Privacy Policy

1. About This Policy

This Privacy Policy describes how C and R CAPITALS FCZ LLC, acting as Investment Manager for MERLINSORT LLC (collectively "we," "us," or "our"), collects, uses, and protects information in connection with our investment management services.

Fund Structure: MERLINSORT LLC is a Delaware limited liability company (the "Fund") managed by C and R CAPITALS FCZ LLC, a Sharjah Free Zone entity based in the United Arab Emirates (the "Investment Manager").

2. Information We Collect

We collect information necessary to comply with applicable securities laws, anti-money laundering regulations, and to provide investment management services to qualified investors:

• Personal identification (name, address, date of birth, government-issued ID)
• Financial information (net worth, income, investment experience, accredited investor status)
• Source of funds and beneficial ownership information
• Tax identification numbers (SSN, EIN, or foreign tax ID)
• Transaction history and account activity
• Communications with our firm (emails, phone calls, messages)
• Cryptocurrency wallet addresses for subscription/redemption processing

3. How We Use Your Information

We use collected information to:

• Verify accredited investor and qualified purchaser status
• Comply with Know Your Customer (KYC) and Anti-Money Laundering (AML) requirements
• Process subscriptions, redemptions, and distributions
• Calculate NAV and prepare financial statements
• Provide K-1 tax forms (US investors) and other required tax documentation
• Comply with FATCA, CRS, and other international tax reporting obligations
• Communicate account information and performance updates
• Manage relationships with prime brokers, custodians, and service providers
• Maintain regulatory compliance and respond to regulatory inquiries

4. Data Security

We implement industry-standard security measures to protect your personal and financial information. This includes encryption, secure data transmission protocols, access controls, and regular security audits.

5. Information Sharing

We do not sell or rent your personal information to third parties. We may share information with the following entities as necessary to operate the Fund:

• Prime Brokers & Custodians: Interactive Brokers, Alpaca Markets, IC Markets, RoboForex, RoboMarkets, Binance, Kraken (for custody, execution, and clearing)
• Fund Administrator: Self-administered by C and R CAPITALS FCZ LLC
• Legal & Compliance Advisors: External counsel for legal and regulatory matters
• Auditors: Independent auditors for annual financial statement preparation
• Tax Authorities: IRS (US), UAE Federal Tax Authority, and foreign tax authorities pursuant to FATCA/CRS
• Regulatory Authorities: SEC, CFTC, Sharjah Free Zone Authority, and other applicable regulators
• Insurance Providers: For professional indemnity and cybersecurity insurance coverage

All service providers are subject to confidentiality obligations and may only use your information for the purposes specified.

6. Data Retention

We retain client information for the duration required by applicable securities laws and regulations, typically for a minimum of seven years following account closure.

7. Your Rights

You have the right to:

• Access your personal information
• Request corrections to inaccurate data
• Request deletion of data (subject to legal requirements)
• Opt-out of marketing communications

8. Cookies and Tracking

Our website uses cookies for analytics and to improve user experience. You can control cookie settings through your browser preferences.

9. Contact Us

For privacy-related inquiries, please contact us at: contact@crcapitals.fr