BlockArrow, LLC ("BlockArrow," "we," "us," or "our") respects the privacy of the visitors and limited partners who interact with our website at blockarrow.xyz, our investor relations channels, and the LP portal. This policy describes the categories of personal information we collect, the purposes for which we use it, the parties with whom we share it, the security and retention practices we apply, and the rights available to specific U.S. state residents and to non-U.S. visitors.
Scope of this policy
This policy applies to (a) visitors to blockarrow.xyz and any subdomain operated by BlockArrow; (b) prospective and current limited partners and their authorized representatives who interact with BlockArrow's investor-relations function; (c) users of the LP portal and any document-distribution surface BlockArrow operates; and (d) recipients of BlockArrow communications (including market commentary, quarterly attribution letters, and onboarding correspondence). It does not apply to information collected by independent third parties — custodians, the fund administrator, the auditor, the on-chain compliance vendor, outside counsel, and trading venues — under their own privacy policies, even where the data ultimately reaches those parties through their role serving the funds.
Categories of personal information we collect
BlockArrow collects different categories of personal information depending on the nature of the interaction:
From website visitors — Standard request metadata may be processed by the firm's hosting and security providers, including IP address, approximate geo-region derived from IP, user-agent string, referring URL, requested page, and time of access. These data are used to deliver, secure, and maintain the website. The public site does not currently collect an audience-gate response or a visitor's stated jurisdiction.
From visitors who contact IR or request materials — name, business email address, organization, role, the substance of the inquiry, and any accreditation or qualified-purchaser status the visitor self-attests. Where a phone number is provided, we collect it; we do not require it.
From prospective and current LPs — full legal name, residential and business address, jurisdiction of residence and (for entities) of organization, date of birth or formation, government-issued identification, tax identification number, source-of-funds documentation, beneficial-ownership information, accreditation or qualified-purchaser verification, banking and wire-transfer instructions, subscription and redemption history, and the contents of investor-relations correspondence. For benefit-plan investors, we additionally collect plan-asset attestations and any documentation required to evidence the firm's reliance on the ERISA "significant participation" exception.
From LP portal users — FGMK may process account, authentication, session, and activity data under its own privacy and security terms. BlockArrow may receive information from FGMK as needed to coordinate provisioning, support, reporting, and regulatory obligations.
BlockArrow does not knowingly collect personal information from anyone under the age of 18. The website and the funds are directed exclusively to qualified institutional and accredited individual investors and are not intended for minors.
How we use personal information
We use the personal information we collect to (a) respond to inquiries and deliver requested materials; (b) operate, secure, and improve the website and coordinate LP portal access and support; (c) onboard subscribers and conduct ongoing KYC, AML, sanctions, accreditation, qualified-purchaser, FATCA, and CRS screening at subscription and periodically thereafter; (d) administer the funds in cooperation with the independent administrator, the qualified custodians, the auditor, and the on-chain compliance vendor; (e) prepare and distribute investor reporting, including monthly statements, attribution letters, audited financials, and K-1s and PFIC statements; (f) comply with applicable law, regulatory request, court order, or other legal process; (g) detect, prevent, and respond to fraud, security incidents, and abuse; and (h) where permitted by law and consistent with the recipient's preferences, send periodic firm and market communications.
Who we share personal information with
BlockArrow does not sell personal information for monetary or other valuable consideration, and does not share personal information for cross-context behavioral advertising. We share personal information only as described below:
Service providers operating the funds. BlockArrow may share personal information with service providers that support fund administration, custody, compliance, audit, legal, tax, technology, communications, document distribution, and investor services. These providers receive personal information as reasonably necessary to perform services for BlockArrow or the funds, and their handling of that information is governed by applicable law, relevant contractual terms, and their own privacy and security policies.
Service providers for the website and LP portal. The firm's website hosting, email delivery, contact-form receipt, and document-distribution providers, together with FGMK as operator of the external LP portal, receive only the data their operational role requires. Internal service-provider schedules are maintained by BlockArrow's compliance officer and are available on written request to tommysutker@blockarrow.io.
Regulators and other authorities. Where required by law, court order, or other compulsory process, BlockArrow may disclose personal information to U.S. federal and state regulators, equivalent non-U.S. regulators, tax authorities, and law enforcement.
Successor entities. In the event of a corporate transaction — merger, reorganization, sale of business, or insolvency — personal information may be transferred to the successor as part of the transferred business, subject to confidentiality undertakings consistent with this policy.
Cookies, analytics, and tracking
The public website does not currently set an audience-gate cookie, store a visitor's stated jurisdiction, use third-party advertising cookies, participate in cross-site advertising networks, or embed advertising trackers. Authentication and session controls for any third-party LP portal are governed by that provider's own privacy and security terms. Server-side request logs may be retained for security, audit, and recordkeeping purposes for the rolling period required by applicable law. If analytics or additional client-side storage is enabled in the future, the categories of data collected and any available visitor controls will be disclosed here before activation. The website serves no behavioral-advertising experience.
