Keystone Capital Fund Inc. (collectively referred to herein as "Keystone Capital," "we," "our," or "us"), a corporation organized and existing under the laws of the Republic of Panama, recognizes the importance of protecting personal data we may collect from visitors and any other individual or entity ("Users," "you," or "your") who visit our website. This Privacy Policy applies to data collection by Keystone Capital and shall apply to your use of the website, www.keystonecapital.com (the "Site") and other Keystone Capital-related applications, software, communications, capabilities, and services ("Services") but excluding services that state that they are offered under a different privacy policy.

By using the Site, you signify your acceptance of this Privacy Policy. If you do not agree to this Privacy Policy, do not use the Site.

Our Privacy Policy applies to all of the Services offered by Keystone Capital, including our website, investor portals, newsletter communications, and any related applications or platforms.

Our Privacy Policy does not apply to services offered by other companies or individuals, including products or sites that may be displayed to you, linked from our Site, or operated by third-party service providers.

By accessing or using the Site in any manner, you also agree to be bound by Keystone Capital's Terms of Use (the "Agreement"). Please read the Agreement carefully. If you do not accept all of the terms and conditions contained in or incorporated by reference into the Agreement, please do not use the Site.

We collect information, including personal data, to provide better services to all our Users and to fulfill our legal and regulatory obligations. We use the term "Personal Data" to refer to any information that identifies or can be used to identify you. Common examples of Personal Data include: full name, email address, phone number, mailing address, government-issued identification, financial information, institutional affiliation, and certain metadata.

When you use our Services, we collect Personal Data in the following ways:

In order to use the Services, access certain parts of the Site, subscribe to our newsletter, submit an investor inquiry, or engage with our investment or advisory services, we may ask you to provide us with Personal Data about yourself, including:

• Your full legal name;
• Email address and phone number;
• Mailing address and country of residence;
• Organization or institutional name;
• Professional title and role;
• Investor accreditation or qualification status;
• Government-issued identification documents (for AML/KYC purposes);
• Source of funds and wealth information (for AML/KYC purposes);
• Tax identification numbers and tax residency information;
• Bank account or payment information; and
• Any other information you submit through forms, correspondence, or communications with us.

We collect certain information automatically, such as your operating system version, browser type, and internet service provider. We also collect information about your interaction with the Services, such as creating or logging into your account, or opening or interacting with the Services on your mobile device. When you use our Site, we automatically collect and store this information in service logs. This includes:

• Details of how you used our Site;
• Internet protocol (IP) address;
• Cookies that uniquely identify your browser;
• The referring web page and pages visited;
• Date, time, and duration of visits;
• Device type, screen resolution, and operating system;
• Geographic location data (derived from IP address); and
• Clickstream data and browsing patterns.

We may also collect and process information about your approximate location. The information we collect automatically is statistical data and may or may not include Personal Data, but we may maintain it or associate it with Personal Data we collect in other ways or receive from third parties.

We may receive Personal Data about you from third-party sources, including:

• Institutional partners and introducers who refer prospective investors or clients to us;
• Fund administrators and custodians involved in the servicing of our managed funds;
• Identity verification and compliance service providers who assist with AML/KYC screening;
• Publicly available sources, including corporate registries, sanctions lists, and professional networking platforms; and
• Your employer or organization, if they engage our services on your behalf or provide you access to our investor portal.

We and our partners use various technologies to collect and store information when you visit one of our services, and this may include using cookies or similar technologies to identify your browser or device. We also use these technologies to collect and store information when you interact with services from our partners, such as analytics and marketing services.

The types of cookies we may use include:

• Strictly necessary cookies — required for the operation of the Site and cannot be switched off;
• Analytics and performance cookies — allow us to recognize and count visitors and understand how visitors navigate the Site;
• Functionality cookies — enable enhanced functionality and personalization; and
• Targeting and advertising cookies — used to deliver content relevant to your interests and to measure the effectiveness of our communications.

You may manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the Site.

We use your Personal Data in ways that are compatible with the purposes for which it was collected or authorized by you, including for the following purposes:

• To present, operate, and improve the Site and Services, including analysis of Site activity;
• To inform you about Services, investment opportunities, research, and publications available from Keystone Capital;
• To authorize access to our Site, investor portal, and Services;
• To provide, maintain, administer, or expand the Services, including performing business analyses or other internal purposes to support, improve, or enhance our business and the services we offer;
• To process, evaluate, and respond to investor inquiries, subscription requests, and due diligence materials;
• To conduct know-your-customer (KYC), anti-money laundering (AML), sanctions screening, and other regulatory compliance checks;
• To verify your identity, accreditation status, and eligibility to invest;
• To administer and manage your investment in any fund managed by Keystone Capital, including processing subscriptions, redemptions, distributions, and capital calls;
• To prepare and distribute investor reports, account statements, tax documents, and other fund-related communications;
• To customize or tailor your experience of the Services;
• To communicate about, and administer your participation in, events, webinars, programs, and other Keystone Capital activities;
• To deliver newsletters, market commentary, research publications, and other communications you have opted in to receive;
• To improve our Site and Services;
• To secure our Services, including to authenticate Users and prevent unauthorized access;
• To use statistical information that we collect in any way permitted by law, including from third parties in connection with their commercial efforts;
• To respond to and support Users regarding their use of the Site and Services;
• To comply with all applicable legal, regulatory, and tax requirements;
• To enforce our Terms of Use and other agreements;
• To perform data analysis and testing;
• To investigate possible fraud, money laundering, or other violations of our Terms of Use or this Privacy Policy and/or attempts to harm our Users;
• To resolve disputes; and
• To otherwise fulfill the purpose for which the information was provided.

