Privacy Policy

This Privacy Policy describes the privacy practices of Grocapitus Investments, LLC ("Grocapitus," "we," "us," or "our") with respect to information collected through Grocapitus.com and related online interactions.

This Privacy Policy explains:

• What personally identifiable information we collect through our website and related online interactions;
• How we use that information and the circumstances in which it may be disclosed;
• What choices are available to you regarding the use of your information;
• The security procedures we use to protect information; and
• How you may contact us to review, correct, or request deletion of information.

Information Collection, Use, and Sharing

We collect information so that we can respond to inquiries, communicate with prospective and current investors, provide information about our investments and services, operate and improve our website, and provide a useful online experience.

Much of the personal information we collect is provided directly by you when you complete a form, schedule a meeting, register for an event or webinar, communicate with us, or otherwise interact with our website.

Personal information we may collect includes:

• Name;
• Telephone number;
• Email address;
• Information you voluntarily provide through forms, applications, registrations, or communications; and
• Other information that could directly or indirectly identify or permit us to contact you.

We use this information to respond to you regarding the reason you contacted us, provide requested information or services, maintain our relationship with you, communicate about investment opportunities and events, and operate our business.

We do not rent or sell personally identifiable information to third parties for their independent use.

We may disclose information to service providers that assist us in operating our website and business, including providers of website hosting, email and customer relationship management services, analytics, meeting scheduling, communications, marketing technology, security, and similar business functions. These providers may process information on our behalf or in accordance with their own applicable privacy practices.

Unless you ask us not to, we may contact you by email about investments, services, events, educational information, or changes to this Privacy Policy. You may unsubscribe from marketing communications at any time by using the unsubscribe link contained in an email or by contacting us.

Account-Related and Interaction Information

We may collect information associated with your use of our website and interactions with Grocapitus, including:

• Forms you have completed;
• Emails and other communications we have sent or received;
• Web pages you have visited;
• Meetings or appointments you have scheduled;
• Customer service requests; and
• Notes or other information relating to inquiries and our responses.

We use this information to communicate with you, maintain appropriate business records, respond to requests, improve our services, and administer our relationship with you.

Cookies

We use cookies and similar technologies on our website.

A cookie is a small data file stored on a visitor's browser or device. Cookies may help us recognize repeat visitors, understand how visitors interact with our website, remember preferences, analyze website performance, and improve the user experience.

Information collected through cookies and similar technologies may, depending on the technology and information involved, be capable of identifying or being associated with a particular user, browser, device, or household.

Cookies and similar technologies may be used for purposes including:

• Website functionality;
• Analytics;
• Security;
• Understanding website usage;
• Remembering preferences;
• Measuring communications and website performance; and
• Marketing and advertising.

Some of our service providers and business partners may also use cookies, pixels, tags, or similar technologies through our website. Their collection and use of information may be governed by their own privacy policies and contractual terms.

You may be able to control or delete cookies through your browser or device settings. Blocking certain cookies may affect the functionality of portions of our website.

Data About Website Usage

Certain information may be collected automatically when you use or interact with our website. This may include:

• Internet Protocol ("IP") address;
• Browser type and settings;
• Operating system;
• Device type;
• Device or browser identifiers;
• Cookie identifiers;
• Date and time of website access;
• Referring website;
• Pages, content, and links viewed or selected;
• Language preferences;
• Browser configuration and plug-ins;
• Network information;
• Error and diagnostic information; and
• Approximate geographic location derived from an IP address or device information.

We use this information to operate, secure, maintain, analyze, and improve our website and communications.

Website Analytics and Marketing Technologies

We use web analytics and technology service providers, which may include services such as Google Analytics, ActiveCampaign, Google-related technologies, LinkedIn technologies, and other providers.

These services may collect information regarding how you interact with our website, including:

• Pages visited;
• Referring websites;
• Time spent on pages;
• Browser and operating-system information;
• IP and network information;
• Device identifiers; and
• Interactions with website content.

These technologies may use persistent cookies, pixels, tags, or similar mechanisms to recognize a browser or device across visits.

Information collected by these providers may be transmitted to and stored on servers located in the United States or other jurisdictions. Their use of information is also subject to their applicable privacy policies and terms.

You may control certain technologies through browser settings, device settings, or privacy controls made available by the applicable provider.

California Online Privacy Protection Act Disclosures

The California Online Privacy Protection Act ("CalOPPA") requires operators of certain commercial websites that collect personally identifiable information from California residents to provide specified information regarding their privacy practices.

The following disclosures supplement the other provisions of this Privacy Policy.

Categories of Personally Identifiable Information Collected

As described above, we may collect categories of personally identifiable information including:

• Name;
• Email address;
• Telephone number;
• Information voluntarily submitted through website forms, applications, registrations, meeting-scheduling tools, or communications;
• IP address;
• Browser and device information;
• Website usage and interaction information;
• Online or device identifiers; and
• Other information that may permit an individual to be identified or contacted.

