Terms of Use

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Keystone Capital Fund Inc. ("Keystone Capital," "we," or "us") provides its website located at [www.keystonecapital.co] (together with all other websites, mobile applications, and services operated by or on behalf of Keystone Capital Fund Inc., the "Site"), to you, an individual user ("you"), subject to compliance with the terms and conditions set forth herein.

1. Parties and Scope. These Terms of Use are a binding agreement between you and Keystone Capital Fund Inc., a corporation organized and existing under the laws of the Republic of Panama (referred to as "Keystone Capital," the "Company," "we," or "us"), together with its Affiliates. These terms, together with the risk disclosures set forth in Appendix A (the "Risk Disclosure Statement," and together with these terms, the "Terms of Use"), govern your access to and use of www.keystonecapital.co, including any related websites, applications, dashboards, interfaces, documentation, and all content, features, functionality, and services made available through them (collectively, the "Services") and the platform through which the Services are offered (the "Website").
    
2. Definition of an Affiliate. An "Affiliate" includes any firm, company, business entity, or other organization: which is directly or indirectly controlled by the Company; or which directly or indirectly controls the Company; or which is directly or indirectly controlled by a third party who also directly or indirectly controls the Company; or of which the Company or any Affiliate is a partner; of which the Company or any Affiliates referred to above owns or has a beneficial interest (whether directly or indirectly) in 20% or more of the issued share capital or 20% or more of the capital assets; or in respect of which the Company or any Affiliate provides or receives day-to-day administrative, operational, management, or support services pursuant to a service level agreement, management services agreement, or similar arrangement.
    
3. Acceptance and Binding Effect. You must carefully review these Terms of Use before accessing or using the Website or Services. By accessing, browsing, or otherwise using the Website or any Services, you confirm that you have read, understood, and agree to be legally bound by these Terms of Use. If you do not agree, you may not access or use the Website or Services.
    
4. Eligibility. The Website is intended only for individuals who are at least eighteen (18) years of age (or the age of legal majority in their jurisdiction, if higher) and who are not prohibited from using the Services under applicable law or these Terms of Use.
    
5. Geographic and Legal Restrictions. The Services and investment opportunities described on this Website are not offered to any individual or entity that is a resident, citizen, national of, or physically located in a Restricted Jurisdiction (as defined below), or to any person whose access or use would be unlawful or would cause Keystone Capital to violate any applicable law, regulation, sanction, or export control requirement.
    
6. Definition of Restricted Jurisdiction. "Restricted Jurisdiction" means any jurisdiction, country, territory, or region: (i) that is subject to economic sanctions, embargoes, or restrictive measures administered or enforced by the United Nations, the United States (including the Office of Foreign Assets Control), the United Kingdom, the European Union, the Republic of Panama, or any other applicable governmental authority; (ii) in which access to or use of the Website or Services would be illegal, restricted, or otherwise prohibited under applicable laws or regulations, including without limitation securities, commodities, financial services, consumer protection, or digital asset regulations; (iii) in which the provision of the Services would require Keystone Capital or any affiliate to obtain a license, registration, authorization, or approval from a governmental or regulatory authority that Keystone Capital does not hold; or (iv) that Keystone Capital determines, in its reasonable discretion, poses heightened legal, regulatory, compliance, enforcement, reputational, or sanctions risk.
    
7. Compliance. You bear sole responsibility for ensuring that your access to and use of the Website and Services complies with all applicable laws, rules, and restrictions in your jurisdiction. Keystone Capital makes no representation or warranty that the Website or Services are lawful, appropriate, or available in any particular location.
    

1. Amendments. Keystone Capital may modify or update these Terms of Use at any time, in its sole discretion. Any revisions become effective immediately upon posting and apply to all subsequent access to and use of the Website.
    
2. Continued Use. Your continued use of the Website following the posting of updated Terms constitutes your acceptance of the revised Terms. You are responsible for reviewing these Terms periodically to remain informed of any changes.
    

