Varick Capital Partners LP and related entities (‘Varick’) is committed to protecting your personal data and respecting your privacy. This Privacy Policy explains how we collect, use and protect your personal data when you visit our website, in accordance with applicable legislation, such as the EU General Data Protection Regulation (GDPR).

Varick Capital Partners LP is registered with the US Commodity Futures Trading Commission (CFTC) as a Commodity Pool Operator (CPO) and as a Commodity Trading Advisor (CTA) and a member of the National Futures Association (NFA) in such capacities.

Our website is hosted in the European Union. If you have any questions about this policy, you can contact us at:
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Email: info@varick.ai

CONTACT ADDRESS:
Varick Capital Partners LP
Amstelplein 1
1096 HA Amsterdam
The Netherlands

WHAT PERSONAL DATA WE COLLECT
Varick may collect and process the following categories of personal data:

- Contact details (name, email address, phone number)
- Professional information (company name, position)
- Reputable service providers (e.g. email), under data processing agreements
- Technical data (IP address, browser type, device type)
- Website usage data (pages visited, time spent onsite, navigation paths)

We do not knowingly collect personal data from children under 18.

HOW WE USE YOUR DATA
Varick processes your data for the following purposes:

Legal Basis

Legitimate interest / Consent
Consent
Legal obligation

We do not use your personal data for automated decision-making or profiling.

WHO HAS ACCESS TO YOUR DATA
Your data may be shared with:

- Our internal team for operational purposes
- Our legal or compliance advisors (as and when necessary)
- Reputable service providers (e.g., email), under data processing agreements

Varick does not sell or rent your personal data to third parties.

INTERNATIONAL TRANSFER OF DATA TO THIRD PARTIES
Varick may transfer your personal data to third parties through the use of and store data on the servers of a cloud service provider. We have entered into a data processing agreement with our cloud service provider which guarantees an adequate level of data protection.
We ensure that appropriate safeguards are in place, such as:

- Standard Contractual Clauses approved by the European Commission
- Data transfer agreements with service providers
- Processing only by trusted vendors in jurisdictions with adequate protection

We may need to transfer personal data to parties that are located in countries outside of the EEA that are not recognized to provide an adequate level of data protection according to EEA standards. Regulations with respect to the protection of personal data can be less strict in such countries, as a result of which personal data may be less adequately protected. In such case, where necessary or appropriate, we will adopt safeguards to ensure an appropriate level of protection of your personal data.

DATA RETENTION
Varick retains your personal data only for as long as necessary to fulfil the purposes described above or to comply with legal obligations. Retention periods depend on:
The nature of the interaction (e.g. inquiry vs. client onboarding) or applicable regulatory requirements.

YOUR RIGHTS UNDER GDPR
You have the following rights, subject to applicable exceptions:

- Right of access – Request a copy of your personal data
- Right to rectification – Correct inaccurate or incomplete data
- Right to erasure – Request deletion of your data ("right to be forgotten")
- Right to restrict processing – Limit how your data is used
- Right to data portability – Receive your data in a structured format
- Right to object – Oppose certain types of processing (e.g., marketing)
- Right to withdraw consent – Where applicable, withdraw your consent at any time

To exercise these rights, email us at info@varick.ai

If you believe your data protection rights have been violated, you also have the right to lodge a complaint with your local supervisory authority.

- Encrypted data transmission
- Access controls
- Regular security monitoring

SECURITY MEASURES
We implement appropriate technical and organizational measures to protect your personal data from unauthorized access, disclosure, or destruction, including:

The security and confidentiality of your information is extremely important to us. All personal data which is collected and recorded, whether on paper or electronically, has appropriate safeguards applied in line with our legal obligations.

Data is protected by our internal policies and procedures designed to minimise loss or damage through accident, negligence or deliberate actions. Our employees undertake regular training in relation to data protection and are subject to duties of confidentiality which apply to the personal data we obtain and process.

Our Information security controls are aligned to industry standards and good practice. This provides a secure control environment that effectively manages risks to the confidentiality, integrity and availability of information. Additionally our controls ensure we can restore your data in situations where the data is corrupted or lost in a disaster recovery situation.

Where appropriate, we use encryption or other security measures which we deem appropriate to protect your information. We also review our security procedures periodically to consider appropriate new technology and updated methods. But, despite our reasonable efforts, no security measure can ever be perfect or impenetrable.

Our employees are bound by internal policies that require confidential treatment of personal data.

CHANGES TO THIS POLICY
We may update this Privacy Policy from time to time. The latest version will always be available on this page and as such we will notify you of material changes where required by law.

Last updated: January 2026.
‍Contact: info@varick.ai
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