Privacy Policy

Last updated: June 2026

This Privacy Policy describes how Common Capital and its affiliates ("Common Capital," "we," "us," or "our") collect, use, and disclose information in connection with your use of the website located at common-cap.com and any related pages (collectively, the "Site"). By using the Site, you agree to the practices described in this Policy. This Policy applies to information collected through the Site and does not alter the terms of any separate privacy notice we may provide to clients or investors, including any financial privacy notice required by applicable law.

1. Information We Collect

Information you provide

We collect information you choose to provide to us, for example when you contact us, request information, or register for or use an investor portal. This may include your name, email address, telephone number, mailing address, the organization you represent, and the contents of any communications you send to us.

Information collected automatically

When you visit the Site, we and our service providers may automatically collect certain technical information, such as your IP address, device and browser type, operating system, referring and exit pages, pages viewed, and the dates and times of your visits. We may collect this information using cookies and similar technologies.

2. How We Use Information

We use the information we collect to:

• operate, maintain, secure, and improve the Site;
• respond to your inquiries and communicate with you;
• provide and administer access to investor or client portals;
• analyze how the Site is used and develop new features;
• detect, prevent, and address fraud, security, or technical issues; and
• comply with legal and regulatory obligations and enforce our terms.

3. How We Share Information

We do not sell your personal information. We may share information:

• With affiliates within the Common Capital group of companies for the purposes described in this Policy;
• With service providers who perform services on our behalf, such as hosting, analytics, communications, and IT support, and who are obligated to protect the information;
• For legal and compliance reasons, when we believe disclosure is necessary to comply with applicable law, regulation, legal process, or governmental request, or to protect the rights, property, or safety of Common Capital, our clients, or others; and
• In connection with a business transaction, such as a merger, financing, reorganization, or sale of assets, subject to customary confidentiality protections.

4. Cookies and Analytics

We use cookies and similar technologies to operate the Site, remember your preferences, and understand how the Site is used. You can usually configure your browser to refuse or delete cookies; however, some features of the Site may not function properly if you do. We may use third-party analytics providers, who collect and process information about your use of the Site in accordance with their own privacy policies.

5. Data Security

We maintain reasonable administrative, technical, and physical safeguards designed to protect the information we collect. However, no method of transmission over the internet or method of electronic storage is completely secure, and we cannot guarantee absolute security.

6. Data Retention

We retain information for as long as necessary to fulfill the purposes described in this Policy, unless a longer retention period is required or permitted by law, including to meet our legal, regulatory, accounting, or reporting obligations.

7. Third-Party Links

The Site may contain links to third-party websites. We are not responsible for the privacy practices or content of those websites. We encourage you to review the privacy policies of any third-party sites you visit.

8. Your Privacy Rights

Depending on where you live, you may have certain rights regarding your personal information, subject to applicable law and exceptions.

California residents

If you are a California resident, the California Consumer Privacy Act, as amended, may give you the right to request access to the categories and specific pieces of personal information we have collected about you, to request deletion or correction of your personal information, and to not be discriminated against for exercising your rights. We do not sell or share personal information for cross-context behavioral advertising.

Virginia residents

If you are a Virginia resident, the Virginia Consumer Data Protection Act may give you the right to confirm whether we are processing your personal data and to access, correct, delete, or obtain a copy of that data, and to opt out of certain processing, subject to applicable exemptions.

To exercise any of these rights, contact us at info@common-cap.com. We will verify and respond to your request as required by applicable law. Certain information may be exempt from these rights, including information governed by financial privacy laws such as the Gramm-Leach-Bliley Act.

9. Financial Privacy

If you are a client or investor, the personal information we collect and maintain in that capacity may be governed by separate financial privacy laws and a dedicated privacy notice that we provide to you. That notice, where applicable, controls our treatment of such information.

10. Children's Privacy

The Site is intended for a business and professional audience and is not directed to children. We do not knowingly collect personal information from children under the age of 16. If you believe a child has provided us with personal information, please contact us so we can delete it.

11. Changes to This Policy

We may update this Privacy Policy from time to time. The "Last updated" date above indicates when this Policy was most recently revised. Your continued use of the Site after any changes become effective constitutes your acceptance of the revised Policy.

12. Contact

If you have questions about this Privacy Policy or our privacy practices, please contact us at info@common-cap.com, or by mail at Common Capital, 411-413A East Main Street, Charlottesville, VA 22902.