Privacy Policy

Last updated: June 4, 2026

1. Introduction

HarborLink Holdings LLC ("HarborLink Holdings LLC," "we," "our," or "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, retain, and protect personal information when you access or use our Investor Terminal platform, websites, mobile applications, investor portals, marketing pages, online forms, communications, and other online services that link to this Privacy Policy (collectively, the "Services").

By accessing or using the Services, you acknowledge that you have read and understand this Privacy Policy.

This Privacy Policy does not replace or modify any confidentiality agreement, subscription agreement, operating agreement, investment document, fund document, platform agreement, or other legal agreement you may enter into with HarborLink Holdings LLC or any related entity. If there is a conflict between this Privacy Policy and a signed agreement, the signed agreement controls for the subject matter covered by that agreement.

2. Information We Collect

We collect information from and about users of the Services. The information we collect depends on how you interact with us and which Services you use.

Personal Information You Provide

We may collect personal information that you provide directly to us, including:

• Name
• Email address
• Phone number
• Mailing address
• Company name
• Job title
• Username and password
• Profile information, such as profile picture or biographical information
• Communication preferences
• Information submitted through online forms, portals, applications, questionnaires, or other workflows
• Messages, comments, questions, or other communications you send to us

Investor, Financial, and Transaction Information

If you use investor-related portions of the Services, we may collect information needed to evaluate, process, administer, or support investor relationships and investment activity, including:

• Investment preferences
• Accreditation status and related supporting information
• Suitability, eligibility, or investor-profile information
• Net worth, income, investment experience, or risk-related information
• Bank account, payment, wire, or transaction information
• Tax-related information
• Subscription, ownership, transfer, or account records
• Entity ownership, authorization, or control information
• Records related to capital contributions, distributions, or other investor activity

Identity Verification Information

We may collect information used to verify identity, prevent fraud, and support compliance-related processes, including:

• Date of birth
• Government-issued identification
• Passport or driver's license information
• Address verification information
• Social Security number or tax identification number, where applicable
• Identity verification documents or images
• Results or status information from identity verification processes

We use Veriff and may use other trusted verification or compliance service providers to support identity verification, fraud prevention, and related security processes.

Usage Data and Technical Information

We automatically collect certain information when you access or use the Services, including:

• IP address
• Browser type
• Device type
• Operating system
• Device identifiers
• Pages visited
• Links clicked
• Time spent on pages
• Referring website or source
• Approximate location based on IP address
• Log data
• Error, diagnostic, and security information
• Cookie and similar technology data

3. How We Use Your Information

We use the information we collect to:

• Provide, operate, maintain, and improve the Services
• Create, manage, and secure user accounts
• Process transactions and send related information
• Support investor onboarding, account administration, and investor communications
• Verify identity and prevent fraud
• Evaluate investor eligibility, accreditation, or related investor information
• Respond to comments, questions, requests, and customer service inquiries
• Communicate with you about HarborLink Holdings LLC, our Services, investment opportunities, events, updates, and related matters
• Send administrative, transactional, legal, compliance, and security-related notices
• Monitor and analyze trends, usage, and activity in connection with the Services
• Personalize your experience and provide content relevant to your interests
• Maintain internal records, reports, and business operations
• Protect the rights, property, safety, and security of HarborLink Holdings LLC, our users, investors, partners, and others
• Detect, investigate, and prevent fraud, unauthorized access, misuse, or other unlawful activity
• Comply with legal, regulatory, tax, accounting, contractual, and recordkeeping obligations
• Enforce our agreements, policies, and terms of service

4. How We Share Information

We do not sell your personal information for money.

We may share personal information in the following circumstances:

Service Providers

We may share information with third-party service providers that perform services on our behalf, including providers that support:

• Hosting and infrastructure
• Platform operations
• Customer relationship management
• Email, phone, SMS, and other communications
• Identity verification, including Veriff
• Fraud prevention and security
• Payment, banking, wire, or transaction processing
• Document management and electronic signature workflows
• Data storage and backup
• Analytics and usage monitoring
• Legal, accounting, tax, audit, and professional services

These service providers are authorized to use personal information only as needed to provide services to us or as otherwise permitted by law.

Business Partners and Related Parties

We may share information with business partners, affiliates, related entities, investment vehicles, portfolio companies, advisors, administrators, or transaction participants when necessary to provide the Services, support investor relationships, administer investment activity, or carry out business operations.

Where appropriate, we may share information with business partners only with your consent or direction.

