Capital Waterfall (“Capital Waterfall”) respects your privacy and is committed to protecting it through our compliance with this policy. This Privacy Policy describes our practices for collecting information through our websites at www.capitalwaterfall.com (collectively, the “Website”), and email messages we send to you that link to this Privacy Policy (collectively, including the Website and e-mail, the “Services”). The Privacy Policy applies only to our online information-gathering and dissemination practices with the Services, and does not apply to any of our practices conducted offline. If you have any questions about the Privacy Policy or our privacy practices, please contact us at info@capitalwaterfall.com.

Your use of any of the Services, signifies that you agree with all this Privacy Policy, so please do not use the Services if you disagree with any part of this Privacy Policy.

PERSONAL INFORMATION

How We May Collect Personal Information

We and our service providers may collect Personal Information in many ways, including:

• Through the Services: We may collect Personal Information through the Services, e.g., when you sign up for a newsletter or request information.

• From Other Sources: We may receive your Personal Information from other sources, such as public databases; joint marketing partners; social media platforms; from people with whom you are friends or otherwise connected on social media platforms, and from other third parties.

How We May Use Personal Information

We may use Personal Information:

• To respond to your inquiries and fulfill your requests, such as to send you newsletters or publications you request or to register you for events.

• To send you our legal updates and mailings relating to our Services we think may interest you.

• To keep a record of your contact information and correspondence, and use it to respond to you, if you contact us through the Services.

• To send administrative information about changes to our terms, conditions, and policies.

• To provide services, including the provision of seminars and other events.

• To allow you to send Services-related content to a friend through the Services. By using this functionality, you are telling us you may use and provide us with your friend’s name and email address.

• For our business, such as data analysis, audits, fraud monitoring and prevention, enhancing, improving or modifying our Services, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities.

• As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; © to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue remedies or limit the damages we may sustain.

How Personal Information May Be Disclosed

Your Personal Information may be disclosed:

• To our third-party service providers that provide services such as website hosting, Services-related consulting and monitoring, data analysis, information technology and related infrastructure, customer service, email delivery, auditing and other similar services.

• To identify you to anyone to whom you send messages through the Services.

• By you on services to which you can post information and materials. Any information you post or disclose through these services will become public information, and may be available to us, to users of the Services and to the general public. We urge you to be very careful when deciding to disclose your Personal Information, or any other information, on the Services.

• To a third party (whether affiliated or unaffiliated with us) if any reorganization occurs, merger, sale, joint venture, assignment, transfer or other disposition of our business, assets or stock (including with any bankruptcy or similar proceedings).

• As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; © to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue remedies or limit the damages we may sustain.

OTHER INFORMATION

Other Information We May Collect

“Other Information” is any information that does not reveal your specific identity or does not directly relate to an individual, such as:

• Browser and device information

• Information collected through cookies, pixel tags and other technologies

• Demographic information and other information provided by you

• Aggregated information

How We May Collect Other Information

We and our third party service providers may collect Other Information in many ways, including:

• Through your browser or device: Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version and the name and version of the Services you are using. We use this information to ensure that the Services function properly.

• Cookies (or browser cookies): A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.

• Physical Location: We may collect the physical location of your device by, for example, using satellite, cell phone tower or WiFi signals. We may use your device’s physical location to provide you with personalized location-based services and content.

• Using pixel tags and other similar technologies: Pixel tags (also known as web beacons and clear GIFs) may be used with some Services to track the actions of users of the Services (including email recipients), measure the success of our marketing campaigns and compile statistics about usage of the Services and response rates.

• From you: Information such as your location, and other information, such as your preferred means of communication, is collected when you voluntarily provide this information. Unless combined with Personal Information, this information does not identify you or any other user of the Services.

• IP Address: Your “IP Address” is a number automatically assigned to the computer you are using by your Internet Service Provider (ISP). An IP Address may be identified and logged automatically in our server log files whenever a user accesses the Services, with the time of the visit and the page(s) that were visited. Collecting IP Addresses is standard practice and is done automatically by many websites and applications. We use IP Addresses for purposes such as calculating usage levels of the Services, helping diagnose server problems, and administering the Services.