Categories of Third Parties

We may disclose information to categories of service providers and other third parties that assist us with functions such as:

• Website hosting and operation;
• Website and business analytics;
• Email and customer relationship management;
• Meeting and event scheduling;
• Communications;
• Marketing and advertising technology;
• Information technology and cybersecurity; and
• Other services necessary to support our website and business operations.

We do not rent or sell personally identifiable information to third parties for their independent use.

Third-Party Online Tracking

Third parties may collect information regarding your online activities over time and across different websites or online services when you visit Grocapitus.com.

This may occur through cookies, pixels, analytics technologies, advertising technologies, social-media technologies, tags, or similar mechanisms.

Information collected through these technologies may include an IP address, device or browser identifiers, website interactions, referring websites, and related internet activity information.

Do Not Track Disclosures

Some web browsers provide a "Do Not Track" ("DNT") setting that allows users to communicate a preference concerning certain online tracking activities.

There is currently no universally accepted industry standard governing how websites must interpret traditional browser DNT signals. Accordingly, Grocapitus.com may not respond to all traditional DNT signals.

You may use your browser or device settings and available privacy controls to manage certain cookies and tracking technologies.

Reviewing or Updating Your Information

You may contact us to:

• Ask what personally identifiable information we maintain about you;
• Request correction of inaccurate information;
• Request deletion of information, where appropriate; or
• Express concerns regarding our collection or use of your information.

Requests are subject to applicable legal, regulatory, contractual, tax, accounting, investment-recordkeeping, security, and other legitimate retention requirements.

You may contact us using the information provided in the Contact Us section below.

Links to Other Websites

Our website contains links to websites and online services operated by third parties.

Grocapitus is not responsible for the content or privacy practices of websites or services that we do not control. We encourage users to review the privacy policies of third-party websites before providing personal information.

CAN-SPAM Act

The CAN-SPAM Act establishes requirements for commercial email communications and provides recipients with the ability to stop receiving commercial email.

In accordance with applicable requirements, we:

• Do not use false or misleading subject lines or email addresses;
• Identify commercial communications as advertisements where required;
• Include our business address in commercial email communications;
• Monitor third-party email marketing services for compliance where appropriate;
• Honor valid opt-out and unsubscribe requests; and
• Provide an unsubscribe mechanism in applicable marketing emails.

Unsubscribing from marketing communications will not prevent us from sending communications that are transactional, administrative, investor-related, legally required, or otherwise non-marketing in nature.

Your Access to and Control Over Information

You may opt out of future marketing communications from us at any time.

You may also contact us to:

• Ask what information we maintain about you;
• Request correction of information;
• Request deletion of information, where appropriate; or
• Express concerns regarding our use of your information.

These options are provided subject to applicable legal, regulatory, tax, accounting, investment, contractual, security, and record-retention obligations.

You may contact us through the email address or telephone number listed below.

Security

We take reasonable precautions designed to protect personal information against unauthorized access, use, alteration, loss, or disclosure.

When sensitive information is transmitted through our website or another system we control, we use security measures appropriate to the nature of the information and the circumstances.

Where appropriate, information transmitted online may be encrypted using technologies such as HTTPS.

We also maintain administrative and technical safeguards intended to limit access to personal information to individuals who require access for legitimate business purposes.

No method of transmission over the Internet or method of electronic storage is completely secure, and we cannot guarantee absolute security.

Personal Data Sharing

We respect your privacy and are committed to protecting personal information.

We do not rent or sell your personally identifiable information to third parties for their independent use.

We may disclose personal information to service providers and other parties that assist us in operating our website, communicating with users, analyzing website activity, providing requested services, maintaining our systems, complying with applicable law, or conducting other legitimate business functions.

We may also disclose information when required by law, regulation, legal process, or governmental request, or when reasonably necessary to protect the rights, property, security, or safety of Grocapitus, our users, or others.

We do not disclose mobile telephone numbers or SMS opt-in consent information to third parties or affiliates for their own marketing or promotional purposes.

Consent to SMS Messaging

Where Grocapitus offers SMS communications, consent is obtained through an applicable opt-in mechanism requiring the individual to affirmatively indicate agreement to receive such messages.

Providing a telephone number by itself does not necessarily constitute consent to receive marketing SMS messages.

Message and data rates may apply. Message frequency may vary.

You may opt out of SMS messages at any time by replying STOP to the number from which you received the message.

For assistance, you may reply HELP where supported or contact us using the information below.

Privacy Policy Changes

We may revise this Privacy Policy from time to time to reflect changes in our information practices, technologies, service providers, business operations, or applicable law.

When we revise this Privacy Policy, we will update the "Last Updated" date at the top of the policy.

Material changes may also be communicated through the website or another appropriate method where warranted.

We encourage users to review this Privacy Policy periodically.

Privacy Policy Location

This Privacy Policy is available through the Privacy Policy link located in the footer of Grocapitus.com.

Contact Us

If you have questions about this Privacy Policy, would like to review or request changes to information we maintain about you, or believe that we are not complying with this Privacy Policy, please contact us: