PRIVACY POLICY.

Effective Date: May 22, 2026

UpDown Investments Fund I, LP and UpDown Management, LLC (collectively, "UpDown Capital," "we," "us," or "our") are committed to protecting the privacy and security of the personal and financial information we collect. This Privacy Policy describes how we collect, use, disclose, and safeguard your information when you visit our website (the "Site"), use our investor portals (including WealthBlock), or engage with the services provided by our operational partner, ET Capital Partners.

1. INFORMATION WE COLLECT

We collect information that identifies, relates to, describes, or could reasonably be linked, directly or indirectly, with a particular consumer or hardware device ("Personal Information").

A. Information Provided Voluntarily:

  • Contact Information: Name, email address, phone number, and mailing address.

  • Investor Identity Verification: Social Security numbers, Tax Identification Numbers, copies of government-issued identification, and date of birth (required for AML/KYC compliance).

  • Financial Information: Bank account details, wire transfer instructions, investment history, and net worth/income data for accredited investor verification.

  • Self-Directed IRA Data: Information regarding custodial accounts and documentation necessary for IRA-funded transactions.

B. Automatically Collected Information:

  • Technical Data: IP addresses, browser types, operating systems, and device identifiers.

  • Usage Data: Pages viewed, links clicked, and time spent on the Site, collected via cookies and similar tracking technologies.

2. HOW WE USE YOUR INFORMATION

We use the information we collect for the following business and commercial purposes:

  • Operational Management: Facilitating LLC setups, processing subscriptions, and managing investor relationships through ET Capital Partners.

  • Communication: Sending offering memorandums, tax documents (K-1s), and fund performance updates.

  • Compliance: Verifying identity and "Accredited Investor" status as required by the Securities and Exchange Commission (SEC) and other regulatory bodies.

  • Service Improvement: Monitoring Site traffic to enhance user experience and portal functionality.

  • Security: Detecting and preventing fraudulent transactions and unauthorized access to investor accounts.

3. SHARING AND DISCLOSURE OF INFORMATION

We do not sell your personal information. We share your information only in the following circumstances:

  • Service Providers: We share information with ET Capital Partners for operational backbone support, as well as third-party portal providers (e.g., WealthBlock.ai, and eventually Repool), and tax professionals (e.g., UHY) to facilitate fund administration.

  • Legal Obligations: We may disclose information if required by law, subpoena, or regulatory inquiry.

  • Business Transfers: In the event of a merger, acquisition, or sale of assets, your information may be transferred as a business asset.

4. DATA SECURITY

We implement industry-standard security measures, including encryption and secure document storage protocols managed by ET Capital Partners, to protect your sensitive information. However, no method of transmission over the internet or electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security.

5. COOKIES AND TRACKING

Our Site uses cookies to maintain session integrity and analyze traffic. You may adjust your browser settings to refuse cookies; however, doing so may limit your ability to access certain features of the investor portal or subscription documents.

6. THIRD-PARTY LINKS AND PORTALS

The Site contains links to third-party platforms, such as ET Capital Partner’s portal services provided by WealthBlock.ai. This Privacy Policy does not apply to those third-party sites. We encourage you to review the privacy policies of any third-party service provider you interact with through our Site.

7. YOUR RIGHTS AND CHOICES

Depending on your jurisdiction, you may have the right to:

  • Request access to the Personal Information we hold about you.

  • Request the correction of inaccurate information.

  • Request the deletion of your information, subject to legal and regulatory retention requirements (notably financial record-keeping laws).

  • Opt-out of marketing communications.

8. DATA RETENTION

We retain Personal Information for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements.

9. UPDATES TO THIS POLICY

We may update this Privacy Policy from time to time to reflect changes in our practices or legal obligations. The "Effective Date" at the top of this page indicates when the latest revisions were made.

10. CONTACT INFORMATION

If you have any questions or concerns regarding this Privacy Policy or our data practices, please contact:

UpDown Capital
c/o ET Capital Partners
Email: info@etcapitalpartners.com
Website: https://www.updowncapital.com