1. Availability and Changes. We reserve the right, at any time and without notice, to modify, suspend, discontinue, restrict, or withdraw the Website or any portion of the Services. Keystone Capital shall not be liable if any part of the Website or Services is unavailable for any reason or for any duration.
    
2. User Responsibilities. You are responsible for: (i) obtaining and maintaining all equipment, software, and connectivity necessary to access the Website and our Services; and (ii) ensuring that any individual accessing the Website or our Services through your internet connection complies with these Terms of Use.
    
3. Information Accuracy. Certain features of the Website may require you to provide information or submit requests. As a condition of your use, all information you provide must be accurate, current, and complete. Any such information is subject to our Privacy Policy and you consent to our collection and use of such information in accordance with that policy.
    
4. Account Security. If the Website provides you with any account credentials, login information, or access codes, you are solely responsible for safeguarding such credentials and for all activity conducted under your account. You must promptly notify us if you become aware of any unauthorized access to or use of your account.
    
5. Access Restrictions. Keystone Capital may, in its sole discretion and without obligation, restrict, suspend, or block your access to the Website at any time, including where your activity presents legal, security, compliance, or reputational risk, or violates these Terms or applicable law.
    

1. Informational Purpose. The Website serves as an informational resource regarding Keystone Capital's investment management, advisory, and private equity activities. The content provided on the Website is intended for general informational purposes only and does not constitute an offer to sell, a solicitation of an offer to buy, or a recommendation of any security, fund interest, investment product, or investment strategy.
    
2. Qualified Investors Only. Any investment opportunities described on the Website are available exclusively to qualified, sophisticated, institutional, or accredited investors as defined under applicable law and regulation, and are subject to separate subscription agreements, offering memoranda, and other definitive documentation. Nothing on the Website supersedes or modifies the terms of any such documentation.
    
3. No Public Offering. The Website does not constitute a public offering of securities or fund interests in any jurisdiction. Offers and sales of interests in any fund managed by Keystone Capital are made only pursuant to confidential offering documents provided directly to eligible investors and in compliance with applicable securities laws.
    
4. Service Evolution. The investment strategies, fund offerings, advisory services, and other activities described on the Website may change or evolve over time. Keystone Capital reserves the right to modify, discontinue, or launch new strategies and services without prior notice on the Website.
    

1. No Advisory Relationship. Unless you have entered into a separate, written advisory or investment management agreement with Keystone Capital, your use of the Website does not create an investment advisory, fiduciary, broker-dealer, or client relationship between you and Keystone Capital.
    
2. No Recommendations. All information, research, commentary, market analysis, or other content made available through the Website is provided for general informational and educational purposes only. Keystone Capital does not provide personalized investment recommendations, endorsements, opinions, or guidance regarding the suitability, desirability, or expected performance of any investment, strategy, or transaction through the Website.
    
3. Independent Decision-Making. You acknowledge that you are solely responsible for evaluating the merits, risks, suitability, and consequences of any investment or financial decision. You agree to seek independent professional advice — including legal, tax, financial, and investment counsel — as you deem appropriate prior to making any investment decision.
    
4. No Fiduciary Duty. Unless expressly established by a separate written agreement, you expressly acknowledge and agree that Keystone Capital does not act as your broker, intermediary, agent, adviser, custodian, trustee, or fiduciary by virtue of your use of the Website, and does not owe you any fiduciary duties, duties of loyalty, duties of care, suitability obligations, or similar duties arising from your access to or use of the Website.
    
5. No Offer or Solicitation. Nothing on the Website constitutes an offer, solicitation, recommendation, endorsement, or promotion to purchase, sell, hold, or dispose of any asset, security, commodity, derivative, fund interest, or financial product, or to engage in any particular investment strategy or transaction. Any such offer or solicitation will be made only pursuant to appropriate offering documents delivered directly to eligible investors.
    

1. General Risk Acknowledgment. All investments carry risk, including the potential loss of the entire amount invested. Past performance is not indicative of future results. No representation or warranty is made that any investment strategy, fund, or portfolio will achieve its objectives or avoid losses.
    
2. Digital Asset Risks. To the extent that Keystone Capital's strategies involve digital assets, cryptocurrencies, tokens, or blockchain-related investments, you acknowledge that such assets are subject to heightened risks, including but not limited to: extreme price volatility, limited or no liquidity, regulatory uncertainty, technology failures, cybersecurity risks, smart contract vulnerabilities, counterparty risk, and the potential for total loss of value.
    
3. Regulatory Risk. The regulatory environment for digital assets and alternative investments is evolving and uncertain across jurisdictions. Changes in laws, regulations, or government policy may materially and adversely affect the value of investments, the ability to transact, or the operations of Keystone Capital and its managed funds.
    
4. No Guarantees. Keystone Capital does not guarantee any rate of return, income, or capital preservation. Investments in any fund or strategy managed by Keystone Capital are speculative and involve a high degree of risk. Prospective investors should review all risk disclosures contained in the applicable offering documents before making any investment decision.
    

1. Fund Fees. Investments in funds managed by Keystone Capital are subject to management fees, performance fees, and other charges as set forth in the applicable offering memorandum, subscription agreement, or limited partnership agreement. Such documents govern and supersede any general descriptions of fees that may appear on the Website.
    
2. Third-Party Fees. Your investments may also be subject to fees, charges, or costs imposed by third parties, including custodians, administrators, brokers, exchanges, and blockchain networks. Keystone Capital does not control and is not responsible for such third-party fees.
    
3. Fee Changes. Fees applicable to specific funds or services may be amended from time to time in accordance with the terms of the relevant governing documents.
    

1. Ownership of Platform Materials. Except as expressly stated otherwise, the Website and all content, features, functionality, software, text, graphics, images, audio, video, design elements, research, analysis, compilations, selection and arrangement of materials, and underlying intellectual property rights (collectively, the "Platform Materials") are owned by or licensed to Keystone Capital and are protected by applicable copyright, trademark, patent, trade secret, and other intellectual property laws.
    
2. Limited License. Subject to your ongoing compliance with this Agreement, Keystone Capital grants you a limited, non-exclusive, non-transferable, non-sublicensable, revocable license to access and use the Website solely for your personal or internal business purposes.
    
3. Use Restrictions. Except as expressly permitted by this Agreement, you may not copy, reproduce, distribute, modify, adapt, create derivative works of, publicly display, publicly perform, republish, download (other than ordinary browser caching), store, transmit, or otherwise exploit any Platform Materials without Keystone Capital's prior written consent. You may not use any data mining, scraping, or similar automated means to access, collect, or extract data from the Website.
    
4. Research and Publications. Keystone Capital may publish research, analysis, market commentary, and other written content through the Website. Such materials are proprietary and protected by copyright. You may not reproduce, redistribute, or republish any such materials without Keystone Capital's prior written consent.
    
5. Feedback License. If you submit any suggestions, ideas, improvements, feedback, or other materials to Keystone Capital ("Feedback"), you grant Keystone Capital a perpetual, irrevocable, worldwide, royalty-free, fully paid-up, sublicensable right and license to use, reproduce, modify, distribute, display, perform, and otherwise exploit such Feedback for any lawful purpose without compensation or attribution.
    

The name "Keystone Capital," all associated logos, trademarks, service marks, trade dress, product names, and slogans are the exclusive property of Keystone Capital Fund Inc. or its licensors. Nothing in this Agreement grants you any right or license to use any such marks without Keystone Capital's prior written consent.

1. Authorized Use. Subject to your compliance with this Agreement and applicable law, you may access and use the Website solely for lawful purposes and for your personal informational use or legitimate professional evaluation of Keystone Capital's services and offerings.
    
