Privacy Policy

Effective and last updated: September 30, 2026

1. Who we are and what this policy covers

Ives Ultra Capital Management LLC, a Delaware limited liability company (“Ives Ultra,” “we,” “us” or “our”) operates this website and the related channels described below in its role as investment adviser to Ives Ultra AI Opportunities Inc., a non-diversified, closed-end management investment company registered under the Investment Company Act of 1940 whose common stock is listed on the New York Stock Exchange under the symbol IVAI (the “Fund”). This policy explains what information we collect through those channels, how we use and disclose it, how long we keep it, and the choices available to you.

This policy applies to the following, together our “Channels”:

• this website, together with any subdomain, microsite or campaign page we operate;
• any email communications we send;
• accounts and channels we operate for the Fund on social media and other third-party platforms, including direct messages sent to them;
• advertising we place, and research, content and sponsored material distributed on our behalf by agencies, publishers, media outlets and individual creators;
• webinars, events and conferences we host or attend; and
• inquiries you send to us, including investor relations, media and careers inquiries.

2. What this policy does not cover

• If you hold Fund shares through a broker, bank or other intermediary, your account relationship is with that firm, and its privacy notice governs the information it collects. We generally do not receive information about shareholders who hold in street name.
• If you are a holder of record, the Fund’s transfer agent maintains the shareholder register, and its privacy practices apply to that relationship.
• Nonpublic personal information collected in connection with a shareholder relationship is governed by the Fund’s privacy notice under Regulation S-P, which is included in the Fund’s prospectus.
• Third-party platforms on which our Channels appear collect information under their own privacy policies, which we do not control.

3. Information you provide to us

Our website has one form, an email signup for updates about the Fund, and no accounts. We collect the information you choose to give us, which may include:

• your email address, if you sign up for updates on our website;
• your name, contact details and the content of any email, letter or message you send us, including investor relations and press inquiries;
• content you post or send through channels and social accounts we operate, including your username, profile information, comments and direct messages;
• information you submit through a form hosted on a third-party platform in response to our advertising;
• registration and attendance information for events, and information you give us in person; and
• information you submit if you apply for a position with us.

We do not collect Social Security numbers, government identifiers, financial account numbers, or documentation of accreditation, income or net worth through our Channels.

4. Information we collect automatically

When you visit our website, some information is collected automatically:

• Server logs. Our hosting and content delivery providers record technical information in the ordinary course of serving the site, including IP address, browser and device type, operating system, referring page, pages requested, and the date and time of each request.
• Analytics. We use analytics tools, including one provided by our hosting provider, to understand how our website is used and how well it performs. They collect information such as the pages you visit, the referring page, your browser, operating system, device type and screen size, your approximate location derived from your IP address, and page-load and performance measurements. We use this information in aggregate to operate and improve the site. Analytics tools may use cookies, scripts or similar technologies to do this.
• Web fonts. The site loads its fonts from Google Fonts, so your browser sends your IP address and browser information to Google when it requests them. Google’s use of that information is governed by its privacy policy.
• Advertising and measurement information, if we use it, as described in Section 9.

Our website does not currently use advertising cookies. If that changes, we will update this policy and, where the law requires, ask for your consent first.

5. Information we receive from others

• Aggregate performance and audience reporting from advertising platforms, social media platforms and publishers.
• Audience and media reporting from agencies and intermediaries engaged to distribute research and content on our behalf.
• Contact information passed to us by creators, publishers or intermediaries where you have asked to hear from us.
• Information from service providers who help us operate our Channels.
• Publicly available information, including regulatory filings and public professional profiles.

We do not buy, rent or otherwise acquire mailing lists, and we do not use data enrichment or append services to add information to the records of people who contact us.

6. How we use information

• To respond to your inquiries and provide materials you request.
• To send communications you have asked to receive.
• To operate, maintain, secure and improve our Channels.
• To understand how our Channels are used and to measure the performance of our content and any advertising.
• To promote the Fund, including through advertising and the distribution of research and sponsored content.
• To comply with legal and regulatory obligations, including books and records requirements that apply to registered investment advisers and registered investment companies, and to respond to examinations, subpoenas and lawful requests.
• To establish, exercise or defend legal claims, and to enforce our Terms of Use.
• In connection with a corporate transaction, reorganization or similar event.

Contacting us does not make you an investor in the Fund, does not create an advisory relationship, and does not obligate us to give investment advice. Any offering of the Fund’s securities is made only by means of its prospectus.

7. Marketing communications and your choices

If you ask to receive communications from us, we may send you related information about the Fund. You can stop receiving them at any time by using the unsubscribe link in any message or by contacting us as described in Section 19. We will honor your request promptly, and in any event within the period the law requires. We may still reply to inquiries you send us, or contact you where we are required to.

8. Cookies and similar technologies

Cookies and similar technologies can be used to operate a site, remember preferences, understand how a site is used, and measure and deliver advertising. As described in Section 4, our website uses them to operate and for analytics. It does not currently use advertising cookies.

You can set your browser to refuse or delete cookies. If we add advertising technologies, we will describe them here. Where you are in a location that requires prior consent, those technologies will not be applied unless you give it; elsewhere, you will be able to opt out as described in Section 9.