We will ask for your consent before using information for a purpose other than those set out in this Privacy Policy.

We do not sell your Personal Data to companies, organizations, or individuals outside of Keystone Capital. We may share Personal Data in the following circumstances:

We will share Personal Data with companies, organizations, or individuals outside of Keystone Capital when we have your consent to do so.

We may share your Personal Data with trusted third-party service providers who perform services on our behalf, including:

• Fund administrators — for fund accounting, investor record-keeping, and NAV calculation;
• Custodians and prime brokers — for the safekeeping and settlement of fund assets;
• Auditors — for the annual audit of our managed funds;
• Legal counsel — for legal advice and compliance purposes;
• Compliance and identity verification providers — for AML/KYC screening and sanctions checks;
• Technology providers — for hosting, IT support, data storage, and security services;
• Communication providers — for email delivery, investor communications, and CRM services; and
• Tax advisors and accountants — for tax reporting and compliance purposes.

All such service providers are bound by contractual obligations of confidentiality and are permitted to use your Personal Data only for the purposes for which it was shared.

If you were introduced to Keystone Capital by a third-party intermediary, placement agent, or institutional partner, we may share limited information regarding your investor status and relationship with us as necessary to manage that commercial relationship.

We will share Personal Data with companies, organizations, or individuals outside of Keystone Capital if we have a good-faith belief that access, use, preservation, or disclosure of the information is reasonably necessary to:

• Meet any applicable law, regulation, legal process, or enforceable governmental request, including requests from tax authorities, securities regulators, or law enforcement agencies in Panama or any other relevant jurisdiction;
• Enforce applicable Terms of Use, including investigation of potential violations;
• Detect, prevent, or otherwise address fraud, money laundering, security, or technical issues;
• Protect against harm to the rights, property, or safety of Keystone Capital, our Users, our investors, or the public as required or permitted by law.

Keystone Capital may compile and share your information in aggregated form (i.e., in a manner that would not personally identify you) or in de-identified form so that it cannot reasonably be used to identify an individual ("De-Identified Information"). We may disclose such De-Identified Information publicly and to third parties.

In the event of a merger, acquisition, reorganization, sale of assets, joint venture, or other business transaction involving Keystone Capital, your Personal Data may be transferred as part of such transaction. We will notify you of any such change in ownership or control of your Personal Data.

Your provision of Personal Data is required in order to use certain parts of our Services, to subscribe to our funds, or to engage our advisory services. If you fail to provide such Personal Data, you may not be able to access and use our Services, invest in our funds, or parts of our Services.

In particular, we are legally required to collect certain Personal Data for AML/KYC and regulatory compliance purposes. If you do not provide such information, we will be unable to accept your investment or provide you with certain Services.

We may retain your Personal Data for a period of time consistent with the original purpose for collection. For example, we keep your Personal Data for no longer than reasonably necessary for your use of our Services and for a reasonable period of time afterward. We also may retain your Personal Data during the period of time needed for us to pursue our legitimate business interests, conduct audits, comply with our legal obligations, resolve disputes, and enforce our agreements.

We retain your Personal Data even after your business relationship with us ends if reasonably necessary to:

• Comply with our legal and regulatory obligations, including record-keeping requirements under Panamanian law and the laws of any other relevant jurisdiction (including law enforcement requests);
• Meet regulatory requirements, including those of securities regulators and tax authorities;
• Resolve disputes;
• Maintain security;
• Prevent fraud and abuse;
• Enforce our Terms of Use;
• Fulfill your request to "unsubscribe" from further messages from us.

We will retain de-personalized information after your account has been closed.

As a general guideline, we retain investor records and fund-related Personal Data for a minimum of five (5) years following the end of your investment relationship with us, or longer if required by applicable law.

Depending on your jurisdiction, you may have certain rights in connection with Personal Data you have shared with us. These rights may include:

Some data protection laws, including the European Union's General Data Protection Regulation ("GDPR") and corresponding legislation in the United Kingdom, provide you with the following rights:

• The right to be informed. You are entitled to be informed of the use of your Personal Data. This Privacy Policy provides such information to you.
• The right of access. You have the right to request a copy of your Personal Data which we hold about you.
• The right of correction. You have the right to request correction or changes of your Personal Data if it is found to be inaccurate or out of date.
• The right to be forgotten. You have the right to request us, at any time, to delete your Personal Data from our servers and to erase your Personal Data when it is no longer necessary for us to retain such data. Note, however, that deletion of your Personal Data will likely impact your ability to use our Services and may not be possible where we are required by law to retain such data.
• The right to object (opt-out). You have the right to opt-out of certain uses of your Personal Data at any time.
• The right to data portability. You have the right to a "portable" copy of your Personal Data that you have submitted to us. Generally, this means your right to request that we move, copy, or transmit your Personal Data stored on our servers to another service provider's servers.
• The right to refuse to be subjected to automated decision making, including profiling. You have the right not to be subject to a decision and insist on human intervention if the decision is based on automated processing and produces a legal effect or a similarly significant effect on you.
• The right to lodge a complaint with a supervisory authority.

