Privacy Policy

01Who is responsible for your information

SBN Capital Management Ltd, PO Box 90, Road Town, Tortola VG1110, British Virgin Islands, is responsible for personal information collected through this website and by email.

Because the firm, its service providers and the people who contact it may be located in different countries, more than one data protection regime may apply to a given person. We apply the standards set out in this policy to everyone who contacts us, whichever regime applies.

Questions about this policy may be sent to enquiries@sbn.capital.

02Information we collect

Through this website and ordinary correspondence, we may hold:

• your name;
• your email address;
• a telephone number, if you choose to give one;
• your employer, firm or other details included in what you write to us;
• technical information such as IP address, browser and device type, and basic server logs;
• anything else you volunteer when you contact us.

03How it is collected

Information reaches us when you email the firm, and through the normal operation of the website and its server. If analytics or cookies are introduced in future, this policy will be updated before they are used.

Where an enquiry progresses towards a possible investment, we may also collect information from professional or publicly available sources as part of our assessment.

04Why we use it

We use personal information to:

• respond to enquiries and correspond with you;
• consider whether an enquiry should be progressed;
• communicate with prospective and existing investors;
• administer and secure the website;
• meet legal, regulatory and record-keeping obligations;
• prevent fraud and misuse.

Where a lawful basis is required, we rely on our legitimate interests in responding to correspondence, assessing enquiries and operating the website securely; on the steps necessary before entering into a contract, where an enquiry progresses towards a subscription; and on compliance with our legal obligations, for record-keeping and anti-money-laundering purposes.

05Investor onboarding is separate

This policy covers the website and ordinary correspondence. If you go on to subscribe to the fund, further information will be collected as part of identity, eligibility and anti-money-laundering checks, which may include identity documents, addresses, financial information and source of funds.

That process is governed by separate privacy information provided with the subscription materials. The fund administrator maintains its own privacy notice covering the information it handles.

06Who it may be shared with

Personal information may be shared with the fund administrator; legal, tax and other professional advisers; auditors; technology and service providers acting on our behalf; and regulators, tax authorities or law enforcement where we are legally required to do so.

We do not sell personal information, and we do not share it for marketing purposes.

07International transfers

The firm, the fund, its service providers and its investors may be located in different countries. Your personal information may therefore be processed outside the country in which you live. Where the law requires it, appropriate safeguards will be put in place for those transfers.

08How long it is kept

Information is kept only for as long as it is reasonably necessary for the purpose it was collected for, and thereafter for the period required by applicable legal, regulatory, tax and record-keeping obligations. Server logs are kept briefly and then discarded.

09Your rights

Depending on which law applies to you, you may have the right to:

• ask what personal information we hold about you;
• have inaccurate information corrected;
• ask for information to be deleted;
• restrict or object to certain uses of it;
• withdraw consent, where we rely on consent;
• complain to the relevant data protection authority.

Requests can be sent to enquiries@sbn.capital. Some information cannot be deleted on request where we are required to retain it, particularly records kept for anti-money-laundering purposes.

10Cookies and analytics

This website does not use cookies, analytics, advertising or tracking of any kind, and nothing is stored on your device.

Typefaces are loaded from Google Fonts, so when a page loads your browser requests those files from a Google server and Google may receive your IP address as a result. The website is hosted by Netlify, whose servers necessarily process the requests your browser makes, as described in section 03.

11Security

We use appropriate technical and organisational measures to protect personal information against loss, misuse and unauthorised access. No method of transmission or storage is completely secure, and email in particular is not a secure medium.

12Changes to this policy

This policy may be updated from time to time. The version published here is always the current one.

Last updated: 28 August 2026