Privacy Policy.

This policy explains what Phoenix Development Group collects through this site, how that information is used, who it is shared with, and how long it is kept. Last updated August 2026.

Information you provide.

The general inquiry form and the capital access request form on this site collect the information you enter into them. Depending on the form, that includes your name, email address, telephone number, the firm or family office you represent, your investor type, and the ticket size range you indicate an interest in, together with any notes, questions, or message you choose to add.

We do not ask for and do not want financial account numbers, tax identification numbers, or other sensitive identifiers through these forms. Please do not submit them here. Where documentation of that kind is required as part of accredited investor verification or subscription, it is collected separately through the placement agent and its verification process, not through this website.

Submitting a form is voluntary. If you would rather not use a form, you can contact us directly by email or telephone using the details in the footer of this site.

Responding to inquiries and assessing eligibility.

Information submitted through this site is used for two purposes only: to respond to your inquiry, and to assess whether you are eligible to receive offering materials as a qualified accredited investor under Regulation D of the Securities Act of 1933, as amended.

We do not use your information for advertising, we do not build marketing profiles from it, and we do not use it to make automated decisions about you.

A short list, and never for sale.

Information you submit may be shared with legal counsel advising the Fund, the fund administrator and other service providers engaged to administer the Fund and maintain its records, and the placement agent, Covitus Capital, LLC, together with GT Securities, Inc., Member FINRA/SIPC (CRD #116012), for the purposes of investor onboarding, subscription processing, and accredited investor verification.

These parties receive your information only to perform those functions and are expected to protect it accordingly. We may also disclose information where we are required to do so by law, regulation, or valid legal process, including the books-and-records and anti-money-laundering obligations that apply to the placement agent and its broker-dealer.

We do not sell your personal information. We do not rent, trade, or otherwise make it available to third parties for their own marketing purposes.

Retention.

Inquiry records for individuals who do not proceed are retained for up to two years from your last communication with us, after which they are deleted.

Where you subscribe or begin the subscription process, records relating to the offering are retained for at least six years following the later of your last transaction or the termination of the Fund, consistent with the recordkeeping obligations that apply to the placement agent and its broker-dealer, and longer where a specific legal, tax, or regulatory obligation requires it.

Access, correction, and deletion.

You may request a copy of the information we hold about you, ask us to correct it, or ask us to delete it. Write to adam@galaxyventurecapital.com and we will respond within a reasonable period.

Where a legal, tax, or regulatory recordkeeping obligation requires us to retain specific records, we will tell you which information we cannot delete and why.

Questions about this policy can be sent to the same address.