POLICY

Privacy Policy

Version 1.0 | Effective date: Feb 3, 2026

At EIGEN (“EIGEN ,” “we,” “us,” or “our”), your privacy is important to us. This Privacy Policy describes how we collect, use, disclose, and safeguard your personal information when you access our website, investor portal, or other online services (collectively, the “Services”).

By using the Services, you consent to the collection and use of your information as outlined in this Policy.

1. Information We Collect

1.1 Information You Provide
We collect personal information you voluntarily provide when you:

  • Establish a relationship with us

  • Inquire about or subscribe to investment opportunities

  • Complete investor documentation

  • Contact us for support

This may include:

  • Name, email address, and phone number

  • Investment details, account credentials, and contact preferences

  • Documentation provided for compliance or suitability assessments

1.2 Information Collected Automatically
We may collect limited technical data when you use the Services, such as:

  • IP address, browser type, operating system, and access time

  • Cookie identifiers and device information

1.3 Information from Relationships
In accordance with Rule 506(C) of Regulation D, we may collect information through pre-existing business relationships or personal introductions to ensure compliance with private placement requirements.

2. Use of Information

We use your personal information to:

  • Establish and maintain investor relationships

  • Provide secure access to the Services

  • Comply with applicable laws, including securities and anti-money laundering regulations

  • Send relevant fund updates, administrative notices, or investor communications

  • Improve the quality and functionality of our Services

We process this information based on contractual necessity, legal obligations, and legitimate business interests.

3. Sharing of Information

We may share your information:

  • With legal or compliance service providers

  • With administrative vendors who support our platform (e.g., hosting, reporting tools)

  • When required by law or regulators (e.g., SEC or IRS)

  • In the event of a corporate transaction such as a merger or acquisition

We do not sell or publicly disclose your personal information to third parties for marketing purposes.

4. Data Security

We implement industry-standard physical, technical, and administrative safeguards to protect your information. However, no online system is completely secure. You are encouraged to use strong passwords and be cautious when sharing sensitive information.

5. Data Retention

We retain your information as long as necessary to:

  • Comply with legal and regulatory requirements

  • Manage investor relationships and reporting

  • Support business operations and financial recordkeeping

6. Your Rights & Choices

You may:

  • Request access to, update, or correct your personal information

  • Request deletion of your data, subject to legal retention requirements

  • Opt out of non-essential communications by clicking “unsubscribe” links or contacting us directly

7. Cookies and Analytics

We may use cookies and limited analytics tools to improve site performance and track engagement. You may control cookies through your browser settings. No identifiable investment data is tracked via cookies.

8. Aggregate and De-Identified Data

We may use anonymized or aggregated data for internal analysis, system optimization, or regulatory reporting. This information cannot be used to identify you.

9. Children’s Privacy

Our Services are intended for individuals 18 years of age or older. We do not knowingly collect personal data from minors. If such data is discovered, it will be deleted promptly.

10. International Data Transfers

If you are located outside the United States, please note that your information may be processed and stored in the U.S., where data protection laws may differ from those in your jurisdiction.

11. Changes to This Policy

We may update this Privacy Policy periodically. Updates will be posted on this page with a revised effective date. Continued use of the Services after updates constitutes acceptance of the changes.

12. Contact Us

If you have any questions about this Privacy Policy or how your data is handled, please contact: icwtholdings@icwtllc.com

Built for Investors
Who Demand Precision

Eigen Quant Fund delivers disciplined, AI-driven quantitative strategies to both accredited and non-accredited investors. Explore transparent performance analytics, systematic allocation models, and next-generation trading infrastructure.

Get Started

VC's/Family Offices

Regulations:

Eigen serves as the Fund’s trading technology provider, supplying the quantitative systems, execution architecture, and supporting infrastructure behind the platform’s market operations. The Fund is offered through a private placement pursuant to Rule 506(c) of Regulation D under the Securities Act of 1933. As such, participation is restricted exclusively to verified accredited investors, and the offering may be promoted through general solicitation in accordance with applicable U.S. securities laws.

In connection with its operating framework, Eigen collaborates with Pioneer Asset Management AG (“Pioneer”), a Swiss financial services firm regulated under the Swiss Financial Institutions Act (FinIA). Pioneer operates under the oversight of a self-regulatory organization recognized by the Swiss Financial Market Supervisory Authority (FINMA) and provides investment-related services in accordance with the laws and regulatory standards of Switzerland.

