax details;
capital account balances;
account and transaction data; and
information about participation in other investments or funds.

We may also obtain personal data about criminal convictions or offences concerning investors’ representatives, authorised signatories, shareholders, members, partners, underlying investors or beneficial owners from publicly available and accessible registries and sources, and third-party databases used to perform due diligence and other screening activities.

Data collected when you use the Sites
When individuals visit the Sites, we may automatically log the following information:

Device Information
The manufacturer and model, operating system, browser type, IP address, and unique identifiers of the device you use to access the Sites. The information we collect may vary based on your device type and settings.

Usage Information
Information about how you use our Sites, such as the types of content that you view or engage with, the features you use, the actions you take, and the time, frequency, and duration of your activities. We may use third-party analytics providers (for example, Google Analytics) to help collect and analyse usage information.

Location Information
We may derive a rough estimate of your location from your IP address when you visit our Sites. Depending on the choices you make on your mobile device, we may also collect and maintain a history of your precise location information using Wi-Fi and Bluetooth technologies, as well as your device identifiers and GPS coordinates. If you want to prevent the collection of your location information, please adjust your settings on your device.

This data will be processed for the purposes set out in the Our Data Collection and Use Practices section below.

Sources of Personal Data

In connection with forming, managing and operating the Funds and the Sites, we collect and maintain personal data (such as addresses, social security or national insurance numbers, and information about assets, income and sources of wealth) from the following sources:
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information we or our representatives receive from you in conversations, including over the telephone, in voicemails, through written correspondence, via e-mail, or information set out in subscription agreements, investor questionnaires, applications, KYC forms or such other documents as we may request to be completed in relation to the management or administration of any investment in the Funds, and any personal data provided by you by way of correspondence or interactions with us by phone, e-mail or otherwise;
client due diligence documentation we obtain or hold as part of our regulatory obligations;
information we obtain or hold about your transactions with us or others;
information we receive from you or third-party sources, including as necessary to comply with law and regulations that apply to us or entities in which we invest, which may include, among others:
- entities in which you or someone connected with you has an interest;
- your legal and/or financial advisors;
- other financial institutions who hold and process your personal data to satisfy their own regulatory requirements; or
- credit reference agencies and financial crime databases;
information we receive when you interact with us on social media platforms such as LinkedIn or other channels. When you interact with us on social media, we may receive personal data that you provide or make available to us based on your settings, such as your contact details. In addition, the companies that host our social media pages may provide us with aggregate information and analytics regarding the use of our social media pages; and
information captured on websites or portals operated by or for us or our affiliates, including registration information and any information captured automatically via “cookies” or other tracking technologies (such as local storage technologies and web beacons).

Our Data Collection and Use Practices

Lawful grounds for processing
Each of the Funds, the Manager, the Administrators and the KYC/AML Service Providers is entitled to hold and process your personal data on the following lawful grounds:

the processing is necessary for our legitimate interests, provided your interests and fundamental rights do not override our legitimate interests;
where you are a natural person, the processing is necessary to comply with our respective contractual duties to you under the terms of our subscription agreement or any agreement with you;
to comply with our legal and regulatory obligations;
on exceptional occasions, where we have obtained your consent or you have directed us to process the personal data; or
on rare occasions, where holding and processing your personal data is needed in the public interest.

Some of the grounds for processing described above will overlap and there may be several grounds which justify our use of your personal data.

Inaccurate or amended information
Please let us know if any of your personal data (including correspondence details) changes as soon as possible. Failure to provide accurate information or to update changed information may have a detrimental impact upon your investment or your returns from it. Failure to provide any information that is required for anti-money laundering or financial crime purposes, pursuant to automatic exchange of information agreements, or due to other legal requirements means that Cloudberry may not, or may no longer, be able to accept you as an investor in the Funds.

Purposes of processing
Information may be processed by Cloudberry (or any of our affiliates, agents, employees, delegates or sub-contractors) where necessary to comply with Cloudberry’s legal obligations, as needed for our legitimate interests indicated below, or where the processing is in the public interest. Specific purposes of processing include the following:

for identity verification and other anti-money laundering and financial crime checks and related actions for the purpose of preventing fraud or other financial crime, complying with statutory and regulatory requirements in relation to anti-money laundering and terrorist financing requirements including the Funds’ own in-house procedures. Such use is (A) necessary to perform obligations under the subscription agreement and to comply with legal obligations such as anti-money laundering laws and regulations; and (B) necessary for Cloudberry’s legitimate interest in preventing, detecting, investigating and prosecuting fraud and/or other criminal activity, and managing risks;
to facilitate the opening of an investor’s account with the Funds, and the management and administration of an investor’s holdings in the Funds and any related account, on an ongoing basis, which are necessary for the performance of the investor’s obligations under a subscription agreement, limited partnership agreement or side letter, including in respect of the processing of subscriptions, transfers, withdrawals and the payment of distributions;
for administering the business of Cloudberry in an efficient and proper manner, including conducting audits, implementing risk management processes, corporate governance, maintaining and monitoring IT systems and management of third-party service providers. Such processing is necessary for Cloudberry’s legitimate interests in managing risks and in the efficient management of the business;
for detecting, investigating and preventing internal and external breaches of internal policy and applicable law and regulation and establishing, exercising and defending legal rights. Such processing is necessary for Cloudberry’s legitimate interests in ensuring compliance with the Data Protection Laws, in managing risks and in the efficient management of the business;
to report tax-related information to tax authorities in order to comply with a legal obligation;
to correspond with you, including to send you direct marketing communications notifying you of fundraising initiatives and investment opportunities via email and other means. Where required by applicable laws, we may rely on your consent to send you direct marketing communications, or we may do so to pursue Cloudberry’s legitimate interests;
to provide, operate, maintain, and improve the Sites, to create new features and personalise your experience on the Sites. Such processing is necessary for Cloudberry’s legitimate interests;
to monitor and record calls and electronic communications, including in connection with:
(A) the verification of instructions;
(B) investigations and fraud prevention measures;
(C) crime detection, prevention, investigation and prosecution;
(D) enforcing and defending rights or remedies of Cloudberry or one of its affiliates, together with the rights or remedies of any third parties to whom we delegate any of our rights or responsibilities;
(E) pursuing the legitimate interests of Cloudberry in relation to such matters; or
(F) otherwise where monitoring or recording is in the public interest;
to disclose information to other third parties such as regulatory or tax authorities or service providers of Cloudberry, including auditors, legal counsel, regulatory authorities, advisers or technology providers, in order to comply with any legal obligations imposed on Cloudberry (including, for the avoidance of doubt, entities in which we invest) or in order to pursue the legitimate interests of Cloudberry;
to monitor and record calls for quality, business analysis, training and related purposes in order to pursue the legitimate interests of Cloudberry to improve its service delivery;
to update and maintain records and carry out fee calculations to pursue the legitimate interests of Cloudberry;
to carry out statistical analysis and market research to comply with our contractual duties and to pursue the legitimate interests of Cloudberry; and
to retain anti-money laundering and other records of individuals to assist with subsequent screening by the KYC/AML Service Providers, including in relation to your investment in other funds administered by such providers, in pursuance of their or their clients’ legitimate interests.

We do not sell or otherwise disclose your personal data for monetary or other valuable consideration. Nor do we process your personal data for cross-context behavioural advertising purposes.

We will only use your personal data for the purposes for which we collected it unless we reasonably determine that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your consent, in compliance with the above rules and where we can rely on another legal basis as set out above, where doing so is required or permitted by law or regulation.

Cloudberry does not make decisions about you based solely on automated processing of your personal data.

Links to Other Websites and Services

Our Sites may contain links to other websites and services that we do not operate or control. The information that you share with such third-party services will be governed by the specific privacy policies and terms of service of those sites and not by this Privacy Notice. By providing these links, we do not imply that we endorse or have reviewed these sites. Please contact the relevant services directly for information on their privacy practices and policies.

Our Sharing of Data and International Transfers of Data

We do not disclose any personal data about you, except to affiliates, relevant parties associated with portfolio investments and third-party service providers for everyday business purposes (such as to process transactions, maintain accounts, respond to court orders or legal investigations), as permitted by law or regulation, or at your direction. In particular, we may disclose your personal data as follows:
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to Cloudberry’s affiliates and third-party service providers, transfer agents, accountants, legal service providers, broker-dealers or custodians. These parties perform certain services and functions as required by or in connection with an investor’s investment and to ensure performance of the subscription agreement. Subject to Cloudberry’s permission and instructions, such parties may provide personal data to sub-processors;
to other service providers that assist Cloudberry in meeting business operations needs and as necessary in connection with an investor’s affairs, investment and the affairs of Cloudberry or for complying with legal obligations as described above. These parties include providers of services and functions such as hosting and cloud services and other information technology providers, email archiving services, production of investor notices and financial statements, providers of client relationship management, investment management, reporting software and other software used to meet business operation needs. Pursuant to Cloudberry’s instructions, these parties may access, process or store personal data in the course of performing their contractual duties;
to third parties such as other investment funds, bank account providers, managers, directors, officers, employees, attorneys, financiers (including senior lenders), auditors or any other service providers together with their respective advisers, agents and service providers in relation to the operations of Cloudberry;
to governmental, regulatory or tax authorities, or other investors/limited partners, including in connection with the disclosure of tax treatment and tax structure of the Funds and all related documentation relating to such tax treatment and tax structure, financial markets or other intermediaries or counterparties or courts, pursuant to applicable laws and regulations;
to prospective investors for the purposes of enabling others to make investments in the Funds; and
to retain anti-money laundering and other records of individuals to assist with subsequent screening by KYC/AML Service Providers, including in relation to your investment in other funds serviced by such providers, in pursuance of their or their clients’ legitimate interests.

