PRIVACY policy.

This Privacy Policy describes how Rauxmont Capital LLC ("Rauxmont Capital," "we," "us," or "our") collects, uses, discloses, and protects personal information about individuals ("you" or "your") who access our website, investor portal, or related services (collectively, the "Platform"). Please read this Policy carefully. By accessing or using the Platform, you agree to the practices described herein. If you do not agree, please do not use the Platform.

This Privacy Policy should be read alongside our Terms of Service, which govern your use of the Platform.

1. Scope and Applicability

This Privacy Policy applies to personal information we collect through:

• Our website at rauxmontcapital.com and any subdomains;
• Our private investor portal accessible at rauxmontcapital.com/portal;
• Email communications and electronic messages sent to or from us;
• Investor onboarding and eligibility verification processes; and
• Any other interactions you have with Rauxmont Capital in connection with our services.

This Policy does not apply to information collected by third-party websites or services that may be linked from the Platform. We are not responsible for the privacy practices of such third parties.

2. Information We Collect

2.1 Information You Provide Directly

Identity Information: When you request access to the investor portal, we collect your full legal name, email address, and any other identifying information you provide in connection with your access request.

Accredited Investor Verification Information: To comply with applicable securities laws, we may collect information necessary to verify your status as an "Accredited Investor" as defined under Rule 501 of Regulation D. This may include information about your annual income, net worth, professional licenses (e.g., Series 7, 65, or 82), investment experience, or, for entities, information about your organization's total assets or ownership structure. We may also request supporting documentation such as tax returns, account statements, or professional certifications.

Communications: We retain records of communications you send to us, including emails, portal messages, and inquiries, together with any information you choose to include.

Investment Activity: When you express interest in investment opportunities through the Platform, we record your actions (such as requesting materials or indicating interest), the relevant deal, and the timestamp of each action.

2.2 Information We Collect Automatically

Authentication Data: Our Platform uses a passwordless authentication system. When you log in, we generate and transmit a one-time numeric code to your email address. We record authentication attempts, successful logins, code issuance, and session activity. Sessions are maintained using HTTP-only cookies stored on your device.

Log Data: Our servers and infrastructure providers automatically collect information when you access the Platform, including your IP address, browser type and version, operating system, device identifiers, referring URLs, pages visited, time spent on pages, and other usage statistics.

Cookies and Similar Technologies: We use HTTP-only session cookies strictly necessary for authentication and session management. These cookies do not track you across other websites and are deleted when you log out or when your session expires. We do not currently use analytics cookies, advertising cookies, or third-party tracking technologies on the investor portal. Our public marketing website may use limited analytics as described in Section 7.

2.3 Information from Third Parties

We may receive information about you from third-party identity verification services, background check providers, or other sources we use to verify accredited investor status or conduct required due diligence. We may also receive information from referral sources who recommend you for portal access.

3. How We Use Your Information

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

3.1 Providing and Operating the Platform

• Authenticating your identity and managing your account and session;
• Evaluating and processing your request for investor portal access;
• Providing you with access to investment opportunity information and materials;
• Processing and recording your expressions of interest in investment opportunities;
• Communicating with you about your account, access status, and available opportunities; and
• Responding to your inquiries and providing customer support.

3.2 Legal and Regulatory Compliance

• Verifying your accredited investor status in accordance with applicable securities laws, including Regulation D under the Securities Act of 1933;
• Complying with applicable anti-money laundering (AML) and know-your-customer (KYC) obligations;
• Maintaining records required by applicable law or regulation;
• Responding to legal process, court orders, or regulatory requests; and
• Enforcing our Terms of Service and other agreements.

3.3 Security and Fraud Prevention

• Detecting, investigating, and preventing fraudulent transactions and other unauthorized activity;
• Protecting the security and integrity of the Platform and our systems; and
• Maintaining audit logs of portal access and activity for security and compliance purposes.

3.4 Business Operations

• Operating and improving the Platform and our services;
• Analyzing usage patterns to enhance security and user experience;
• Notifying authorized personnel at Rauxmont Capital of investor activity (e.g., deal interest); and
• Managing and administering investment vehicles in which you participate.

