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PRIVACY NOTICE OF BARCA GLOBAL FUND, LP (the “Partnership”)

 

Dated April 2026

 

Barca Capital, LLC (“Barca Capital”, “we”, “our”, or “us”) is committed to maintaining the privacy of personal information that the Partnership’s limited partners (the “Limited Partners”), prospective Limited Partners and former Limited Partners provide to us. Federal law requires registered investment advisers and private funds to inform investors how we collect, share, and protect nonpublic personal information. This Privacy Notice describes our privacy practices and is provided at the time of subscription and at least annually thereafter, as required by law.

 

Barca Capital Privacy Policy

 

Barca Capital collects nonpublic personal information to process and administer Limited Partners’ business and to ensure that we are satisfying their financial needs. We may collect the following categories of information:

• Information provided to Barca Capital, such as on applications, questionnaires, contracts, or other forms, including names, addresses, phone numbers, social security numbers, and employment, asset, income and other household information.

• Date of birth, government-issued identification numbers, tax identification numbers, and banking information.

• Information regarding your transactions with us, our affiliates, administrators, or service providers, including capital contributions, distributions, account balances, and capital account history.

• Information provided by Limited Partners and their representatives, financial advisors, investment consultants or other financial institutions with whom the Partnership has a relationship and/or whom the Limited Partner may have authorized to provide such information to the Partnership.

• Information received from third parties such as financial advisors, broker-dealers, custodians, administrators, identity verification services, or public databases, where permitted by law.

 

Security Measures: It is the policy of Barca Capital to restrict access to nonpublic personal information to those employees, agents, representatives or third parties that need to know the information to provide products and services to its clients. Barca Capital maintains written policies and procedures reasonably designed to:

 

• Ensure the security and confidentiality of nonpublic personal information;

• Protect against unauthorized access to or use of such information;

• Oversee and monitor service providers that receive, maintain, process, or otherwise have access to customer information; and

• Protect against anticipated threats or hazards to the security or integrity of such information.

 

Our safeguards include administrative, technical and physical measures such as:

• Physical safeguards including locked doors to our office;

• Electronic safeguards including passwords for local network protection, passwords for computer login for on-site computers, and passwords required to access Barca Capital’s cloud storage system; and

• Restriction of access to client information to those required to have access in order to service client needs.

 

Sharing of Nonpublic Information: Barca Capital does not share nonpublic personal information about its clients with anyone except:

• As permitted by law.

• Our affiliates and employees in order to service your investment.

• Service providers that perform services on our behalf (including administrators, auditors, legal counsel, IT providers, compliance consultants, custodians, and other operational service providers), provided that such parties are required to maintain appropriate safeguards and use the information only for permitted purposes.

• Other financial institutions with whom we have a relationship, which may include banks, attorneys, trustees, third-party administrators, registered broker/dealers, auditors, regulators, and transfer agents, in order to service client accounts.

• Regulators, governmental authorities, or law enforcement, as required by applicable law or regulation.

• If requested or approved by the client.

 

Retention of Information

We retain nonpublic personal information for as long as necessary to fulfill the purposes for which it was collected, including to comply with legal, regulatory, accounting, and recordkeeping requirements. Retention periods are determined based on regulatory requirements, contractual obligations, and legitimate business needs.

 

Former Investors

If you cease to be a Limited Partner, we will continue to adhere to the privacy policies and practices described in this Privacy Notice with respect to your information.

 

The Partnership takes its responsibility to protect the privacy and confidentiality of Limited Partner information very seriously. We maintain appropriate administrative, technical and physical safeguards to guard Limited Partners’ nonpublic personal information, as described above.

 

Notice to residents of California

Barca Capital collects and uses information that identifies, describes, references, links or relates to, or is associated with, a particular consumer or device (“Personal Information”), as described above. Personal Information we collect from our customers and consumers is covered under the Gramm-Leach-Bliley Act (“GLBA”) and is therefore excluded from the scope of California Consumer Privacy Act (“CCPA”).

 

However, for website visitors that are not yet Barca Capital customers or consumers, as those terms are defined by GLBA, the personal information we collect during your time on our website is subject to the CCPA. As such, you have privacy rights with respect to your personal information. 

 

We may collect the following categories of personal information from our website:

• Name, email address, phone number, and any other information you provide when you contact us via our website or when you contact us directly.

• Information automatically collected from your browser (e.g., your browser type, operating system type or mobile device model, viewed webpages, links that are clicked, keystrokes typed, movement of the mouse or pointer, IP address, mobile device identifier or other unique identifier, sites or apps visited before coming to our website, the amount of time you spend viewing or using the website, the number of times you return, or other click-stream or site usage data, emails we send that you open, forward, or click through to our website).

 

For our California business contacts, your personal information is subject to the CCPA. If we receive your personal information in the form of contact details from business events, for example as part of a business appointment (e.g., by exchanging business cards) or as part of any other form of collaboration, we may use your contact and business details to maintain our business contacts. For this purpose, we may transfer your contact details to our internal database. Pursuant to the CCPA, you have privacy rights with respect to your business contact personal information.

 

The processing activity may include the following categories of personal information:

• Your contact information (e.g., name, title, form of address or salutation, address, gender, telephone numbers, email address); and

• Details on your profession (e.g., job title, position, personnel number, place of work, branch office, department, qualifications).

 

The processing of the collected data is based on our legitimate business interests. We have a legitimate economic interest in collecting information about potential consumers or customers and their website user data, as well as maintaining business contacts beyond the initial context. These legitimate business interests extend to our use of the personal information to establish and develop a relationship and to remain in contact with the parties concerned. We may disclose this information to the service providers we engage to effectuate these legitimate business interests. Our business contacts could also be processed in our email communications with you and then kept in typical business software, either centrally or on the electronic devices of our employees. 

 

California law provides these website visitors and business contacts with the following rights with respect to their personal information:

• The right to know what personal information we have collected, used, or disclosed about you.

• The right to request that we delete any personal information we have collected about you.

• The right to correct inaccurate personal information about you.

 

California law requires us to identify, for the 12-month period prior to the date of this Privacy Policy, what information we may have “sold” or “shared” about you. For the 12-month period prior to the date of this Privacy Policy, we have not sold or shared any personal information about our website visitors or business contacts.

 

Submitting Requests: You may submit requests to correct, delete, and know specific Personal Information and/or categories of Personal Information we have collected about you by contacting us at +1 415 992-6334 or dthompson@barcacapital.com.

 

Verification of Your Identity: When you exercise these rights and submit a request to us, we or our partners will verify your identity by asking you to authenticate your identity via standard authentication procedures. For example, we may ask for your email address or other identifier. We also may use a third-party verification provider to verify your identity.

 

Non-Discrimination: If you make a request under the CCPA, we will not discriminate against you in any way. For example, we will not deny you goods or services, charge you different prices or rates for goods or services, deny you discounts or other benefits or impose penalties on you, or provide you with or suggest that you will receive a different level or quality of goods or services.

Automated Decision-Making: We generally do not use automated decision-making technology, as that term is defined by the CCPA. If we make use of automated decision-making technology, you will be informed through a separate privacy notice.

 

We provide Limited Partners with a Privacy Notice as part of their subscription materials and annually after that. If we materially change our privacy policies in a manner that would permit disclosures of your nonpublic personal information beyond those permitted by law, we will provide you with advance notice and, if required by law, an opportunity to opt out of such disclosures. If you have any questions, comments or concerns about our Privacy Policy, you may contact us at analyst@barcacapital.com.