2. Prohibited Activities. You agree that you will not, and will not attempt to, directly or indirectly:
    
   • access or use the Website in violation of any applicable law, regulation, sanctions program, export control requirement, or court order;
   • engage in money laundering, terrorist financing, fraud, deceptive practices, or any unlawful or abusive activity in connection with the Website;
   • interfere with, disrupt, degrade, or impair the operation, integrity, or security of the Website, including through the introduction of malware, denial-of-service attacks, excessive automated traffic, scraping, spamming, or similar conduct;
   • attempt to gain unauthorized access to any systems, networks, data, or accounts associated with the Website;
   • impersonate any person or entity or misrepresent your identity, affiliation, or authority;
   • use any robot, bot, scraper, crawler, automated script, or similar automated tool to access, collect, or extract data from the Website except where expressly authorized;
   • bypass, evade, defeat, or circumvent any access controls, geographic restrictions, technical safeguards, or usage limitations;
   • reverse engineer, decompile, disassemble, or otherwise attempt to derive source code or underlying structure of any portion of the Website except to the extent permitted by applicable law.

1. Enforcement and Remedies. Keystone Capital reserves the right, but does not assume the obligation, to investigate suspected violations, cooperate with law enforcement or regulators, restrict or terminate access, preserve or disclose information as required by law, and pursue any remedies available at law or in equity.
    

Your use of the Website is subject to our Privacy Policy, which describes how personal information is collected, used, stored, and disclosed in connection with the Website and Services. By using the Website, you consent to the collection and processing of your personal data in accordance with our Privacy Policy and applicable data protection laws, including the laws of the Republic of Panama.

1. As-Is Basis. THE WEBSITE, SERVICES, AND ALL CONTENT AND MATERIALS ARE PROVIDED ON AN "AS IS" AND "AS AVAILABLE" BASIS, WITH ALL FAULTS AND WITHOUT WARRANTIES OF ANY KIND, WHETHER EXPRESS, IMPLIED, OR STATUTORY.
    
2. Disclaimer of Implied Warranties. TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, KEYSTONE CAPITAL EXPRESSLY DISCLAIMS ALL IMPLIED WARRANTIES, INCLUDING WITHOUT LIMITATION ANY IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, TITLE, QUIET ENJOYMENT, NON-INFRINGEMENT, AND ANY WARRANTIES ARISING FROM COURSE OF DEALING, COURSE OF PERFORMANCE, OR USAGE OF TRADE.
    
3. No Representations as to Accuracy or Availability. WITHOUT LIMITING THE FOREGOING, KEYSTONE CAPITAL DOES NOT WARRANT OR REPRESENT THAT THE WEBSITE WILL BE CONTINUOUS, UNINTERRUPTED, ERROR-FREE, SECURE, ACCURATE, RELIABLE, OR FREE FROM DEFECTS, OR THAT ANY CONTENT, DATA, OR INFORMATION ON THE WEBSITE IS COMPLETE, CURRENT, OR FREE FROM ERRORS. KEYSTONE CAPITAL DOES NOT WARRANT OR REPRESENT THAT ANY INVESTMENT STRATEGY, FUND, OR PORTFOLIO WILL ACHIEVE ITS OBJECTIVES, GENERATE ANY PARTICULAR LEVEL OF RETURN, OR AVOID LOSSES.
    

1. Exclusion of Certain Damages. TO THE FULLEST EXTENT PERMITTED BY APPLICABLE LAW, IN NO EVENT SHALL KEYSTONE CAPITAL OR ITS AFFILIATES, DIRECTORS, OFFICERS, EMPLOYEES, CONTRACTORS, AGENTS, LICENSORS, OR SERVICE PROVIDERS (COLLECTIVELY, THE "KEYSTONE PARTIES") BE LIABLE FOR ANY INDIRECT, INCIDENTAL, CONSEQUENTIAL, SPECIAL, EXEMPLARY, OR PUNITIVE DAMAGES, INCLUDING WITHOUT LIMITATION LOSS OF PROFITS, LOSS OF REVENUE, LOSS OF BUSINESS OPPORTUNITY, LOSS OF GOODWILL, LOSS OF DATA, LOSS OF INVESTMENT VALUE, BUSINESS INTERRUPTION, OR ANY OTHER COMMERCIAL OR ECONOMIC LOSS, ARISING OUT OF OR RELATING TO THIS AGREEMENT, THE WEBSITE, THE SERVICES, ANY INVESTMENT, OR YOUR ACCESS TO OR USE OF (OR INABILITY TO USE) THE FOREGOING, REGARDLESS OF THE THEORY OF LIABILITY AND WHETHER OR NOT ADVISED OF THE POSSIBILITY OF SUCH DAMAGES.
    
