Privacy Policy

1. Introduction & Scope

Gadget Capital Management, LLC ("Gadget Capital," "we," "us," or "our") respects your privacy and is committed to protecting the personal information you share with us. This Privacy Policy describes how we collect, use, disclose, and safeguard your personal information when you visit our website, communicate with us, or engage with our investment management services.

This policy applies to information collected through our website (gadgetcapital.com), email and other electronic communications, and any related services or interactions with our firm.

This policy does not apply to information collected about our employees or personnel, the operations of our portfolio companies or investments, or third-party websites or services that may be linked from our site. Those are governed by their own respective privacy policies and practices.

2. Information We Collect

We may collect the following categories of personal information:

Information you provide directly. When you contact us, submit a form, request materials, or engage with our services, we may collect:

• Name and contact information (email address, phone number, mailing address)
• Accredited investor status and related qualification documentation
• Firm affiliation, job title, and professional background
• Investment-related information, including investment preferences, financial qualifications, and subscription details

Information collected automatically. When you visit our website, we may automatically collect certain technical and usage information, including:

• IP address, browser type and version, and device identifiers
• Pages visited, referring URL, and time spent on each page
• Usage patterns and navigation behavior collected via cookies and analytics tools

Information from third parties. We may also receive personal information from:

• Service providers that assist with investor verification and compliance
• Regulatory agencies in connection with compliance inquiries
• Publicly available sources, such as SEC filings, professional directories, and public databases

3. How We Use Your Information

We use the personal information we collect for the following purposes:

• Respond to inquiries and provide requested materials, including fact sheets, offering documents, and fund-related communications
• Communicate about fund updates, market commentary, performance reporting, and investor reporting
• Verify accredited investor status and comply with Know Your Customer (KYC) and Anti-Money Laundering (AML) requirements
• Improve our website and services through analytics and usage data
• Comply with legal, regulatory, and SEC reporting obligations
• Prevent fraud, detect unauthorized activity, and protect the security of our systems and services

4. How We Share Your Information

We may share your personal information in the following limited circumstances:

• Service providers: We share information with trusted third-party service providers who assist with fund administration, auditing, legal counsel, technology infrastructure, and compliance. These providers are bound by confidentiality obligations and may only use your information for the specific purposes for which it was disclosed.
• Regulatory agencies and law enforcement: We may disclose information when required by law, regulation, subpoena, court order, or governmental request, including in response to inquiries from the SEC, FINRA, or other regulatory authorities.
• Professional advisors: We may share information with our auditors, lawyers, and accountants in connection with fund operations, compliance, and financial reporting.
• Business transfers: In the event of a merger, acquisition, reorganization, or sale of all or a portion of our assets, your personal information may be transferred as part of that transaction. In such cases, we will require that the acquiring entity continue to protect your personal information in accordance with this policy.

We do not sell your personal information.

5. Cookies and Tracking Technologies

Our website uses cookies and similar tracking technologies to support site functionality and understand visitor behavior. We may use the following types of cookies:

• Functional cookies: These cookies are necessary for our website to operate properly, including session management, security features, and user preference settings such as theme selection.
• Analytical cookies: These cookies help us understand how visitors interact with our website by collecting information about pages visited, navigation patterns, and time on site. We may use third-party analytics services such as Google Analytics for this purpose.

We do not use advertising cookies or targeted marketing cookies.

You may manage your cookie preferences through your browser settings. Most browsers allow you to block or delete cookies. Please note that disabling certain cookies may affect the functionality and user experience of our website.

6. Data Retention

We retain personal information only as long as reasonably necessary to fulfill the purposes described in this policy, including to satisfy legal, regulatory, accounting, and reporting requirements.

Financial and transaction data related to fund investments may be retained for up to seven (7) years in accordance with SEC regulatory requirements under Rule 17a-4 and other applicable record-keeping obligations.

If you become an inactive client or cease engaging with our services, your personal information will continue to be protected in accordance with this policy for as long as it is retained.

7. Data Security

We implement administrative, technical, and physical safeguards designed to protect your personal information from unauthorized access, disclosure, alteration, and destruction. These measures include industry-standard encryption for data in transit and at rest, access controls, regular security assessments, and employee training on data handling practices.

However, no method of transmission over the Internet or method of electronic storage is completely secure. While we strive to protect your personal information, we cannot guarantee its absolute security.

8. Your Privacy Rights

a. All Users

Regardless of your location, you may:

• Request access to the personal information we hold about you
• Request correction of inaccurate or incomplete personal information
• Request deletion of your personal information, subject to certain legal and regulatory exceptions
• Opt out of marketing emails by following the unsubscribe instructions included in each communication or by contacting us directly

b. California Residents (CCPA/CPRA)

If you are a California resident, you may have additional rights under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA), including:

• The right to know the categories and specific pieces of personal information we have collected about you
• The right to request deletion of your personal information
• The right to opt out of the sale of your personal information (note: we do not sell personal information)
• The right to non-discrimination for exercising your privacy rights

We have not sold personal information in the preceding 12 months.

c. How to Exercise Your Rights

To exercise any of the rights described above, please contact us at info@gadgetcapital.com. We will verify your identity and respond to your request within 45 days of receipt. If additional time is required, we will notify you of the reason and the expected timeframe for our response.

9. Privacy of Minors

Our website and services are not directed to individuals under the age of 18. We do not knowingly collect personal information from children. If we discover that we have inadvertently collected personal information from a child under 18, we will take prompt steps to delete such information from our records.

10. Third-Party Links

Our website may contain links to third-party websites, platforms, or services that are not operated or controlled by Gadget Capital Management, LLC. We are not responsible for the privacy practices, security, or content of these third-party sites.

We encourage you to review the privacy policies of any third-party websites you visit before providing them with your personal information.

11. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, services, or applicable laws and regulations. When we make material changes, we will update the "Effective Date" at the top of this page.

Your continued use of our website and services following the posting of changes constitutes your acceptance of the updated policy. We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your information.

12. Contact Us

If you have questions or concerns about this Privacy Policy or our data practices, please contact us at:

Gadget Capital Management, LLC
PMB 6069
4225 Executive Square, Suite 600
La Jolla, CA 92037
Email: info@gadgetcapital.com