• By aggregating information: Aggregated Personal Information does not identify you or any other user of the Services, (for example, we may aggregate Personal Information to calculate the percentage of our users with a particular telephone area code).

How We May Use and Disclose Other Information

We may use and disclose Other Information for any purpose, unless we must do otherwise under applicable law. If we must treat Other Information as Personal Information under applicable law, then we may use it as described in “How We May Collect Other Information” section above, and for all the purposes for which we use and disclose Personal Information.

Sometimes we may combine Other Information with Personal Information (such as combining your name with your geographical location). If we combine any Other Information with Personal Information, the combined information will be treated by us as Personal Information if it is combined.

THIRD PARTY SERVICES

This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any site or service to which the Services link. Including a link on the Services does not imply endorsement of the linked site or service by us or by our affiliates.

We are not responsible for the collection, usage and disclosure policies and practices (including the data security practices) of other organizations, such as any app, social media platform, or wireless service provider, including any Personal Information you disclose to other organizations through or for the Services.

SECURITY

We seek to use reasonable organizational, technical and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us as described in the “Contacting Us” section below.

CHOICES AND ACCESS

Your choices regarding our use of your Personal Information for marketing purposes

If you no longer want to receive marketing-related emails from us going-forward, you may opt-out of receiving these marketing-related emails by following the unsubscribe instructions in any such message or by contacting us by email at info@capitalwaterfall.com. We will try to comply with your request when reasonably practicable. If you do opt-out of receiving marketing-related emails from us, we may still send you important administrative messages, and you cannot opt-out from receiving administrative messages.

How You Can Access, Change, or Suppress Your Personal Information

You may request to review, correct, update, suppress, or otherwise modify any of your Personal Information you have previously provided to us through the Services, or object to the use or processing of such Personal Information by us. You may exercise these rights by logging on to your subscriptions account here or by contacting us by email at info@capitalwaterfall.com.

In your request, please clarify what Personal Information you would like changed, whether you would like your Personal Information you have provided to us suppressed from our database or otherwise let us know what limitations you would like to put on our use of your Personal Information you have provided to us For your protection, we may only implement requests regarding the Personal Information associated with the particular email address you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request when reasonably practicable.

We may need to retain certain information for record keeping purposes, and there may also be residual information that will remain within our databases and other records, which will not be removed.

SPECIAL NOTIFICATION FOR INDIVIDUAL CALIFORNIA USERS

We may disclose Personal Information to affiliates of Capital Waterfall and these affiliates may use such information for all purposes outlined in this Privacy Policy. Because separate legal entities are considered “third parties” for California Civil Code Section 1798.83, and certain communications from our affiliates might be viewed as promoting similar or related services, we are providing the following information for California residents who have provided us with their Personal Information through use of the Services during the creation of or during an established relationship (“Individual California Users”).

Individual California Users may request information about our disclosures of certain categories of Personal Information to third parties for such third parties’ direct marketing purposes. Such requests must be submitted to us by email at info@capitalwaterfall.com.

We will provide a list of the categories of Personal Information disclosed to third parties (i.e., our affiliates) for their direct marketing purposes during the immediately preceding calendar year, with the names and addresses of these third parties. This request may be made only once per calendar year. We reserve our right not to respond to requests submitted other than to the email or mailing addresses specified in this section.

RETENTION PERIOD

We will retain your Personal Information for the period to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.

CROSS-BORDER TRANSFER

The Services are controlled and operated by us from the United States, and are not intended to subject us to the laws or jurisdiction of any state, country or territory other than that of the United States. Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have different data protection rules than those of your country.

SENSITIVE INFORMATION

We ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., Social Security numbers, credit card or other payment card information) through the Services or otherwise to us through the Website.

UPDATES TO THIS PRIVACY POLICY

We may change this Privacy Policy. Please look at the “Last Updated” legend at the top of this page to see when this Privacy Policy was last revised. Any changes to this Privacy Policy will become effective when we post the revised Privacy Policy on the Services. Your use of the Services following these changes means you accept the revised Privacy Policy.

CONTACTING US

If you have questions about this Privacy Policy, please contact us by email at info@capitalwaterfall.com.

Email communications are not always secure, so please do not include credit card information or sensitive information in any emails to us.