Agora Investor Portal Privacy Policy
Last Updated: September 17, 2026
RJ Kelly Co. LLC ("RJK," "we," "us," or "our") provides this Privacy Policy to explain how we collect, use, disclose, and protect information in connection with the Agora Investor Portal (the "Portal"). RJK makes the Portal available through a third-party hosted platform solely to investors in RJK investment entities and their authorized representatives.
This Privacy Policy applies only to the Portal and explains RJK’s information practices. The Terms of Use separately govern access to and use of the Portal. RJK’s website privacy policy, available at https://rjk.com/privacy-policy, governs www.rjk.com and does not apply to the Portal.
Information We Collect
We collect the account and contact information needed to establish and secure your access, including your name, email address, telephone number, mailing address, and the investment entities associated with your account.
We also collect information you submit through the Portal, including tax identification information, payment or distribution instructions, documents you upload, and messages or requests you send to RJK. We may also maintain records of investment-related transactions and instructions processed through the Portal.
We automatically log Portal access and activity, including sign-in times, materials viewed or downloaded, and technical information such as IP address, browser type, and device associated with your session. The Portal uses cookies and similar technologies necessary to authenticate your session and maintain security.
How We Use Information
We use this information to operate and secure the Portal, authenticate your access, make reporting and investment materials available to you, process and record distributions and capital call activity, respond to your requests, maintain the confidentiality and integrity of investor information, and comply with applicable legal, regulatory, tax, and recordkeeping requirements.
RJK does not sell information for monetary consideration. RJK also does not use information collected through the Portal for targeted advertising.
How We Share Information
We may disclose information to the third-party provider that hosts the Portal; to other service providers that support, secure, or administer the Portal; and to our accountants, attorneys, auditors, tax preparers, and similar professional advisors.
We may also disclose information to government authorities or other parties when reasonably necessary to comply with applicable law, respond to legal process, protect our rights or property, investigate suspected fraud or a security issue, or protect the safety of RJK or others. We may also disclose information in connection with a merger, acquisition, financing, sale of assets, restructuring, or similar transaction.
Service providers are bound by written contract to maintain appropriate safeguards and to use information only for the purposes for which it was provided.
Data Retention
We retain Portal access and activity logs and records relating to your investment for as long as reasonably necessary to meet business, contractual, tax, and legal requirements and in accordance with RJK’s data retention practices. Retention periods vary by record type.
Data Security
RJK uses reasonable administrative, technical, and organizational measures designed to protect information against unauthorized access, loss, misuse, alteration, or disclosure. Access to the Portal is credentialed and restricted to investors and their authorized representatives.
No electronic system can be guaranteed completely secure, and RJK cannot guarantee the absolute security of information transmitted through or stored in connection with the Portal. You are responsible for keeping your credentials confidential and for notifying RJK promptly if you believe they have been compromised. RJK maintains an incident response process and will provide any notifications required by applicable law.
Confidentiality of Portal Information
Information made available through the Portal is confidential and proprietary to RJK and is provided solely so that investors and their authorized representatives may evaluate and monitor the applicable investments. It may not be shared, reproduced, or distributed except as permitted by the Terms of Use.
Your Privacy Rights
Depending on where you reside, applicable privacy laws may give you rights regarding information RJK maintains about you. These rights may include requesting access to that information, requesting correction or deletion of certain information, or obtaining information about how it is used or disclosed.
To submit a request, contact info@rjk.com. We may need to verify your identity before processing certain requests. Rights and exceptions vary by jurisdiction and will be handled in accordance with applicable law. Certain information may need to be retained to meet applicable legal and recordkeeping obligations.
Changes to This Privacy Policy
We may update this Privacy Policy from time to time. When changes are made, we will update the "Last Updated" date above. Material changes will be communicated through the Portal, and the revised Privacy Policy will be presented during the Portal sign-in process. The updated Privacy Policy will apply in accordance with applicable law.
Contact
Questions regarding this Privacy Policy should be directed to RJ Kelly Co. LLC, 55 Cambridge Street, Suite 300, Burlington, MA 01803, or info@rjk.com.