PRIVACY POLICY

Last Updated: 6 March 2026

S10X Carbon Fund, LLC (“S10X”, “we”, “us”, or “our”) is committed to protecting your privacy and the security of personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard personal information when you visit our website (www.s10xcarbonfund.com), register for or use our Applications (Register, Secretarial Portal, Survey), purchase carbon credits, or otherwise interact with our services.

We process personal information in compliance with applicable data protection laws, including the Protection of Personal Information Act (POPIA) (South Africa), the General Data Protection Regulation (GDPR) (European Union), and other relevant privacy laws.

1. Data Controller

S10X Carbon Fund, LLC
651 North Broad Street
Middletown, DE 19709
United States

Email: privacy@s10xcarbonfund.com

2. Personal Information We Collect

Information You Provide

We collect information you voluntarily provide, such as:

  • Full name
  • Email address
  • Phone number
  • Company/organization name and details
  • Project/site survey data
  • Information submitted via registration, contact forms, inquiries, or communications

Information Collected Automatically

When you access our website or Applications, we may automatically collect:

  • IP address
  • Browser type and version
  • Device type and operating system
  • Referring URLs and pages visited
  • Time and duration of visits
  • Approximate geographic location (derived from IP)

Cookies and Similar Technologies

We use cookies, web beacons, pixels, and similar technologies for functionality, analytics, security, and performance. You can manage preferences via your browser settings or our cookie consent tool (where applicable).

3. Legal Basis for Processing (where GDPR applies)
  • Legitimate interests – operating, securing, and improving our website, Applications, and services
  • Consent – where you have given clear consent (e.g., for certain cookies or marketing)
  • Contractual necessity – to perform our obligations under agreements or respond to your requests
  • Legal obligation – to comply with laws, regulations, or lawful requests
4. How We Use Personal Information
  • To provide, maintain, and improve our website and Applications
  • To process registrations, project submissions, surveys, and carbon credit purchases
  • To respond to inquiries, support requests, and communications
  • To verify identity and prevent fraud or unauthorized access
  • To analyze usage trends and enhance user experience
  • To comply with legal, tax, regulatory, or carbon market obligations
  • To send service-related notices or updates (where permitted)
5. Disclosure of Personal Information

We do not sell personal information to third parties.

We may share personal information with:

  • Service providers (e.g., hosting, cloud storage, analytics, email, verification/verification bodies, IT/security providers) under strict confidentiality obligations
  • Regulatory authorities, government bodies, or law enforcement when required by law
  • Third parties in connection with a merger, acquisition, reorganization, or asset sale (with notice where feasible)
  • Carbon market participants or verifiers (only as necessary for project validation, credit issuance, or retirement processes)
6. International Data Transfers

Your personal information may be transferred to and processed in the United States, South Africa, or other countries where we or our service providers operate. These jurisdictions may have different data protection standards.

We use appropriate safeguards for transfers outside South Africa or the EEA, such as standard contractual clauses, binding corporate rules, adequacy decisions, or other mechanisms recognized under POPIA and GDPR.

7. Data Security

We implement reasonable administrative, technical, and physical safeguards to protect personal information from unauthorized access, loss, misuse, alteration, or destruction. However, no internet-based system or electronic storage is 100% secure, and we cannot guarantee absolute security.

8. Data Retention

We retain personal information only for as long as necessary to fulfill the purposes outlined in this Policy, comply with legal/tax obligations, resolve disputes, or enforce agreements. After this period, data is securely deleted, destroyed, or anonymized where possible.

9. Your Rights

Subject to applicable law (including POPIA and GDPR), you may have the right to:

  • Access your personal information
  • Request correction of inaccurate or incomplete data
  • Request deletion/erasure in certain circumstances
  • Restrict or object to certain processing
  • Request data portability (where technically feasible)
  • Withdraw consent at any time (where processing is consent-based)
  • Lodge a complaint with a supervisory authority (e.g., Information Regulator in South Africa)

To exercise these rights, please contact us at privacy@s10xcarbonfund.com. We will respond within the timeframes required by law.

10. Cookies and Tracking Technologies

You can manage or disable cookies through your browser settings. Note that disabling certain cookies may limit website functionality.

11. Third-Party Links

Our website the Applications may link to third-party sites. We are not responsible for their privacy practices or content.

12. Children's Privacy

Our services are not directed at children under 16 (or the applicable age of consent in your jurisdiction). We do not knowingly collect personal information from children. If we learn we have done so, we will promptly delete it.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Changes will be posted here with an updated “Last Updated” date. Significant changes may be communicated via email or website notice where appropriate.

14. Contact Us

S10X Carbon Fund, LLC
651 North Broad Street
Middletown, DE 19709
United States

Email: privacy@s10xcarbonfund.com