Privacy and Confidentiality Policy

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Effective Date: 25.06.2025
Applicable to: www.klothorla.com
This Privacy and Confidentiality Policy (the “Policy”) governs the manner in which
Klotho Capital Partners, acting through its Luxembourg-based special purpose vehicles,
including any SCSp or other affiliated entities (“Klotho,” “we,” “us,” or “our”), collects, uses, and safeguards
any information that you, as a visitor (“you” or “Visitor”), may provide via
rla.klothocapital.com (the “Website”).

1. Confidential Treatment of Submitted Information

   By accessing and using the Website and/or by submitting any information through forms, emails, uploads, or other communications, you acknowledge and agree that:

   • All information you provide, whether personal, business-related, financial, or otherwise (the “Submitted Information”), will be treated as confidential.
   • Klotho shall not disclose the Submitted Information to any third parties except as strictly necessary and only to:
     
     1. Klotho’s duly authorized directors, officers, employees, legal and financial advisors, and affiliates;
     2. Potential and existing investors, limited partners, and shareholders of Klotho or its associated investment vehicles;
     3. Klotho’s bankers, auditors, service providers, or regulatory authorities, only to the extent strictly necessary and limited in scope;
     4. As may be required by applicable laws or court order.

   All recipients of such information shall be bound by confidentiality obligations no less protective than those stated herein.

2. Purpose of Information Use

   The Submitted Information may be used by Klotho solely for:

   • Evaluating potential cooperation, investment opportunities, or services;
   • Conducting required due diligence and compliance checks;
   • Fulfilling legal or regulatory obligations;
   • Internal business and operational needs.

   Klotho does not sell, trade, or rent your personal or business data.

3. No Offer or Obligation

   Submission of information via the Website does not constitute an offer or commitment by Klotho or its affiliates
   to enter into any transaction, nor does it create any binding obligation. Any investment or commercial relationship
   shall be governed solely by separate, duly executed binding agreements.

4. Retention and Deletion

   Klotho shall retain the Submitted Information only as long as necessary for the intended purposes or as required by
   applicable laws or regulations. Upon reasonable request, and subject to legal constraints, we will delete or anonymize your data.

5. Changes to This Policy

   We reserve the right to update this Policy. We will notify users of material changes via this website.

6. Jurisdiction and Governing Law

   This Policy and any related confidentiality obligations are governed by and shall be construed in accordance with the laws of the
   Grand Duchy of Luxembourg. Any disputes arising in connection with this Policy shall be submitted to the exclusive jurisdiction of
   the courts of Luxembourg City.

   By entering and using the Website, and by submitting any information through them, you expressly confirm your agreement with this
   Privacy and Confidentiality Policy, Cookies Policy and Copyright Notice & Disclaimer, and consent to the terms herein.
   If you do not agree, please do not use the Website or submit any information.