Privacy Policy

Phoenix Agentics Commodity Pool

Phoenix Agentics Capital Management LLC, a Delaware limited liability company (the “Manager,” “we,” “us,” or “our”), serves as the commodity pool operator and investment manager of the Phoenix Agentics Commodity Pool (the “Pool”). This Privacy Policy explains how we collect, use, disclose, and protect personal information obtained through the phoenixagentics.com website (the “Site”) and in the course of administering the Pool. By accessing the Site or submitting a request for offering materials, you acknowledge that you have read and understood this Privacy Policy.

1. Information We Collect

A. Information You Provide Directly

Name, email address, telephone number, and entity/individual type submitted via the QEP questionnaire/contact form. Additional information provided during QEP verification, onboarding, subscription, or redemption processes (e.g., identity documents, accreditation/QEP certifications, tax forms). Correspondence and communications with us.

B. Information Collected Automatically

IP address, browser type, operating system, referring URLs, and pages viewed (via server logs). We do not use cookies, analytics scripts, or third-party tracking technologies on the public portion of the Site.

C. Information from Third Parties

Administrators, prime brokers, auditors, and legal counsel may share KYC/AML verification results or tax reporting data.

2. How We Use Your Information

We use personal information solely for legitimate business purposes related to the Pool, including: Verifying Qualified Eligible Person (QEP) status under CFTC Rule 4.7. Providing confidential offering materials and subscription documents. Managing investor relations, capital accounts, and redemptions. Complying with legal, regulatory, and tax reporting obligations (CFTC, IRS, Cayman Islands Monetary Authority, etc.). Communicating material updates about the Pool.

3. How We Share Your Information

4. Data Retention

We retain personal information for as long as necessary to fulfill the purposes above and to comply with applicable recordkeeping requirements (minimum 5 years under CFTC/NFA rules, longer where required by tax or anti-money-laundering laws).

5. Security

We implement reasonable administrative, technical, and physical safeguards appropriate to the sensitivity of the information, including encryption in transit and at rest, restricted access controls, and secure document delivery systems.

6. International Data Transfers

The Pool is structured with a Cayman Islands master fund and U.S. feeder. Personal data may be transferred to and processed in the United States, Cayman Islands, and other jurisdictions where our service providers operate. Such transfers are protected by Standard Contractual Clauses or adequacy decisions where applicable.

7. Your Rights

Depending on your jurisdiction, you may have rights to access, correct, or delete your personal information. Requests should be submitted in writing to the contact below. We will respond within the timeframes required by applicable law.

8. Children's Privacy

The Site and the Pool are not directed to individuals under the age of 18. We do not knowingly collect personal information from children.

9. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be communicated to existing investors via email and posted on the Site.

10. Contact Us

Last Updated: December 3, 2025