9. Advertising, sponsored content, and information collected away from our website

9.1 We may advertise the Fund on third-party platforms, and may engage agencies, publishers, media outlets and individual creators to distribute research, content and sponsored material on our behalf. In that case, information about you may be collected somewhere other than our website: for example, when you view or interact with our advertising on a platform, submit a form hosted inside a platform, or respond to content distributed by a third party.

9.2 What we receive from that activity is ordinarily limited to aggregate campaign, media and audience reporting. Where you submit a form or click through to us, we receive the information you provided and the campaign details attached to your visit.

9.3 The platforms, agencies and distributors involved may use identifiers, device and browsing information and interaction data for their own purposes under their own privacy policies. Some act as our service providers and may use information only for us; others act independently, and disclosures to them may count as “sharing” for targeted advertising or a “sale” of personal information under some state privacy laws.

9.4 We do not upload our contact lists, or hashed versions of them, to advertising platforms, and we do not use them to build custom or lookalike audiences. We do not use advertising or analytics data to decide whether you may invest, and we do not sell personal information for money.

9.5 You can opt out of targeted advertising and of the sale or sharing of your personal information by contacting us as described in Section 19. We honor Global Privacy Control signals sent by your browser. You can also use the privacy controls each platform provides, and the industry opt-out tools of the Digital Advertising Alliance and the Network Advertising Initiative. Opting out does not stop you from seeing our advertising and does not delete information a platform already holds.

9.6 Advertising, research and sponsored content are for informational purposes. Responding to them does not make you an investor in the Fund, does not create an advisory relationship, and is not an offer to sell or a solicitation of an offer to buy any security. Any offering is made only by means of the Fund’s prospectus.

10. Social media, community channels, and moderation

Social accounts and community channels are public or semi-public spaces. What you post there, including your username and the content of your posts, can be seen by others and may be copied or kept by people we do not control. We, and moderators acting for us, may review, moderate, remove or retain content posted on channels we operate, and may keep records of moderation actions. Please do not post or send us sensitive personal information, account numbers or confidential information through these channels.

11. Recordkeeping and supervision of communications

We are subject to books and records requirements under the federal securities laws. Communications with us, including email, messages sent through channels and social accounts we operate, and content we publish, may be captured, archived and retained by third-party compliance providers for the periods those rules require, and may be produced to regulators. This applies whichever channel you use to reach us.

12. How we disclose information

We do not sell personal information for money. We disclose personal information:

• to service providers who perform functions for us, such as website hosting and delivery, email, analytics, advertising, content distribution, compliance archiving, cloud storage and professional services, who may use it only to provide services to us;
• to advertising platforms and measurement providers, as described in Section 9;
• to agencies, publishers and intermediaries engaged to distribute our research and content;
• to the Fund and its service providers, where relevant to the Fund’s operations;
• to our attorneys, auditors and other professional advisers;
• to regulators, self-regulatory organizations and other authorities where the law requires, in response to lawful requests, and in connection with examinations, investigations and litigation;
• in connection with a corporate transaction, financing, reorganization or similar event; and
• at your direction or with your consent.

13. How long we keep information

We keep personal information for as long as we need it for the purposes in this policy, and longer where the federal securities laws or other legal obligations require. Records subject to books and records requirements are kept for the periods those rules set. Retention of analytics, advertising and measurement information is governed in part by the settings and policies of the providers and platforms involved. When information is no longer needed and no retention obligation applies, we delete it or remove its association with you.

14. Security

We maintain administrative, technical and physical safeguards designed to protect personal information against unauthorized access, use, alteration and destruction, and we require our service providers to do the same. No system is perfectly secure, and we cannot guarantee the security of information sent to us over the internet.

15. Your choices and rights

Depending on where you live, you may have the right to request access to the personal information we hold about you, to request that we correct or delete it, to obtain a portable copy, to opt out of targeted advertising and of the sale or sharing of your personal information, and not to be discriminated against for exercising these rights. To make a request, contact us as described in Section 19. We will verify your identity before responding and will respond within the period the law requires. You may use an authorized agent where the law permits, and you may appeal a decision by replying to our response. If the federal securities laws require us to keep a record, we will tell you if we cannot delete it.

Additional rights that may apply where you are located are described in Section 17. Advertising opt-outs are described in Section 9.5.

16. Children

Our Channels are intended for adults. We do not knowingly collect personal information from children under 16, and we do not knowingly direct advertising to them. If you believe a child has given us personal information, contact us and we will delete it.

17. Where you are located

17.1 We operate from the United States. Our Channels are hosted in the United States, and the information we collect is processed and stored there, where privacy laws may differ from those where you live.

17.2 Nothing on our Channels is an offer to sell, or a solicitation of an offer to buy, any security in any jurisdiction where that would be unlawful, and our materials are not directed to anyone in such a jurisdiction.

17.3 Wherever you are, you may contact us as described in Section 19 to ask what information we hold about you, to ask us to correct or delete it, or to ask us to stop sending you marketing. We will consider any such request, whether or not the law where you live requires us to.

18. Changes to this policy

We may update this policy from time to time. We will post the updated version with a revised effective date and, where changes are material, give additional notice. Prior versions are available on request.

19. How to contact us

Privacy inquiries, requests and general questions may be sent to: