Privacy Policy

1. Scope

This Privacy Policy describes how DWS OFFSHORE FUND dba Ultiwrite ("Ultiwrite," "we") handles information in connection with the Ultiwrite platform (the "Service"). Ultiwrite is a business-to-business tool used by approved organizations; we do not offer the Service to consumers.

2. Information We Process

We process the following categories of information:

• Account data — names, business email addresses, roles, and organization details of authorized users.
• Merchant analysis inputs — application fields, business identifiers, website/domain references, documents, and related materials submitted by customers for analysis.
• Derived evidence — public-footprint observations, reason codes, scores, and evidence records generated by the Service.
• Operational data — logs, IP addresses, and usage events used for security, auditing, and reliability.

We do not intend to collect or store full payment-card numbers, bank login credentials, or unnecessary consumer-sensitive data, and ask that customers not submit such data.

3. How We Use Information

We use information to:

• provide, operate, and improve the Service;
• generate merchant-coherence analysis, reason codes, and reports;
• authenticate users and enforce access controls and usage limits;
• maintain security, prevent abuse, and keep audit trails; and
• comply with legal obligations.

4. Public and Third-Party Sources

The Service analyzes publicly available business information (such as websites, public business listings, and registry records) and may use third-party data providers. We record source provenance and timestamps for evidence used in analysis. Absence of a public record is treated as a review signal, not proof of any conclusion.

5. Sharing

We do not sell personal information. We share information only with service providers who support the operation of the Service under confidentiality obligations, within your own organization as configured, and where required by law. Customer analysis data is isolated by organization and is not shared with other customers.

6. Retention

We retain information for as long as needed to provide the Service, maintain auditable evidence records, and meet legal obligations. Customers may request deletion of their organization's data, subject to legal and audit-retention requirements.

7. Security

We use access controls, authentication, and audit logging to protect information. The Service is pilot-stage; additional production-hardening measures (such as expanded encryption, retention controls, and formal data-processing agreements) are part of our ongoing roadmap. No method of transmission or storage is completely secure.

8. Your Choices

Authorized users may update account information or request access changes through their organization administrator. For data-subject or organization requests, contact us using the details below.

9. Contact

For privacy questions, contact info@dwsoffshorepartners.com or see our contact page.