Ancova Volatility Optimizer Fund
Website Privacy Policy, Cookie Policy & Data Protection Notice Pack
Privacy Policy
Last updated: 12 January 2026
This Privacy Policy sets out how personal data is collected, used, stored, disclosed, and protected in connection with the website of Ancova Volatility Optimizer Fund (the “Website”). This Privacy Policy is intended for a professional and institutional audience and reflects applicable obligations under the Cayman Islands Data Protection Act (2021 Revision) (the “DPA”) and other applicable laws.
Data Controller
For the purposes of the DPA, the data controller is:
Ancova Capital Management
P.O. Box 10008, Willow House, Cricket Square, Grand Cayman, KY1-1001, Cayman Islands
Ancova Capital Management acts as investment manager. The fund is a segregated portfolio within Ancova Capital Management SPC. Ancova Capital Management and/or Ancova Capital Management SPC are authorized and regulated by the Cayman Islands Monetary Authority (“CIMA”).Scope
This Privacy Policy applies to personal data collected through the Website and communications initiated via the Website. This policy does not replace privacy disclosures contained in offering documents, subscription agreements, or investor notices, which shall prevail in the event of inconsistency.Categories of Personal Data Collected
Information provided voluntarily: name, professional title, employer, contact details, inquiry content, and correspondence.
Technical and usage data: IP address, approximate location, browser type, operating system, device identifiers, access times, referring URLs, and interaction data.
Regulatory-related data (where applicable): if an inquiry progresses beyond general contact, additional data may be collected to meet legal and regulatory obligations (including AML/KYC), as set out in applicable offering documentation.Purposes of Processing
Responding to inquiries and professional communications.
Operating, maintaining, and securing the Website.
Improving Website performance and user experience.
Managing investor-related communications where applicable.
Complying with legal, regulatory, and supervisory obligations, including those imposed by CIMA.
Establishing, exercising, or defending legal rights and preventing fraud or misuse.Legal Bases for Processing
Legitimate interests (e.g., business communications, Website operation, security, and service improvement).
Consent (where expressly obtained, e.g., marketing communications).
Compliance with legal obligations (e.g., regulatory, tax, record-keeping, AML/KYC where applicable).
Performance of a contract or steps prior to entering a contract (where applicable).Disclosure of Personal Data
Personal data may be disclosed on a confidential, need-to-know basis to:
Service providers and professional advisers (IT/hosting, analytics, legal, compliance, audit, consultants).
Regulatory, supervisory, or governmental authorities where required (including CIMA).
Affiliates or related entities within the Ancova group for legitimate business and compliance purposes.
Personal data is not sold and is not disclosed for unrelated commercial purposes.International Data Transfers
Personal data may be transferred to and processed in jurisdictions outside the Cayman Islands. Where transfers occur, appropriate safeguards are implemented to ensure a level of protection consistent with applicable data protection requirements.Data Retention
Personal data is retained only for as long as necessary to fulfill the purposes for which it was collected and to satisfy applicable legal, regulatory, tax, and compliance obligations. Retention periods may vary based on the nature of the data and applicable requirements.Data Security
We maintain reasonable and proportionate technical and organizational measures designed to protect personal data against unauthorized access, disclosure, alteration, or destruction. No system is completely secure; however, measures are implemented consistent with industry standards and regulatory expectations.Data Subject Rights
Subject to applicable law, individuals may have rights to:
Request access to personal data held about them.
Request rectification of inaccurate or incomplete data.
Request erasure or restriction of processing in certain circumstances.
Object to processing based on legitimate interests.
Withdraw consent where processing is based on consent.
Requests may be made via the contact details published on the Website. Identity verification may be required.Marketing Communications
Marketing communications will only be sent where permitted by law or where consent has been provided. Recipients may opt out at any time. Operational, compliance, or regulatory communications may continue where required.Third-Party Websites
The Website may contain links to third-party websites. We are not responsible for the privacy practices or content of such websites.Children
The Website is intended for a professional audience and is not directed at children. We do not knowingly collect personal data from children.Changes to this Privacy Policy
This Privacy Policy may be updated from time to time. Updates will be posted on the Website with a revised “Last updated” date.Regulatory & Investment Notice
The Website is provided for informational purposes only. Nothing on the Website constitutes investment advice, an offer, or a solicitation to invest. Any offering of interests in the fund will be made solely pursuant to formal offering documents and in accordance with applicable laws and regulations.
