PRIVACY POLICY
Cross Market Management Company LLC
Cross Market Fund LLC
Effective Date: February 8, 2026
Last Updated: March 29, 2026
1. INTRODUCTION
Cross Market Management Company LLC and Cross Market Fund LLC ("Cross Market Fund," "the Fund," "we," "our," or "us") are committed to protecting the privacy and security of the personal information of our website visitors, prospective investors, members, and other individuals who interact with us. This Privacy Policy describes how we collect, use, store, share, and protect your personal information when you visit our website at www.crossmarketfund.com (the "Site"), communicate with us, or engage with us as a prospective or current investor.
By accessing or using our Site, you acknowledge that you have read, understood, and agree to the practices described in this Privacy Policy. If you do not agree with this Privacy Policy, please do not access or use our Site or provide us with your personal information.
2. INFORMATION WE COLLECT
We may collect the following categories of information:
2.1 Information You Provide Directly
Contact Information: Name, email address, phone number, mailing address
Professional Information: Employer, job title, professional affiliations
Investor Qualification Information: Income, net worth, accredited investor status, investment experience, and other financial information necessary to evaluate investor eligibility
Account and Subscription Information: Information provided when executing subscription agreements, operating agreements, or other fund documents, including Social Security number or taxpayer identification number, date of birth, citizenship, and banking information for distributions
Communications: Any information you include in emails, contact form submissions, phone calls, or other correspondence with us
Identification Documents: Government-issued identification and other documents provided for identity verification and anti-money laundering compliance
2.2 Information Collected Automatically
When you visit our Site, we may automatically collect certain technical information, including:
Device Information: IP address, browser type and version, operating system, device type
Usage Information: Pages visited, time spent on pages, referring URL, clickstream data, date and time of access
Cookies and Tracking Technologies: We may use cookies, web beacons, pixel tags, and similar technologies to collect information about your browsing behavior and preferences. See Section 7 (Cookies and Tracking Technologies) for more details.
2.3 Information from Third Parties
We may receive information about you from third-party sources, including:
Identity verification and background check services
Anti-money laundering (AML) and know-your-customer (KYC) compliance providers
Financial advisors, attorneys, or other professionals acting on your behalf with your authorization
Publicly available sources
3. HOW WE USE YOUR INFORMATION
We may use the information we collect for the following purposes:
Investor Relations: To evaluate investor eligibility, process subscription agreements, manage member accounts, distribute K-1 tax documents, and facilitate investment-related communications
Communications: To respond to inquiries, provide requested information, send investment updates, and communicate regarding fund activities
Legal and Regulatory Compliance: To comply with applicable federal, state, and local laws and regulations, including securities laws, tax reporting obligations, anti-money laundering requirements, and know-your-customer obligations
Site Operations: To operate, maintain, and improve our website, ensure security, and analyze usage patterns
Fraud Prevention: To detect, prevent, and address fraud, security breaches, and other potentially prohibited or illegal activities
Contractual Obligations: To fulfill our obligations under the Fund's Operating Agreement, subscription documents, and other contractual arrangements
Business Operations: To manage internal operations, record keeping, reporting, and administrative functions of the Fund and Cross Market Management LLC
4. HOW WE SHARE YOUR INFORMATION
We do not sell, rent, or trade your personal information to third parties for marketing purposes. We may share your information in the following circumstances:
4.1 Service Providers
We may share your information with trusted third-party service providers who assist us in operating our business, including:
Legal counsel and accounting firms
Tax preparation and K-1 processing services
Fund administration service providers
Identity verification and AML/KYC compliance providers
IT, hosting, and cybersecurity service providers
Communication and email service providers
All service providers are contractually obligated to protect the confidentiality and security of your information and to use it only for the purposes for which it was disclosed.
4.2 Legal and Regulatory Disclosures
In response to a subpoena, court order, or other legal process
To comply with applicable securities laws, tax laws, and regulatory requirements
To cooperate with governmental or regulatory investigations
To report suspicious activity as required by anti-money laundering laws
To enforce our legal rights, terms, and agreements
4.3 Fund Management
Your information may be shared with Cross Market Management LLC, its principals, officers, and authorized representatives as necessary to manage the Fund, evaluate investment opportunities, administer member accounts, and fulfill fiduciary and contractual obligations.