Legal, Compliance, and Protection Purposes

We may disclose information when we believe disclosure is necessary or appropriate to:

• Comply with law, regulation, legal process, subpoena, court order, or governmental request
• Enforce our agreements, policies, and terms of service
• Protect the rights, property, and safety of HarborLink Holdings LLC, our users, investors, partners, employees, and others
• Detect, investigate, or prevent fraud, unauthorized activity, security incidents, or misuse of the Services
• Support legal, regulatory, tax, accounting, audit, or compliance obligations

Business Transactions

We may share or transfer personal information in connection with a merger, acquisition, financing, reorganization, sale of assets, bankruptcy, receivership, assignment, or other business transaction involving HarborLink Holdings LLC or related entities.

Text Messaging Opt-In and Consent Data

The categories of sharing described above exclude text messaging originator opt-in data and consent. We do not sell, rent, share, or otherwise disclose text messaging originator opt-in data or consent to any third parties for their own marketing purposes. We share your mobile number and message content only with vendors that help us operate our messaging program (such as our messaging provider) and only as needed to deliver the messages you have requested.

5. Cookies and Similar Technologies

We may use cookies, pixels, tags, scripts, local storage, and similar technologies to operate and improve the Services.

These technologies may be used to:

• Enable core platform functionality
• Keep you signed in
• Improve security
• Remember preferences
• Understand how users interact with the Services
• Monitor performance and troubleshoot issues
• Improve user experience

You can control cookies through your browser settings. Some parts of the Services may not function properly if cookies are disabled.

6. Data Security

We implement reasonable administrative, technical, and physical safeguards designed to protect personal information from unauthorized access, disclosure, alteration, loss, misuse, or destruction.

These measures may include access controls, authentication, encryption, monitoring, vendor controls, internal policies, and other security safeguards.

However, no method of internet transmission, email transmission, or electronic storage is completely secure. You should use care when submitting information online and should notify us promptly if you believe your account or information has been compromised.

7. Data Retention

We retain personal information for as long as reasonably necessary to fulfill the purposes described in this Privacy Policy, including to provide the Services, maintain investor and business records, comply with legal, regulatory, tax, accounting, contractual, and recordkeeping obligations, resolve disputes, prevent fraud, enforce agreements, and support legitimate business operations.

Retention periods vary depending on the type of information, the purpose for which it was collected, the nature of your relationship with us, and applicable legal or business requirements.

When personal information is no longer needed, we will delete, de-identify, aggregate, or securely retain it in accordance with applicable law and our internal data retention practices.

8. Your Rights and Choices

Depending on your location and applicable law, you may have certain rights regarding your personal information, including the right to:

• Request access to personal information we maintain about you
• Request correction of inaccurate or incomplete information
• Request deletion of personal information
• Request restriction of certain processing
• Object to certain processing
• Request portability of certain information
• Withdraw consent where processing is based on consent
• Opt out of marketing communications

To exercise these rights, contact us using the information in the "Contact Us" section below.

We may need to verify your identity before responding to your request. We will respond within the timeframe required by applicable law.

Please note that certain information may be retained where required or permitted by law, including for legal, tax, accounting, compliance, security, fraud-prevention, contractual, or recordkeeping purposes.

9. Marketing Communications

We may send you communications about HarborLink Holdings LLC, the Services, investment opportunities, events, updates, and related matters.

You may opt out of marketing emails by following the unsubscribe instructions included in the email or by contacting us at privacy@harborlink.com.

If you have opted in to receive text, SMS, or RCS messages from us, you may opt out at any time by replying STOP to any message, or reply HELP for help. Message frequency varies, and message and data rates may apply. Our text messaging program is described in our Text, SMS & RCS Messaging Terms.

Even if you opt out of marketing communications, we may still send administrative, transactional, legal, investor, compliance, security, or account-related communications.

10. Children's Privacy

The Services are not directed to children under the age of 18. We do not knowingly collect personal information from children under 18.

If we learn that we have collected personal information from a child under 18, we will take appropriate steps to delete the information, unless retention is required or permitted by law.

11. Third-Party Services and Links

The Services may contain links to third-party websites, platforms, applications, portals, payment processors, verification providers, document tools, or other services.

We are not responsible for the privacy practices, content, or security of third-party services. You should review the privacy policies of any third-party services before providing information to them.

12. International Users

HarborLink Holdings LLC is based in the United States. If you access or use the Services from outside the United States, your information may be transferred to, stored in, or processed in the United States or other countries where we or our service providers operate.

Those countries may have privacy laws that differ from the laws in your jurisdiction.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time.

If we make material changes, we may notify you by email, through the Services, or by other appropriate means. The updated Privacy Policy will be effective when posted unless otherwise stated.

Your continued use of the Services after the effective date of the revised Privacy Policy means you acknowledge the updated Privacy Policy.

14. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us at:

HarborLink Holdings LLC

Email: privacy@harborlink.com

Phone: (239) 994-8402

Address: 5th Ave S, Naples, Florida 34102 USA

By using the HarborLink Holdings LLC CRM, you acknowledge that you have read this Privacy Policy, understand it, and agree to its terms.