Last Reviewed: September 21, 2025

Iron Elk Capital Equity Income Fund, LP (the "Fund"), together with its affiliates, including Iron Elk Capital, Inc. (the "General Partner") and Iron Elk Capital Advisors, Inc. (the "Investment Manager") (collectively, "Iron Elk Capital," "we," "us," or "our"), is committed to protecting the privacy and security of your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information in connection with our services, including our investment activities, website (available at: https://ironec.com), and interactions with investors, prospective investors, and other individuals.

As a U.S.-based hedge fund organized as a Delaware limited partnership, we comply with applicable U.S. federal and state privacy laws. By accessing our website, submitting information to us, or engaging in our investment services (including through our Confidential Private Placement Memorandum, Subscription Documents, Limited Partnership Agreement, or Investment Management Agreement), you acknowledge that you have read and understand this Privacy Policy and consent to our practices as described herein.

1. Information We Collect Through This Website

We collect personal information that identifies, relates to, or could reasonably be linked to you or your household ("Personal Information"). The types of Personal Information we may collect include:

Investor and Prospective Investor Information: Name, address, email address, phone number, date of birth, net worth, income, accreditation status.

Contact and Communication Information: Information from emails, phone calls, meetings, or other interactions, including queries about our Fund, performance reports, or risk management.

Website and Digital Information: IP address, browser type, device information, pages visited, and usage data collected via cookies or similar technologies (see Section 8 for details).

Compliance and Regulatory Information: Information required for anti-money laundering (AML), Know Your Customer (KYC), or accreditation verification, such as government-issued identification, proof of address, or source of funds.

We may also collect non-personal information that does not identify you directly, such as aggregated data on website traffic or investment trends.

2. How We Collect Your Information

We collect Personal Information through various means, including:

Directly from You: When you submit subscription documents, complete investor questionnaires, request information, or communicate with us via email, phone, or in-person meetings.

Automatically: Through our website or digital platforms, using cookies, web beacons, or server logs to track usage.

From Third Parties: From service providers (e.g., brokers, custodians, auditors, or legal advisors), regulatory bodies, or public sources for verification purposes.

Through Our Affiliates: Information shared within Iron Elk Capital entities, such as between the General Partner and Investment Manager, for operational efficiency.

3. How We Use Your Information

We use your Personal Information for legitimate business purposes, including:

Providing Investment Services: To process subscriptions, manage your investment account, allocate profits and losses, handle withdrawals, and distribute reports as outlined in our Limited Partnership Agreement and Investment Management Agreement.

Compliance and Risk Management: To verify investor accreditation, conduct anti-money laundering and other "know your customer" checks, monitor risks, and comply with applicable securities laws and regulations, tax laws, and other legal requirements.

Communication: To send you updates on Fund performance, risk metrics (e.g., Sharpe Ratio, Calmar Ratio), investment strategies, or regulatory notices.

Operational Purposes: To administer the Fund, including accounting, auditing, tax preparation, and record-keeping.

Marketing and Relationship Management: To inform you about Fund opportunities or related services, subject to your consent where required.

Security and Fraud Prevention: To protect against unauthorized access, fraud, or legal claims.

We do not sell your Personal Information to third parties.

4. Sharing Your Information

We may share your Personal Information with the following parties for the purposes described above:

Affiliates: Within Iron Elk Capital entities (e.g., General Partner, Investment Manager) to manage the Fund.

Service Providers: Third-party vendors such as administrators, auditors, legal counsel, brokers, custodians, tax advisors, and technology providers. These providers are contractually obligated to protect your information and use it only for the services they provide to us.

Regulatory and Legal Authorities: As required by law, including regulatory filings, tax authorities , or in response to subpoenas, court orders, or audits.

Business Transfers: In the event of a merger, acquisition, or dissolution of the Fund, your information may be transferred as a business asset, subject to confidentiality obligations.

We do not share your Personal Information with unaffiliated third parties for their marketing purposes without your consent.

5. Data Security

We implement reasonable administrative, technical, and physical safeguards to protect your Personal Information from unauthorized access, loss, misuse, or alteration. These measures include encryption, access controls, secure servers, and regular security audits. However, no system is completely secure, and we cannot guarantee the absolute security of your information. In the event of a data breach, we will notify affected individuals and authorities as required by law.

6. Data Retention

We retain any information submitted to us for the purposes outlined in this Privacy Policy, to comply with legal obligations, resolve disputes, and enforce our agreements.

7. Your Rights and Choices

Depending on your location and applicable laws, you may have the following rights regarding your Personal Information:

Access: Request details about the Personal Information we hold about you.

Correction: Request updates to inaccurate or incomplete information.

Deletion: Request deletion of your information, subject to legal retention requirements.

Opt-Out: Opt out of certain data sharing or processing (note: we do not sell data).

Non-Discrimination: We will not discriminate against you for exercising your rights.

To exercise these rights, contact us at the details below. We may verify your identity before responding. For requests under CCPA, CPA, CTDPA, UCPA, or VCDPA, we will respond within 45 days (extendable by 45 days if needed). You may designate an authorized agent to submit requests on your behalf, provided we can verify their authority.

8. Cookies and Tracking Technologies

Our website may use cookies, pixels, and similar technologies to enhance user experience, analyze traffic, and customize content. These may collect data such as your IP address and browsing behavior.

Essential Cookies: Necessary for website functionality.

Analytics Cookies: To understand usage patterns (e.g., via Google Analytics, Meta, Pinterest, or other).

You can manage cookies through your browser settings. Disabling cookies may limit website features. Our site does not currently respond to "Do Not Track" signals.

9. Children's Privacy

Our services are not directed to individuals under 18. We do not knowingly collect Personal Information from children. If we learn we have collected such information, we will delete it promptly, however an incidence case that does not contain any of the deleted information may be logged and retained at our discretion.

10. International Transfers

While our operations are primarily U.S.-based, some data may be processed in Canada (e.g., our physical office in Okotoks) or other locations through service providers. We ensure appropriate safeguards for cross-border transfers, such as standard contractual clauses.

11. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes in our practices or legal requirements. We will post the revised policy on our website with the updated effective date. Continued use of our services after changes constitutes acceptance.

12. Contact Us

If you have questions about this Privacy Policy or our privacy practices, please contact us at:

Email: [email protected]

Phone: 1-888-217-6035

Secured domains that are verified to be owned by Iron Elk Capital Advisors Inc are as follows:

https://ironec.com (this website)

https://ironec.ca (directs to https://ironec.com)

https://ironelkcapital.com (directs to https://ironec.com)

https://ironelkcapital.ca (directs to https://ironec.com)

We will NEVER contact you asking for sensitive information by phone or email. All sensitive information will only be collected through our investor portal via the investor subscription process facilitated by NAV Fund Administration Services. If you ever receive a suspicious call, email or other communication requesting information from us please notify us immediately using the contact information above.

For complaints or disputes, we encourage direct resolution and are dedicated to responding to and dealing with any issues directly.