4.4 Business Transfers
In the event of a merger, acquisition, reorganization, dissolution, or similar transaction involving Cross Market Fund LLC or Cross Market Management LLC, your information may be transferred as part of that transaction. We will notify affected individuals of any such transfer and any choices they may have regarding their information.
4.5 With Your Consent
We may share your information with third parties when you have provided explicit consent to do so.
5. DATA SECURITY
We implement reasonable administrative, technical, and physical safeguards designed to protect your personal information from unauthorized access, use, alteration, disclosure, or destruction. These measures include:
Encryption of sensitive data in transit and at rest
Secure access controls and authentication procedures
Regular security assessments and monitoring
Employee and contractor confidentiality obligations
Secure document storage and disposal practices
However, no method of transmission over the Internet or electronic storage is 100% secure. While we strive to protect your information, we cannot guarantee absolute security. You are responsible for maintaining the confidentiality of any login credentials or account information provided to you.
6. DATA RETENTION
We retain your personal information for as long as necessary to fulfill the purposes for which it was collected, including:
For the duration of your membership or investment in the Fund
As required to comply with applicable legal, regulatory, tax, and accounting obligations
As necessary to resolve disputes, enforce agreements, and protect our legal rights
For a reasonable period following the termination of your membership or relationship with the Fund, consistent with applicable record retention requirements
Investor records, tax documents, and regulatory compliance records may be retained for a minimum of seven (7) years following the termination of your investment or as otherwise required by law.
7. COOKIES AND TRACKING TECHNOLOGIES
7.1 What Are Cookies?
Cookies are small text files placed on your device when you visit a website. They help the website recognize your device and remember certain information about your visit.
7.2 How We Use Cookies
We may use the following types of cookies:
Cookie Type
Purpose
Strictly Necessary
Required for the Site to function properly, including security and access features
Analytical/Performance
Help us understand how visitors use the Site, which pages are most popular, and how to improve the user experience
Functional
Remember your preferences and settings to enhance your experience
7.3 Managing Cookies
Most web browsers allow you to manage cookie preferences through browser settings. You may disable or delete cookies at any time; however, doing so may affect the functionality of certain features of the Site. For more information about managing cookies, visit [www.allaboutcookies.org](http://www.allaboutcookies.org).
7.4 Do Not Track
Some browsers offer a "Do Not Track" (DNT) signal. Our Site does not currently respond to DNT signals. However, you may manage your tracking preferences through your browser settings and cookie preferences as described above.
8. YOUR RIGHTS AND CHOICES
Depending on your jurisdiction, you may have certain rights regarding your personal information, including:
Access: The right to request a copy of the personal information we hold about you
Correction: The right to request correction of inaccurate or incomplete information
Deletion: The right to request deletion of your personal information, subject to legal and regulatory retention requirements
Restriction: The right to request that we restrict processing of your information in certain circumstances
Portability: The right to receive your personal information in a structured, commonly used, machine-readable format
Objection: The right to object to certain processing activities
Withdrawal of Consent: Where processing is based on consent, the right to withdraw consent at any time without affecting the lawfulness of prior processing
To exercise any of these rights, please contact us using the information provided in Section 12 below. We may require identity verification before fulfilling your request. Please note that certain rights may be limited where we have a legitimate legal basis for processing or are required to retain information for regulatory compliance.
9. CHILDREN'S PRIVACY
Our Site and services are not directed to individuals under the age of 18. We do not knowingly collect personal information from children under 18. If we become aware that we have collected personal information from a child under 18, we will take steps to delete such information promptly. If you believe a child has provided us with personal information, please contact us immediately.
10. THIRD-PARTY LINKS
Our Site may contain links to third-party websites, services, or platforms that are not owned or controlled by Cross Market Fund LLC. This Privacy Policy does not apply to those third-party sites. We are not responsible for the privacy practices, content, or security of any third-party websites. We encourage you to review the privacy policies of any third-party sites you visit.
11. CHANGES TO THIS PRIVACY POLICY
We reserve the right to update or modify this Privacy Policy at any time. When we make changes, we will update the "Last Updated" date at the top of this page. Material changes may be communicated through a notice on the Site or by direct communication to members and registered users. Your continued use of the Site following any changes constitutes acceptance of the updated Privacy Policy. We encourage you to review this page periodically.
12. CONTACT US
If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:
Cross Market Fund LLC
Cross Market Management Company LLC
206 S Clay Street
Ennis, TX 75119
Email: [email protected]
Phone: 214-435-5712