Ancova Capital Management and/or Ancova Capital Management SPC are authorized and regulated by the Cayman Islands Monetary Authority (“CIMA”).
Cookie Policy
Last updated: 12 January 2026
This Cookie Policy explains how cookies and similar technologies are used on the Website. Cookies are small text files placed on your device that enable Website functionality, security, and analytics.
Types of Cookies We Use
Strictly necessary cookies: required for core Website operation, security, and network management.
Performance/analytics cookies: used to understand Website usage and improve performance (e.g., aggregated page views, session metrics).
Functionality cookies: remember user preferences (where implemented).
Advertising cookies: the Website does not deploy advertising cookies unless expressly implemented and disclosed (e.g., via a consent banner).Managing Cookies
You can control cookies through your browser settings, including deleting existing cookies and blocking future cookies. If you disable certain cookies, parts of the Website may not function properly.Consent (Where Applicable)
Where required by applicable law, non-essential cookies will be set only after you provide consent through a cookie banner or preference tool.Third-Party Cookies
Some cookies may be set by third-party service providers used for analytics or Website functionality. We seek to use reputable providers and limit data shared to what is necessary for the relevant purpose.Updates to This Cookie Policy
We may update this Cookie Policy from time to time to reflect operational or legal changes. Updates will be posted on the Website.
Investor Data Protection Notice (for Subscription / Onboarding)
Last updated: 12 January 2026
This notice is intended to be presented at the point of investor onboarding (e.g., subscription portal, KYC upload page, or subscription package) and supplements disclosures in the fund’s offering and subscription documentation.
Who Processes Your Data
Ancova Capital Management, as investment manager, and Ancova Capital Management SPC (including the relevant segregated portfolio) process personal data in connection with investor onboarding, ongoing investor servicing, and compliance. Ancova Capital Management and/or Ancova Capital Management SPC are authorized and regulated by CIMA.Data Collected
Identification and contact data (name, address, email, phone, nationality, date of birth, identification numbers).
Verification documents (passport/ID, proof of address, corporate documents for entities).
Financial and suitability information (source of funds/wealth, investment experience, accredited/qualified status where applicable).
Compliance data (sanctions/PEP checks, AML/KYC screening outcomes, tax residency and reporting information where required).Purposes & Legal Bases
To evaluate and process subscriptions and provide investor services (contract / pre-contract steps).
To meet legal and regulatory obligations including AML/KYC, sanctions screening, tax reporting, and recordkeeping (legal obligation).
To maintain risk management, fraud prevention, and security (legitimate interests).
To communicate fund updates and operational notices (legitimate interests / contract).
Marketing is conducted only where permitted or with consent (consent where required).Who We Share Data With
Personal data may be shared with, on a confidential and need-to-know basis:
Fund administrators, AML/KYC providers, custodians, auditors, legal counsel, banks, payment processors, and IT/portal providers.
Regulators, law enforcement, tax authorities, and other competent authorities where required.
Affiliates within the Ancova group where necessary for the above purposes.Transfers, Retention & Security
Data may be processed in multiple jurisdictions depending on service providers. Appropriate safeguards are applied where required. Data is retained for as long as necessary to satisfy contractual, legal, and regulatory obligations (including AML recordkeeping). Reasonable technical and organizational measures are maintained to protect personal data.Your Rights
Subject to applicable law, you may request access, correction, restriction, or other rights in respect of your personal data. We may need to verify your identity before responding and may decline requests where permitted by law (e.g., where required to retain records for AML compliance).Contact
To raise a question or exercise rights, contact Ancova Capital Management using the contact details provided in the Website Privacy Policy or the subscription materials.