Global Website Terms & Conditions of Use

1. Website Operator and elevator21 Group

The website accessible at elevator21.com and related public pages (the “Website”) is operated by Elevator21 Inc. (“elevator21”, “we”, “us”), a Delaware corporation and the parent company and global headquarters of the Elevator21 group.

Elevator21 Inc. was formed in Delaware on 19 March 2025 and has Delaware State File Number 10136305. Its Delaware registered office is 16192 Coastal Highway, Lewes, Delaware 19958, County of Sussex, United States.

The Elevator21 group also operates through the following wholly owned subsidiaries:

The elevator21 entity providing a particular service will be identified in the applicable contractual documentation. The Website Terms do not by themselves determine which group entity is the contracting or service-providing entity.

2. Scope and Acceptance

These Terms govern access to and use of the public Website. By accessing or using the Website, you agree to these Terms. If you do not agree, you must cease using the Website.

The Terms apply to the Website only. Fund administration, accounting, investor services, technology, operational support and other professional services are governed by separate written agreements. A Services Agreement or product- or portal-specific terms prevail over these Terms to the extent of any conflict.

The Global Privacy Notice and Cookie Notice are incorporated by reference.

3. Intended Audience and Territorial Restrictions

The Website is principally intended for professional and institutional audiences, including alternative investment fund managers, general partners, investment advisers, institutional investors, family offices, fund operators and professional advisers.

The Website is not directed at consumers as a primary audience. Nothing on the Website is intended to cause elevator21 or any group entity to conduct regulated activity, solicit investments or provide a service in a jurisdiction where it is not permitted to do so.

Users are responsible for complying with laws applicable to them and for ensuring that access to and use of the Website is lawful in their jurisdiction.

4. No Offer, Solicitation or Professional Advice

Website content is provided for general information only. It does not constitute an offer, solicitation or invitation to acquire a security, fund interest, financial instrument or investment product, nor investment, legal, tax, accounting or regulatory advice.

Access to the Website does not create a client, advisory, fiduciary, agency, partnership or other professional relationship. Any such relationship arises only under a separate written agreement.

Examples, demonstrations, model outputs, workflow descriptions, service levels, timelines and other illustrative material are indicative only and are not contractual commitments unless expressly incorporated into a written agreement.

5. Regulatory Status

elevator21 operates through different group entities and jurisdictions. Regulatory status depends on the relevant entity and activity. Nothing on the Website represents that any elevator21 entity is licensed, authorised, registered or supervised for a regulated activity unless that is expressly and factually stated.

Elevator21 Luxembourg S.à r.l. is not authorised or supervised by the Commission de Surveillance du Secteur Financier (CSSF) unless and until it obtains the relevant authorisation. Nothing on the Website should be construed as representing otherwise.

The Website does not constitute a public offering, financial promotion or solicitation where such activity would require an authorisation that the relevant elevator21 entity does not hold.

6. Portal Access and Security

Authenticated areas may be made available to authorised users. Access is personal and may be suspended or withdrawn for security, legal, regulatory or operational reasons.

Users must keep credentials and authentication factors confidential and must notify elevator21 promptly through website@elevator21.com of suspected compromise, loss or unauthorised use.

7. Acceptable Use

• access or attempt to access systems, accounts or data without authorisation or circumvent security controls;
• introduce malicious code, conduct denial-of-service activity or impose an unreasonable load on the Website or supporting infrastructure;
• conduct penetration testing, vulnerability scanning or security research without prior written consent;
• use robots, scrapers, crawlers or other automated means to extract or systematically copy Website content or databases except where expressly permitted by law;
• use Website content to train, fine-tune, evaluate or ground an artificial-intelligence or machine-learning model where prohibited by elevator21's rights or applicable law;
• resell, sublicense, frame, mirror or commercially exploit the Website or its content without permission;
• impersonate a person, misrepresent an affiliation, submit false or misleading information, or infringe third-party rights; or
• use the Website in breach of applicable law, sanctions or other mandatory restrictions.

8. Intellectual Property and Third-Party Content

The Website and its content, including text, graphics, interfaces, databases, methodologies, documentation, software, trademarks and logos, are owned by elevator21 or its licensors and protected by applicable intellectual-property laws.

Subject to these Terms, elevator21 grants a limited, revocable, non-exclusive, non-transferable right to access and display Website content for the user's own internal professional purposes. No other licence is granted.

Third-party links, embedded content and services are provided for convenience. elevator21 does not control or accept responsibility for third-party content, services or privacy practices.

9. Personal Data and Cookies

elevator21 processes personal data in accordance with applicable data-protection laws. The Global Privacy Notice describes the relevant entities, processing purposes, legal bases where applicable, recipients, transfers, retention and rights.

Cookies and similar technologies are described in the Global Cookie Notice. Where applicable law requires prior consent for non-essential cookies or similar technologies, elevator21 will obtain that consent before deployment.

10. Confidentiality, Financial Crime and Sanctions

Non-public information made available through restricted areas or otherwise disclosed under a contractual relationship must be treated as confidential in accordance with the applicable agreement.

elevator21 may conduct customer due diligence, sanctions screening and other financial-crime controls where required by applicable law or relevant to its services. elevator21 may refuse, suspend or terminate access or a relationship where necessary to comply with law or manage sanctions or financial-crime risk.

11. Availability and Warranties

The Website is provided on an “as is” and “as available” basis. elevator21 does not warrant uninterrupted, secure or error-free access or that Website content is complete, current or fit for a particular purpose.

elevator21 may modify, suspend or discontinue the Website for maintenance, security, legal, regulatory or operational reasons.

12. Liability

To the fullest extent permitted by applicable law, elevator21 shall not be liable for indirect or consequential loss, loss of profit, revenue, business, opportunity or goodwill arising solely from use of the Website.

To the fullest extent permitted by applicable law, elevator21's aggregate liability arising solely from use of the Website or these Terms shall not exceed EUR 1,000 in any twelve-month period.

Nothing in these Terms excludes or limits liability that cannot lawfully be excluded or limited, including liability for fraud, wilful misconduct, gross negligence, death or personal injury caused by negligence, or other mandatory liability.

Liability for services provided under a Services Agreement is governed by that agreement.

13. Indemnity

To the fullest extent permitted by applicable law, you shall indemnify elevator21 and its relevant affiliates, officers, employees and agents against losses and reasonable costs arising from your material breach of these Terms or unlawful or unauthorised use of the Website.

14. Electronic Communications

Electronic communications and records may be used to the extent permitted by applicable law. Website Terms do not require elevator21 to accept electronic submissions or communications as a binding service request unless expressly stated.

15. Complaints and Security Notifications

Website-related complaints, privacy matters, cookie enquiries and security notifications may be addressed to website@elevator21.com. Any regulatory complaints procedure applies only where the relevant elevator21 entity is subject to that regulatory regime.

16. Changes

elevator21 may amend these Terms from time to time. The current version and effective date will be published on the Website. Continued use after an amended version becomes effective constitutes acceptance to the extent permitted by applicable law.

17. Governing Law, Jurisdiction and Mandatory Local Law

These Terms and non-contractual obligations arising from them are governed by the laws of the State of Delaware, United States, without prejudice to mandatory provisions of the law of the jurisdiction in which a user is located or in which a relevant elevator21 entity provides services.

Subject to mandatory jurisdictional rules, the courts of the State of Delaware have jurisdiction over disputes arising from these Terms. This does not exclude mandatory rights or remedies available under applicable Luxembourg, Hong Kong, United States or other local law.

The Terms are drafted in English. Any translation is provided for convenience only, and the English version prevails except where mandatory law provides otherwise.

18. Contact

Elevator21 Inc., 16192 Coastal Highway, Lewes, Delaware 19958, United States · website@elevator21.com