2. Aggregate Liability Cap. TO THE MAXIMUM EXTENT PERMITTED BY LAW, THE TOTAL CUMULATIVE LIABILITY OF THE KEYSTONE PARTIES FOR ALL CLAIMS ARISING OUT OF OR RELATING TO THIS AGREEMENT, THE WEBSITE, OR THE SERVICES SHALL NOT EXCEED ONE HUNDRED UNITED STATES DOLLARS (US $100).
    
3. Allocation of Risk. YOU ACKNOWLEDGE THAT THE FOREGOING LIMITATIONS OF LIABILITY AND EXCLUSIONS OF DAMAGES REFLECT A REASONABLE ALLOCATION OF RISK AND FORM AN ESSENTIAL BASIS OF THE BARGAIN BETWEEN YOU AND KEYSTONE CAPITAL, AND THAT KEYSTONE CAPITAL WOULD NOT PROVIDE THE WEBSITE OR SERVICES WITHOUT SUCH LIMITATIONS.
    
4. Jurisdictional Limitations. SOME JURISDICTIONS DO NOT PERMIT THE EXCLUSION OR LIMITATION OF CERTAIN WARRANTIES OR DAMAGES. TO THE EXTENT SUCH RESTRICTIONS APPLY TO YOU, SOME PORTIONS OF THIS SECTION MAY NOT APPLY.
    

1. Indemnity Obligation. You agree to defend, indemnify, and hold harmless Keystone Capital and the Keystone Parties from and against any and all claims, demands, actions, investigations, proceedings, losses, damages, liabilities, judgments, settlements, penalties, fines, costs, and expenses (including reasonable attorneys' fees and costs) arising out of or relating to:
    
   • your access to or use of the Website or Services;
   • your breach of this Agreement or violation of any applicable law or regulation;
   • your infringement, misappropriation, or violation of any intellectual property, privacy, publicity, or other rights of any third party;
   • any misrepresentation made by you; or
   • any dispute between you and any third party relating to your activities in connection with the Website.

1. Control of Defense. Keystone Capital reserves the right, at its own expense, to assume exclusive control over the defense and settlement of any matter subject to indemnification by you, in which case you agree to reasonably cooperate and not to settle any such matter without Keystone Capital's prior written consent.
    
2. Survival. Your indemnification obligations shall survive any termination or expiration of this Agreement and your use of the Website.
    

1. Availability of Third-Party Materials. The Website may display, link to, or otherwise make available content, data, research, tools, services, or materials that are owned, operated, or provided by third parties ("Third-Party Materials"). Such Third-Party Materials may be governed by separate terms, policies, or licenses established by the applicable third party.
    
2. No Control or Responsibility. Keystone Capital does not control, operate, maintain, sponsor, endorse, warrant, or assume responsibility for any Third-Party Materials, including without limitation their accuracy, reliability, completeness, availability, legality, or continued operation.
    
3. Independent Risk Assumption. Your access to and use of any Third-Party Materials is undertaken solely at your own risk and subject exclusively to the applicable third party's terms and policies.
    
4. Waiver of Claims. To the maximum extent permitted by applicable law, you irrevocably waive and release any and all claims against Keystone Capital and the Keystone Parties arising out of or relating to your access to or use of any Third-Party Materials.
    

By accessing or using the Website, you represent, warrant, acknowledge, and agree on a continuing basis that:

1. Authority and Capacity. You have full legal capacity and authority to enter into this Agreement and to comply with its terms. If acting on behalf of an entity, you are duly authorized to bind that entity.
    