3.5 Legal Basis (for EEA/UK Residents)

If you are located in the European Economic Area or the United Kingdom, we process your personal information on the following legal bases: (a) performance of a contract (operating your account and providing our services); (b) compliance with legal obligations (AML/KYC, securities law compliance); (c) our legitimate interests (security, fraud prevention, and improvement of our services); and (d) your consent, where applicable.

4. How We Share Your Information

We do not sell your personal information. We do not share your personal information for third-party advertising or marketing purposes. We may share your information in the following limited circumstances:

4.1 Service Providers

We engage third-party service providers who process personal information on our behalf to support the operation of the Platform. These providers are contractually obligated to use your information only as directed by us and in accordance with this Policy. Our key service providers include:

• Database and Infrastructure: We use a cloud database provider to store user account information, investment activity records, and audit logs securely.
• Email Delivery: We use a transactional email service provider to deliver authentication codes, access notifications, and other account-related communications to your email address.
• Hosting: Our Platform is hosted on a cloud infrastructure provider. Your data may be processed on servers located in the United States.

4.2 Portfolio Companies and Co-Investors

If you invest through a special purpose vehicle (SPV) facilitated by Rauxmont Capital, certain information about you may be shared with the portfolio company or other parties as required to complete the investment, including for capitalization table management, regulatory filings, or investor communications. The extent of such sharing will be described in the applicable SPV governing documents.

4.3 Legal and Regulatory Disclosure

We may disclose your personal information if required to do so by law, court order, subpoena, or other legal process, or if we believe in good faith that disclosure is necessary to: (a) comply with applicable law or regulation; (b) protect the rights, property, or safety of Rauxmont Capital, our investors, or others; (c) investigate fraud, security breaches, or other potential violations; or (d) respond to requests from government or regulatory authorities.

4.4 Business Transfers

If Rauxmont Capital LLC is involved in a merger, acquisition, reorganization, sale of assets, or similar transaction, your personal information may be transferred as part of such transaction, subject to standard confidentiality obligations. We will provide notice before your information is transferred and becomes subject to a different privacy policy.

4.5 With Your Consent

We may share your information with third parties for any other purpose with your explicit prior consent.

5. Data Retention

We retain personal information for as long as necessary to fulfill the purposes described in this Policy, including to provide our services, comply with legal obligations, resolve disputes, and enforce our agreements. The specific retention periods depend on the category of information:

• Account Information: Retained for the duration of your account relationship and for a period of at least seven (7) years following the termination of your account, to comply with applicable recordkeeping requirements.
• Accredited Investor Verification Records: Retained for a minimum of five (5) years from the date of last verification, consistent with SEC Regulation D recordkeeping requirements, or longer if required by applicable law.
• Authentication and Session Logs: Authentication codes expire after 10 minutes and are purged after use. Session logs and access audit records are retained for up to three (3) years for security and compliance purposes.
• Investment Activity Records: Records of investment interest, materials requests, and participation in investment opportunities are retained indefinitely or as required by applicable law and the governing documents of any relevant SPV.
• Email Communications: Retained for up to three (3) years, unless a longer period is required by law.

When personal information is no longer required, we dispose of it securely in accordance with applicable data protection standards.

6. Data Security

We implement commercially reasonable administrative, technical, and physical safeguards designed to protect your personal information against unauthorized access, use, disclosure, alteration, or destruction. These measures include:

• Encryption of data in transit using TLS/HTTPS;
• HTTP-only session cookies that are not accessible to client-side scripts;
• Passwordless authentication using single-use codes with short expiration windows;
• Access controls limiting employee access to personal information on a need-to-know basis;
• Audit logging of administrative and investor portal activity; and
• Use of cloud infrastructure providers with industry-standard security certifications.

Despite our efforts, no security system is impenetrable. We cannot guarantee the absolute security of your personal information. In the event of a data breach that is likely to result in a high risk to your rights and freedoms, we will notify you and, where required, applicable regulatory authorities in accordance with applicable law.