Retention windows
BlockArrow retains personal information only for as long as is necessary for the purposes for which it was collected and as required by applicable law, regulation, or contract. Indicative retention windows:
Website server logs — up to 13 months from collection (security, audit, and recordkeeping window); IR correspondence and contact-form submissions — 7 years from the last interaction or for the duration of any related LP relationship plus 7 years, whichever is longer (regulatory recordkeeping); LP onboarding and KYC / AML documentation — for the duration of the LP relationship plus 7 years (Bank Secrecy Act, AML, IRS, and state record-retention rules); FATCA / CRS self-certifications — for the duration of the LP relationship plus 6 years, and refreshed on the triennial cycle or on material change; LP portal data — retained by FGMK under its policies, terms, and applicable legal requirements; tax workpapers, K-1s, and PFIC statements — per the applicable statute of limitations plus a defensive cushion (typically 7 years).
Where personal information is no longer required and not subject to a legal hold, it is either deleted from BlockArrow's production systems and from any sub-processor system holding it for our account, or de-identified to the extent that it can no longer be associated with a natural person.
Security
BlockArrow applies commercially reasonable administrative, technical, and physical safeguards to the personal information it holds. The external LP portal is operated by FGMK; its authentication, access, security, retention, and activity controls are governed by FGMK's systems, policies, and terms. IR coordinates provisioning and support but does not control the provider's security configuration. No system is perfectly secure; in the event of a security incident affecting personal information, BlockArrow will notify affected individuals, regulators, and (where applicable) law enforcement in accordance with applicable law.
State-specific consumer rights (U.S.)
Residents of certain U.S. states have specific rights with respect to their personal information under state privacy law, including (without limitation) the California Consumer Privacy Act as amended by the California Privacy Rights Act ("CCPA / CPRA"), the Virginia Consumer Data Protection Act ("VCDPA"), the Colorado Privacy Act ("CPA"), the Connecticut Data Privacy Act ("CTDPA"), the Utah Consumer Privacy Act ("UCPA"), and the Texas Data Privacy and Security Act ("TDPSA"). Subject to each statute's eligibility criteria and exceptions, those rights include: (i) the right to confirm whether BlockArrow processes the resident's personal information and to access that information; (ii) the right to correct inaccurate personal information; (iii) the right to delete personal information, subject to exemptions for recordkeeping required by law (notably, much of the personal information BlockArrow holds about its LPs is subject to AML, securities, and tax record-retention rules that override general deletion rights); (iv) the right to data portability where applicable; (v) the right to opt out of the sale of personal information, of sharing for cross-context behavioral advertising, and of certain profiling (BlockArrow does not engage in any of those activities); and (vi) the right to be free from discrimination for exercising any of these rights. Note that significant categories of the personal information BlockArrow processes about LPs are covered by the Gramm-Leach-Bliley Act ("GLBA") and the SEC's Regulation S-P, and are therefore exempted from many state-law rights — that exemption is structural rather than discretionary, and is itself disclosed here as a matter of transparency.
To exercise an applicable right, write to tommysutker@blockarrow.io with sufficient detail to identify the request and the requestor. We will respond within the timeframe required by the applicable statute. An authorized agent may submit a request on a resident's behalf with documentation of authority. BlockArrow does not charge a fee for routine requests.
Non-U.S. visitors
BlockArrow's investor base, operations, and infrastructure are primarily U.S.-based. Where personal information is collected from a non-U.S. visitor or LP, it may be transferred to and processed in the United States; by interacting with the website or providing personal information through any BlockArrow channel, the non-U.S. visitor consents to that transfer subject to the protections set out in this policy and the firm's contractual obligations to its sub-processors. Where the General Data Protection Regulation ("GDPR"), the UK GDPR, or another non-U.S. data-protection regime applies to a specific interaction, BlockArrow will, in addition to the rights above, observe the additional rights granted under that regime — including the right to object to processing, the right to restrict processing, and (where applicable) the right to lodge a complaint with the competent supervisory authority.
Children
BlockArrow does not knowingly collect personal information from anyone under the age of 18. The website, the LP portal, and the funds are directed exclusively to qualified institutional and accredited individual investors. If we become aware that personal information of a minor has been collected, we will delete that information.
Changes to this policy
BlockArrow may update this policy from time to time. The "Last reviewed" date at the top of the page reflects the most recent review. Material changes — including changes to the categories of personal information collected, the parties with whom it is shared, or the rights available to data subjects — will be highlighted in the page itself for a reasonable transition period and, where appropriate, notified by email to LPs and others with whom BlockArrow has an ongoing relationship.
Contact
Questions about this policy, requests to exercise applicable rights, or notifications of a suspected security incident affecting BlockArrow systems can be sent to tommysutker@blockarrow.io. Security-specific concerns may additionally be reported through the channel published at /.well-known/security.txt. The firm's compliance officer reviews each privacy inquiry; substantive responses are returned within the timeframe required by applicable law.
Last reviewed . This page is maintained by BlockArrow and reviewed periodically against the firm's compliance manual, the funds' operating documents, and the U.S. state privacy regimes in force. It is intended to satisfy the standing notice requirements applicable to a private investment-manager website addressed to qualified prospects.