2. Sanctions and Jurisdiction. You are not located in, a resident of, or subject to the laws or control of any Restricted Jurisdiction, and you are not listed on any sanctions, restricted party, or denied persons lists maintained by any governmental authority.
    
3. Legal Compliance. Your use of the Website complies with all applicable laws and regulatory requirements in your jurisdiction, including securities, sanctions, anti-money laundering, counter-terrorism financing, consumer protection, data protection, and tax laws.
    
4. Tax Responsibility. You are solely responsible for determining and fulfilling all tax obligations arising from any investments made through or in connection with Keystone Capital's managed funds.
    
5. Sophisticated Investor Status. To the extent you access information regarding investment opportunities, you represent that you are a qualified, accredited, sophisticated, or institutional investor as defined under applicable law, or that you are a licensed professional evaluating such information on behalf of such an investor.
    
6. No Misrepresentation. You will not misrepresent the nature, scope, or availability of the Services or investment opportunities to third parties.
    
7. Accuracy of Information. All information you provide to Keystone Capital is accurate, current, and complete, and you will promptly update such information as necessary.
    
8. Assumption of Risk. You knowingly assume all risks associated with your use of the Website, including risks related to the accuracy or completeness of information contained herein. You acknowledge that you have reviewed, understand, and agree to the Risk Disclosure Statement set forth in Appendix A, which is incorporated by reference into these Terms of Use.
    
9. Continuing Effect. These representations are reaffirmed each time you access or use the Website.
    

1. Suspension. Keystone Capital may suspend or restrict your access to the Website at any time if Keystone Capital reasonably believes that your activity: (i) violates applicable law, regulation, sanctions requirements, or court orders; (ii) breaches this Agreement; (iii) poses a security, operational, compliance, or reputational risk; or (iv) may expose Keystone Capital or any third party to liability or regulatory scrutiny.
    
2. Termination by Keystone Capital. Keystone Capital may terminate your access to the Website, in whole or in part, at any time, with or without prior notice, for any reason or no reason.
    
3. Termination by You. You may discontinue use of the Website at any time.
    
4. Effect of Termination. Upon termination, all rights and licenses granted to you under this Agreement immediately cease. Any provisions which by their nature should survive termination, including without limitation disclaimers, limitations of liability, indemnification obligations, dispute resolution provisions, and representations, shall continue in full force and effect.
    

1. Consent to Electronic Delivery. You consent to receiving all notices, disclosures, statements, agreements, and other communications (collectively, "Communications") from Keystone Capital in electronic form, including by email or posting on the Website.
    
2. Legal Effect of Electronic Communications. You agree that any Communications delivered electronically satisfy any legal requirement that such communications be provided in writing.
    

1. AML/KYC Compliance. Keystone Capital is committed to complying with applicable anti-money laundering ("AML") and know your customer ("KYC") laws and regulations. You agree to provide any documentation or information requested by Keystone Capital to verify your identity, source of funds, or compliance status.
    
2. Right to Refuse. Keystone Capital reserves the right to refuse to provide Services, decline to accept investments, or terminate relationships where it is unable to satisfactorily verify your identity or compliance with applicable AML/KYC requirements, or where it determines in its sole discretion that doing so is necessary to comply with applicable law or manage risk.
    

1. Entire Agreement. This Agreement constitutes the entire agreement between you and Keystone Capital regarding your access to and use of the Website and supersedes all prior or contemporaneous agreements, communications, and understandings, whether written or oral. For the avoidance of doubt, this Agreement does not supersede or modify any subscription agreement, offering memorandum, limited partnership agreement, advisory agreement, or other definitive documentation entered into between you and Keystone Capital or any of its managed funds.
    
2. No Waiver. The failure of Keystone Capital to enforce any provision of this Agreement shall not constitute a waiver of such provision or of the right to enforce such provision at any later time.
    
3. Severability. If any provision of this Agreement is held to be invalid, illegal, or unenforceable, such provision shall be enforced to the maximum extent permissible, and the remaining provisions shall remain in full force and effect.
    