Disclaimer:

Participation in financial markets, including foreign exchange, derivatives, and other leveraged instruments, entails substantial risk and may not be suitable for all investors. Leverage can amplify both gains and losses, and investors may incur losses that exceed their original capital commitment. Past or targeted performance is not a guarantee of future results. Each investor should conduct an independent assessment of their financial circumstances, sophistication, investment objectives, and risk tolerance before making any investment decision.

This presentation is provided exclusively for informational and discussion purposes. It does not constitute an offer to sell, or a solicitation of an offer to buy, any securities or investment interests. Any such offer may be made only pursuant to the Fund’s private placement memorandum, subscription documents, and other governing offering materials, which should be reviewed carefully in their entirety. An investment in the Fund involves significant risks, including the risk of partial or total loss of invested capital.

© 2026 EIGEN. All rights reserved.

Privacy Policy

Terms of Use

Built for Investors
Who Demand Precision

Eigen Quant Fund delivers disciplined, AI-driven quantitative strategies to both accredited and non-accredited investors. Explore transparent performance analytics, systematic allocation models, and next-generation trading infrastructure.

Get Started

VC's/Family Offices

Regulations:

Eigen serves as the Fund’s trading technology provider, supplying the quantitative systems, execution architecture, and supporting infrastructure behind the platform’s market operations. The Fund is offered through a private placement pursuant to Rule 506(c) of Regulation D under the Securities Act of 1933. As such, participation is restricted exclusively to verified accredited investors, and the offering may be promoted through general solicitation in accordance with applicable U.S. securities laws.

In connection with its operating framework, Eigen collaborates with Pioneer Asset Management AG (“Pioneer”), a Swiss financial services firm regulated under the Swiss Financial Institutions Act (FinIA). Pioneer operates under the oversight of a self-regulatory organization recognized by the Swiss Financial Market Supervisory Authority (FINMA) and provides investment-related services in accordance with the laws and regulatory standards of Switzerland.

Disclaimer:

Participation in financial markets, including foreign exchange, derivatives, and other leveraged instruments, entails substantial risk and may not be suitable for all investors. Leverage can amplify both gains and losses, and investors may incur losses that exceed their original capital commitment. Past or targeted performance is not a guarantee of future results. Each investor should conduct an independent assessment of their financial circumstances, sophistication, investment objectives, and risk tolerance before making any investment decision.

This presentation is provided exclusively for informational and discussion purposes. It does not constitute an offer to sell, or a solicitation of an offer to buy, any securities or investment interests. Any such offer may be made only pursuant to the Fund’s private placement memorandum, subscription documents, and other governing offering materials, which should be reviewed carefully in their entirety. An investment in the Fund involves significant risks, including the risk of partial or total loss of invested capital.

© 2026 EIGEN. All rights reserved.

Privacy Policy

Terms of Use

Built for Investors Who Demand Precision

Eigen Quant Fund delivers disciplined, AI-driven quantitative strategies to both accredited and non-accredited investors. Explore transparent performance analytics, systematic allocation models, and next-generation trading infrastructure.

Get Started

VC's/Family Offices

Regulations:

Eigen serves as the Fund’s trading technology provider, supplying the quantitative systems, execution architecture, and supporting infrastructure behind the platform’s market operations. The Fund is offered through a private placement pursuant to Rule 506(c) of Regulation D under the Securities Act of 1933. As such, participation is restricted exclusively to verified accredited investors, and the offering may be promoted through general solicitation in accordance with applicable U.S. securities laws.

In connection with its operating framework, Eigen collaborates with Pioneer Asset Management AG (“Pioneer”), a Swiss financial services firm regulated under the Swiss Financial Institutions Act (FinIA). Pioneer operates under the oversight of a self-regulatory organization recognized by the Swiss Financial Market Supervisory Authority (FINMA) and provides investment-related services in accordance with the laws and regulatory standards of Switzerland.

Disclaimer:

Participation in financial markets, including foreign exchange, derivatives, and other leveraged instruments, entails substantial risk and may not be suitable for all investors. Leverage can amplify both gains and losses, and investors may incur losses that exceed their original capital commitment. Past or targeted performance is not a guarantee of future results. Each investor should conduct an independent assessment of their financial circumstances, sophistication, investment objectives, and risk tolerance before making any investment decision.

This presentation is provided exclusively for informational and discussion purposes. It does not constitute an offer to sell, or a solicitation of an offer to buy, any securities or investment interests. Any such offer may be made only pursuant to the Fund’s private placement memorandum, subscription documents, and other governing offering materials, which should be reviewed carefully in their entirety. An investment in the Fund involves significant risks, including the risk of partial or total loss of invested capital.

© 2026 EIGEN. All rights reserved.

Privacy Policy

Terms of Use