We may also share your personal data over the course of a business transaction, such as with counterparties and others assisting with a merger, acquisition, financing, reorganisation, restructuring, bankruptcy, receivership, dissolution, asset sale, or similar transaction, and with successors or affiliates as part of or following that transaction.

International transfers
Personal data may be processed by us or our service providers in jurisdictions including (but not limited to) the United Kingdom, the European Economic Area, the United States and other countries in which our service providers operate. Data protection laws in such countries may be less stringent than or otherwise different from the data protection laws in your jurisdiction and therefore may not offer the same level of data protection.

When transferring personal data internationally, we shall comply with the requirements of the GDPR and any other applicable Data Protection Laws. Where required by applicable laws (for example, where personal data is being transferred to a country which is not recognised as providing adequate protection in your jurisdiction), we will ensure that appropriate safeguards are in place, such as standard contractual clauses or other lawful transfer mechanisms.

Retention of Information

Cloudberry will retain your personal data for as long as required in order for us to perform the services described above or carry out the purposes for which the information was collected, depending on the legal basis for which the information in question was obtained and whether additional legal or regulatory obligations mandate that we retain your personal data. We apply criteria to determine the appropriate periods for retaining personal data depending on its purpose, nature and sensitivity and any retention periods provided by applicable laws and regulations.

Former Investors

We maintain personal data of former investors and apply the same policies and procedures that apply to current investors.

Information Security

We consider the protection of personal data to be a sound business practice, and to that end we employ physical, electronic and procedural safeguards to protect your personal data in our possession or under our control from unauthorised access and use, unlawful processing, and accidental loss, destruction or damage, including security measures required to ensure compliance with laws and regulations.We will endeavour to store your personal data securely in accordance with accepted market standards, and may do so either electronically or manually.While we have taken reasonable care to implement appropriate technical and security measures, we cannot guarantee the security of your personal data (including in respect of any transmission over the internet, via email or via our websites), nor do we accept, to the fullest extent permitted by law, any liability for any errors in data transmission, machine, software or operating error or any other cause.

Your Choices and Rights

Marketing Communications
You may opt out of marketing-related communications by following the opt-out or unsubscribe instructions contained in the marketing communications we send you, or by contacting us as set out below.

Limit Online Tracking
Most browsers let you remove or reject cookies that we or our service providers may place on our Sites. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Some internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. Our Sites currently do not respond to “Do Not Track” or similar signals.

Personal Data Requests
Depending on your jurisdiction and subject to certain conditions and exceptions, you may have the following rights in relation to your personal data:
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the right to learn more about what personal data of yours is being processed, how and why such information is processed and the third parties who have access to such personal data;
the right to access your personal data;
the right to rectify/correct your personal data;
the right to restrict the use of your personal data;
the right to request that your personal data is erased/deleted;
the right to data portability (i.e. receive your personal data or have it transferred to another controller in a structured, commonly used, machine-readable format); and
the right to object to processing of your personal data or to direct us not to share your personal data with a non-affiliated third party.

Where you have provided your consent to processing for the purposes indicated above, you may withdraw your consent at any time (or otherwise exercise your aforementioned rights in relation to your personal data) by contacting us (see How to Contact Us below).

In order to comply with your request, you may need to provide us with personal data and other information to verify your identity and the nature of your request. Depending on your jurisdiction, you may designate an authorised agent to make a request on your behalf. We will require the authorised agent to have written authorisation confirming that authority.

Please note that in some circumstances, we may not be able to fully comply with your request, for example if we are required to retain certain information about you to comply with applicable laws and regulations or if the information is necessary in order for us to provide the services you requested. In particular, we, and our collection and processing of your personal data, may be governed by laws and regulations on anti-money laundering, fraud prevention, taxation and financial services.

We will not discriminate against you for exercising your rights. We will not deny you access to our services, or provide you a lower quality of services, if you exercise your rights.

You also have the right to lodge a complaint with the UK Information Commissioner’s Office (ICO), an EU data protection authority, or another relevant supervisory authority in the country of your usual residence, place of work or of the place of the alleged breach, if you consider that the processing of your personal data carried out by Cloudberry or any of our affiliates or third-party service providers has breached Data Protection Laws.

Changes to this Privacy Notice

We reserve the right to change this Privacy Notice, or any other relevant policies or procedures, at any time, in which case the “Effective Date” at the top of this Privacy Notice will be revised. The examples contained within this Privacy Notice are illustrations only and are not intended to be exclusive or exhaustive.

You may have additional rights in respect of data protection under other U.S., UK, EU or foreign laws (including those of states or other subdivisions) that may apply to you.

How to Contact Us

If you have any questions concerning this Privacy Notice or the policies, procedures, or rights referred to above, or our use of your personal data, our retention procedures or our security processes, please contact us at:

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Email: mahir@cloudberry.ventures (or your usual Cloudberry contact); and
Postal address (manager): Allocator One Limited, 7 Stone Street, Brighton, BN1 2HB, United Kingdom.
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