4. Governing Law and Dispute Resolution. This Agreement and any dispute arising out of or relating to it shall be governed by and construed in accordance with the laws of the Republic of Panama, without regard to conflict-of-law principles. The parties agree to first attempt to resolve any dispute in good faith through informal negotiations. If such efforts do not resolve the dispute within thirty (30) days, the dispute shall be finally resolved by binding arbitration administered by the Centro de Conciliación y Arbitraje de Panamá (CeCAP) in accordance with its rules then in effect. The arbitration shall be conducted by a single arbitrator. The seat of arbitration shall be Panama City, Republic of Panama. The language of the arbitration shall be English. All proceedings, submissions, evidence, hearings, and awards shall be confidential, except to the extent disclosure is required by law or for enforcement purposes.
    
5. Class Action Waiver. To the maximum extent permitted by applicable law, you and Keystone Capital agree that any dispute shall be brought solely in an individual capacity and not as a plaintiff or class member in any purported class, collective, representative, or private attorney general proceeding.
    
6. Assignment. You may not assign, transfer, delegate, or subcontract any of your rights or obligations under this Agreement without Keystone Capital's prior written consent. Keystone Capital may freely assign or transfer this Agreement without restriction or notice.
    
7. Language. These Terms of Use are drafted in the English language. In the event of any conflict between an English-language version and any translation, the English-language version shall prevail.
    

Last Updated: February 2026

Effective Date: February 2026

Keystone Capital Fund Inc. ("Keystone Capital," "we," "us," or "our"), a corporation organized under the laws of the Republic of Panama, is committed to protecting the privacy and security of your personal information. This Privacy Policy explains how we collect, use, store, disclose, and safeguard your information when you visit our website at [www.keystonecapital.co] (the "Website") or engage with our services.

Information You Provide. We may collect personal information that you voluntarily provide, including your name, email address, telephone number, mailing address, employer or institutional affiliation, professional title, investor accreditation status, and any other information you submit through contact forms, newsletter subscriptions, investor inquiries, or other communications.

Information Collected Automatically. When you visit the Website, we may automatically collect certain technical information, including your IP address, browser type and version, operating system, device identifiers, referring URLs, pages visited, time spent on pages, and other browsing activity data.

Cookies and Tracking Technologies. We may use cookies, web beacons, pixels, and similar tracking technologies to enhance your experience, analyze Website usage, and support our marketing efforts. You may manage your cookie preferences through your browser settings.

We may use the information we collect for the following purposes:

• To operate, maintain, and improve the Website and our services;
• To respond to your inquiries, requests, and communications;
• To process and evaluate investor applications and due diligence materials;
• To send newsletters, market commentary, research, and other communications you have opted in to receive;
• To comply with applicable legal, regulatory, and compliance obligations, including AML/KYC requirements;
• To detect, prevent, and address fraud, unauthorized access, and other security concerns;
• To enforce our Terms of Use and protect our legal rights; and
• For any other purpose described to you at the time of collection or for which you provide consent.

We do not sell your personal information. We may share your information with:

• Affiliates and Service Providers. Trusted third parties who assist us in operating the Website, conducting our business, or providing services to you, subject to confidentiality obligations;
• Professional Advisors. Lawyers, auditors, accountants, and consultants engaged by Keystone Capital;
• Fund Administrators and Custodians. Third-party service providers involved in the administration, custody, and operation of our managed funds;
• Regulatory and Legal Authorities. Government agencies, regulators, courts, or other parties when required by applicable law, regulation, legal process, or enforceable governmental request; and
• Business Transfers. In connection with any merger, acquisition, reorganization, or sale of assets, your information may be transferred as part of such transaction.

Your information may be transferred to and processed in jurisdictions outside the Republic of Panama, including jurisdictions that may not provide the same level of data protection as your home jurisdiction. By using the Website, you consent to such transfers. We take commercially reasonable steps to ensure that your information is treated securely and in accordance with this Privacy Policy wherever it is processed.

