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Privacy Policy

Last Updated: August 5, 2026

LEGGIERO Capital LLC ("we," "our," or "us") is committed to protecting the privacy and confidentiality of the personal data of our qualified professional investors, potential allocators, and website visitors. This Privacy Policy details how we collect, use, store, and protect your information when you visit our website leggierocapital.com or interact with our Investor Relations desk.

1. Scope and Jurisdiction

This Privacy Policy is designed to comply with applicable data protection laws, including the UAE Federal Decree-Law No. 45 of 2021 on Personal Data Protection (PDPL), the ADGM Data Protection Regulations 2021, the DIFC Data Protection Law No. 5 of 2020, and the European Union General Data Protection Regulation (GDPR) where relevant to our European compartment configurations.

2. Information We Collect

We collect information you provide directly through our secure fiduciary onboarding and inquiry form, including:

  • Identity Data: Full name, corporate title, and name of your institution or family office.
  • Contact Data: Fiduciary/corporate email address, telephone number, and communication preferences.
  • Allocation Interest Data: Financial profile type (e.g., HNWI, Family Office, Fund Manager), preferred investment strategy (e.g., Private Debt, Quasi-Equity), target allocation ticket size, and underwriting notes.

3. How We Use Your Information

We process your personal information strictly for the following purposes:

  • To verify your status as a Qualified Professional Investor or Institutional Allocator in compliance with regulatory mandates.
  • To securely dispatch requested data room access, term sheets, or private placement memoranda.
  • To respond to your inquiries and establish direct contact through our Investor Relations team.
  • To maintain internal compliance records and audit trails.

4. Data Custody and Security

We implement rigorous security architectures to protect your data from unauthorized access, alteration, or disclosure. Personal data submitted via our landing page is temporarily stored client-side for administrative review and is transferred to secure, encrypted databases. We do not sell or rent your information to third-party brokers or external marketing entities.

5. Fiduciary Data Sharing

We may share your data only with third-party service providers acting on our behalf under strict confidentiality agreements, including:

  • Security Trustees (e.g., TMF Group) for KYC and compliance verification.
  • Administrators or custodians responsible for compartment bookkeeping.
  • Legal or regulatory authorities where required by applicable laws in the UAE or Luxembourg.

6. Your Rights

Depending on your jurisdiction, you have the right to access, correct, delete, or restrict the processing of your personal data. You may object to data processing or request portability. To exercise any of these rights, please contact our Data Protection Officer at ir@leggierocapital.com.