Under Panamanian Law No. 81 of March 26, 2019, on the Protection of Personal Data, you may have the right to access, rectify, cancel, or object to the processing of your Personal Data. To exercise these rights, please contact us using the information provided below.

If you reside in a jurisdiction that provides additional data protection rights (including certain U.S. states such as California, Virginia, Colorado, and Connecticut), you may have similar or additional rights with respect to your Personal Data. We will respond to your request in accordance with applicable law.

In some cases, our ability to uphold these rights for you may depend upon our obligations to process Personal Data for security, safety, fraud prevention reasons, compliance with regulatory or legal requirements, or because processing is necessary to deliver the services you have requested. Where this is the case, we will inform you of specific details in response to your request.

You may update or correct information about yourself by contacting us at the email address provided below. Please note that we may need to verify your identity before processing any request to change or delete your information.

By providing an email address on the Keystone Capital Site or Services, you agree that we may contact you in the event of a change in this Privacy Policy, to provide you with any Service-related notices, or to provide you with information about our investment strategies, research, events, invitations, or related communications.

For purposes of this Privacy Policy, "opt-in" is generally defined as any affirmative action by a User to submit or receive information, as the case may be.

We currently provide the following opt-out opportunities:

• At any time, you can follow a link provided in newsletters or other email messages (except for transactional, regulatory, or Service-related notices) received from us to unsubscribe from the service.
• At any time, you can contact us to unsubscribe from the service and opt-out of our right per your consent under the terms of this Privacy Policy to share your Personal Data for marketing purposes.

Notwithstanding anything else in this Privacy Policy, please note that we always reserve the right to contact you in the event of a change in this Privacy Policy, or to provide you with any Service-related, regulatory, or investor-related notices required by law or by the terms of your investment.

Keystone Capital is incorporated in the Republic of Panama and operates internationally. Your Personal Data may be transferred to, stored in, and processed in jurisdictions outside of your country of residence, including Panama and other jurisdictions where our service providers, affiliates, fund administrators, and custodians operate. These jurisdictions may not provide the same level of data protection as your home jurisdiction.

By using the Site and providing your Personal Data, you consent to such international transfers. Where required by applicable law, we will implement appropriate safeguards for cross-border transfers, including standard contractual clauses, adequacy decisions, or other legally recognized mechanisms.

Keystone Capital maintains administrative, technical, and physical safeguards designed to protect your Personal Data and information against accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use. These measures include:

• Encryption of sensitive data in transit and at rest;
• Access controls limiting Personal Data access to authorized personnel on a need-to-know basis;
• Regular security assessments and vulnerability testing;
• Secure data storage with reputable hosting and cloud service providers;
• Confidentiality agreements with employees and third-party service providers; and
• Incident response procedures to address data breaches promptly.

However, no method of transmission over the internet or method of electronic storage is completely secure. While we strive to protect your Personal Data, we cannot guarantee its absolute security.

The Site is not intended for use by children. We do not intentionally gather Personal Data about visitors who are under the age of eighteen (18). If you believe we have inadvertently collected Personal Data from a minor, please contact us immediately and we will take steps to delete such information.

Keystone Capital does not track its Users over time and across third-party websites to provide targeted advertising and therefore does not respond to Do Not Track (DNT) signals. However, some third-party sites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are visiting such sites, your browser may include controls to block and delete cookies, web beacons, and similar technologies, to allow you to opt out of data collection through those technologies.

California residents are entitled to contact us to request information about whether we have disclosed Personal Data to third parties for the third parties' direct marketing purposes. Under the California "Shine the Light" law, California residents may opt out of our disclosure of Personal Data to third parties for their direct marketing purposes. You may choose to opt out of the sharing of your Personal Data with third parties for marketing purposes at any time by submitting a request to us. California users may request further information about our compliance with this law by contacting us at the address below.

If you are a California resident, you may also have additional rights under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA), including the right to know what Personal Data we collect, the right to delete, the right to correct, and the right to opt out of the sale or sharing of Personal Data. To exercise these rights, please contact us using the information below.

Our Privacy Policy may change from time to time. We will provide notice on our Site in the event of material changes. We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your Personal Data. Your continued use of the Site following the posting of changes constitutes your acceptance of such changes.

If you have any specific questions about this Privacy Policy, wish to exercise your data protection rights, or have concerns about how your Personal Data is being handled, you can contact us at:

Keystone Capital Fund Inc.[Registered Address] Panama City, Republic of Panama

Email: info@keystonecapital.com

Last Updated: February 2026