7. Cookies

Investor Portal: The investor portal uses only strictly necessary HTTP-only session cookies for authentication. These cookies are required for the portal to function and cannot be disabled without preventing login. They contain no personally identifiable information directly and expire when your session ends or you log out.

Public Website: Our public marketing website (rauxmontcapital.com) may use limited first-party analytics to understand aggregate traffic patterns. We do not use third-party advertising cookies or cross-site tracking technologies. You can disable cookies through your browser settings, which may affect certain website functionality.

We do not use cookies to track your activity across other websites or to serve you targeted advertisements.

8. Your Rights and Choices

8.1 Access, Correction, and Deletion

You may request access to the personal information we hold about you, request corrections to inaccurate information, or request deletion of your information by contacting us at rohan@rauxmontcapital.com. We will respond to your request within a reasonable time and in accordance with applicable law. Please note that certain information may be retained as required by law (including securities and AML recordkeeping requirements) or for legitimate business purposes even after a deletion request.

8.2 Email Communications

You may opt out of receiving non-essential marketing communications from us at any time by following the unsubscribe instructions in any email we send, or by contacting us directly. Please note that certain communications are transactional or regulatory in nature (such as authentication codes, access decisions, and legal notices) and are not subject to opt-out.

8.3 Account Closure

You may request closure of your investor portal account at any time by contacting us. Account closure will result in termination of your access to the Platform. Certain records related to your account may be retained as described in Section 5.

8.4 California Residents: CCPA Rights

If you are a California resident, you have the following rights under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 ("CCPA/CPRA"):

• Right to Know: You have the right to request disclosure of the categories and specific pieces of personal information we have collected about you, the categories of sources from which it was collected, the business or commercial purposes for collecting it, and the categories of third parties with whom we share it.
• Right to Delete: You have the right to request deletion of personal information we have collected from you, subject to certain exceptions (including legal compliance and legitimate business needs).
• Right to Correct: You have the right to request correction of inaccurate personal information we maintain about you.
• Right to Opt Out of Sale or Sharing: We do not sell or share personal information for cross-context behavioral advertising. You do not need to take any action to opt out.
• Right to Limit Use of Sensitive Personal Information: We do not use sensitive personal information (such as financial account details) for purposes beyond those necessary to provide our services.
• Right to Non-Discrimination: We will not discriminate against you for exercising your CCPA rights.

To exercise your California privacy rights, please contact us at rohan@rauxmontcapital.com. We will verify your identity before processing your request. You may designate an authorized agent to submit requests on your behalf, subject to verification requirements.

Categories of Personal Information Collected (in the past 12 months): Identifiers (name, email address, IP address); financial and professional information (income, net worth, professional licenses) for accredited investor verification; internet or other electronic network activity (log data, portal usage); inferences drawn from the above to evaluate investor eligibility.

8.5 Nevada Residents

Nevada residents may submit a request to opt out of the sale of certain covered information by contacting us at the address below. We do not sell covered information as defined under Nevada law.

9. Children's Privacy

The Platform is not directed to, and we do not knowingly collect personal information from, individuals under the age of 18. If you believe we have inadvertently collected personal information from a minor, please contact us immediately and we will take steps to delete such information.

10. International Users

The Platform is intended for use by persons located in the United States. If you access the Platform from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States, where our servers are located and our operations are conducted. Data protection laws in the United States may differ from those in your jurisdiction. By using the Platform, you consent to the transfer of your information to the United States.

11. Third-Party Links

The Platform may contain links to third-party websites or resources. Rauxmont Capital does not control and is not responsible for the content, privacy practices, or data collection activities of any third-party website. We encourage you to review the privacy policies of any third-party sites you visit.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, applicable law, or for other operational, legal, or regulatory reasons. When we make material changes, we will update the "Last Updated" date at the top of this Policy and, where appropriate, notify registered users by email or through the Platform. Your continued use of the Platform after any change to this Policy constitutes your acceptance of the updated Policy.

13. Contact Us

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

Rauxmont Capital LLC
Email: rohan@rauxmontcapital.com

We will endeavor to respond to all legitimate privacy inquiries within thirty (30) days.

This Privacy Policy was last updated on June 14, 2026.