Beneficial Returns and The Reciprocity Fund (“we,” “us,” or “our”) are committed to protecting your privacy and handling personal data in a transparent and responsible way.

This Privacy Policy explains how we collect, use, store, and protect personal information when you visit our websites, interact with us, or communicate with us.

This Privacy Policy applies globally and covers, among others:

• https://www.beneficialreturns.com
• https://www.thereciprocityfund.com

It is intended to comply with applicable data protection laws, including the EU General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA).

Information We Collect

We may collect the following types of information:

Personal information, such as your name, email address, organization or affiliation, and any information you choose to provide when contacting us or signing up for communications.

Automatically collected information, such as IP address, browser type, device information, pages visited, time spent on the site, and referring URLs. This information is collected using cookies and similar technologies.

How We Use Your Information

We use personal information to:

• Respond to inquiries and communications
• Share updates, newsletters, and other information you request
• Manage relationships with investors, partners, and borrowers
• Operate and improve our websites
• Meet legal, regulatory, or compliance obligations

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

Legal Basis for Processing (GDPR)

For users in the European Economic Area (EEA), we process personal data based on:

• Consent, where you have explicitly agreed (e.g. newsletters, forms, cookies)
• Legitimate interests, such as relationship management and basic operations
• Legal obligations, where applicable

You may withdraw consent at any time.

How We Share Information

We do not sell personal information.

We may share personal information with trusted service providers (such as website hosting and email platforms) solely for operational purposes. These providers are required to protect your information.

We may also disclose information if required by law.

Data Retention

We retain personal information only for as long as necessary to fulfill the purposes described in this Privacy Policy, unless a longer retention period is required by law.

Data Security

We take reasonable technical and organizational measures to protect personal information. However, no system is completely secure, and we cannot guarantee absolute security.

Your Rights (GDPR – EU/EEA Users)

If you are located in the EU or EEA, you have the right to:

• Access your personal data
• Request correction or deletion
• Restrict or object to processing
• Withdraw consent at any time
• Lodge a complaint with a data protection authority

Additional Rights for California Residents (CCPA)

If you are a California resident, you have the right to:

• Know what personal information we collect and how it is used
• Request deletion of your personal information
• Opt out of the sale of personal information

We do not sell personal information and do not discriminate against users who exercise their rights.

Cookies and Tracking Technologies

We use cookies and similar technologies to ensure our websites function properly and to understand how visitors use our sites.

Where required by law, we request consent before placing non-essential cookies. You can manage your cookie preferences through our cookie consent banner or your browser settings.

Children’s Privacy

Our websites are not directed at individuals under the age of 18, and we do not knowingly collect personal information from children.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Updates will be posted on this page with a revised “Last updated” date.

Contact Us

If you have questions, wish to exercise your rights, or withdraw consent, please contact us at:
beneficialreturns@gmail.com.

Last Update: This Privacy Policy was last updated on January 29, 2026.