We retain your personal information for as long as reasonably necessary to fulfill the purposes for which it was collected, to comply with our legal and regulatory obligations, to resolve disputes, and to enforce our agreements. When personal information is no longer needed, we will securely delete or anonymize it.

We implement commercially reasonable administrative, technical, and physical safeguards to protect your personal information from unauthorized access, use, alteration, or disclosure. However, no method of transmission over the internet or electronic storage is completely secure, and we cannot guarantee absolute security.

Depending on your jurisdiction, you may have certain rights regarding your personal information, including the right to access, correct, delete, restrict processing of, or request portability of your personal data. To exercise any such rights, please contact us using the information provided below. We will respond to your request in accordance with applicable law.

The Website is not intended for individuals under the age of eighteen (18). We do not knowingly collect personal information from children. If you believe we have inadvertently collected information from a minor, please contact us immediately.

We may update this Privacy Policy from time to time. Any changes will be posted on this page with an updated effective date. Your continued use of the Website following the posting of changes constitutes your acceptance of such changes.

If you have questions about this Privacy Policy or wish to exercise your data protection rights, please contact us at:

Keystone Capital Fund Inc.[Registered Address, Panama City, Republic of Panama] Email: privacy@keystonecapital.co

The information contained on this website is provided by Keystone Capital Fund Inc. ("Keystone Capital"), a corporation organized under the laws of the Republic of Panama, for general informational purposes only. Nothing on this website constitutes an offer to sell, a solicitation of an offer to buy, or a recommendation of any security, fund interest, investment product, or investment strategy.

Not Investment Advice. The content on this website, including any research, analysis, commentary, or market information, does not constitute investment, legal, tax, accounting, or other professional advice. You should not rely on any information on this website as a basis for making any investment decision. You should consult your own qualified advisors before making any investment or financial decision.

No Offer or Solicitation. This website does not constitute an offer to sell or a solicitation of an offer to buy any securities or fund interests in any jurisdiction. Any such offer or solicitation will be made only pursuant to confidential offering documents delivered directly to qualified investors and in compliance with all applicable securities laws and regulations.

Qualified Investors Only. Investment opportunities described on this website are available exclusively to qualified, accredited, sophisticated, or institutional investors as defined under applicable law. Investments in funds managed by Keystone Capital involve a high degree of risk, including the potential for total loss of capital, and are suitable only for investors who can bear such risks.

Past Performance. Past performance is not indicative of future results. No representation or warranty is made that any investment strategy, fund, or portfolio will achieve its objectives, generate any particular level of return, or avoid losses. All investments carry risk, and the value of investments can go down as well as up.

Forward-Looking Statements. This website may contain forward-looking statements that involve risks and uncertainties. Actual results may differ materially from those expressed or implied by such statements. Keystone Capital undertakes no obligation to update forward-looking statements.

Digital Asset Risks. To the extent that Keystone Capital's investment activities involve digital assets, cryptocurrencies, tokens, or blockchain-related technologies, such investments are subject to heightened risks including extreme volatility, limited or no liquidity, regulatory uncertainty, technology failures, cybersecurity risks, and the potential for total loss of value.

Jurisdictional Limitations. The distribution of information on this website may be restricted by law in certain jurisdictions. This website is not directed at any person in any jurisdiction where such distribution would be contrary to applicable law or regulation. Persons who access this website are responsible for informing themselves of and observing any such restrictions.

Third-Party Information. This website may contain information obtained from third-party sources believed to be reliable. Keystone Capital does not guarantee the accuracy, completeness, or timeliness of such information and assumes no liability for errors or omissions.

No Warranty. The information on this website is provided "as is" without any representations or warranties, express or implied. Keystone Capital disclaims all liability for any loss or damage arising from your reliance on the information contained on this website.

Governing Law. This Disclaimer shall be governed by and construed in accordance with the laws of the Republic of Panama.

© 2025 Keystone Capital Fund Inc. All Rights Reserved.

Keystone Capital Fund Inc. is incorporated under the laws of the Republic of Panama.