effective date: January 30, 2025
Last Updated: October 30th, 2025

Our Commitment to Privacy
Black Harbor Capital Group (“Black Harbor,” “we,” “us,” or “our”) is committed to safeguarding the privacy and security of your personal information. We collect, process, and store data in accordance with applicable privacy and data protection laws, including the California Consumer Privacy Act (CCPA), General Data Protection Regulation (GDPR), and Telephone Consumer Protection Act (TCPA).
This Privacy Policy explains how we collect, use, and protect your information when you interact with our websites, mobile applications, communications, and related services (collectively, the “Services”).

Information We Collect
We collect and process personal data that you voluntarily provide or that is automatically gathered through your use of our Services, including:
• Identification Data: Name, email address, phone number, and postal address.
• Investor Information: Investment objectives, financial background, and communication records.
• Transactional Data: Information about purchases, payments, or investments made through our platforms.
• Device & Usage Data: IP address, browser type, access times, referring pages, and device identifiers.
• Compliance Information: KYC (Know Your Customer) and AML (Anti-Money Laundering) documentation where applicable.
• Communications Data: Messages, calls, and SMS correspondence (including A2P messaging consent records).

How We Use Information
We process personal information for legitimate business purposes, including:
• To provide onboarding, account setup, and investor support.
• To process transactions, investments, and service requests.
• To communicate via email, SMS, and automated messaging — only after obtaining your express consent.
• To comply with regulatory, anti-fraud, and compliance obligations.
• To improve site functionality, analytics, and user experience.
• To protect the integrity and security of our systems.
You may withdraw consent to receive marketing or informational texts at any time by replying “STOP” to any SMS message. Message and data rates may apply.

Legal Basis for Processing
We rely on one or more of the following legal bases to process your information:
• Your consent;
• The performance of a contract with you;
• Compliance with a legal or regulatory obligation;
• Legitimate business interests, such as preventing fraud or improving our services.

Data Security & Storage
All data is encrypted in transit and at rest within SOC 2 and ISO 27001–certified environments.
We implement administrative, physical, and technical safeguards to prevent unauthorized access, alteration, or disclosure.
Access to personal data is restricted to authorized personnel and service providers under strict confidentiality agreements.

Data Retention
We retain personal information only as long as necessary to:
• Fulfill the purpose for which it was collected;
• Comply with applicable laws and regulations;
• Resolve disputes and enforce agreements.
When data is no longer needed, it is securely deleted or anonymized.

Your Rights
Depending on your jurisdiction, you may have the right to:
• Access, correct, or delete your personal data;
• Object to or restrict processing;
• Withdraw consent for marketing communications;
• Request data portability.
To exercise these rights, please contact privacy@blackharbor.us with “Privacy Request” in the subject line.

International Data Transfers
We may process or transfer your data outside your country of residence. All transfers comply with applicable data protection standards, ensuring equivalent levels of privacy and security.

Disclosure of Information
We do not sell personal data. We may share information only with:
• Authorized vendors and service providers supporting our operations (subject to NDAs and data processing agreements);
• Regulatory or legal authorities where required by law;
• Successors in the event of a merger, acquisition, or asset sale, with notice provided to affected users.

Automated Messaging & A2P 10DLC Compliance
By submitting your phone number via our website or forms, you consent to receive automated text messages from Black Harbor Capital Group for updates, confirmations, and account-related communications.
• Message frequency varies.
• Reply STOP to opt out or HELP for assistance.
• Consent is not a condition of purchase or investment.
• Data related to consent and opt-out activity is stored securely for compliance verification.

Cookies & Tracking Technologies
Our websites use cookies, pixels, and analytics tools to improve user experience and measure engagement. You can manage cookie preferences in your browser settings.

Policy Updates
We may revise this Privacy Policy periodically to reflect new laws or business practices. The “Effective Date” above will indicate the most recent revision. Significant updates will be communicated via email or website notice.

Contact Us
Privacy Officer
Black Harbor Capital Group
Email: privacy@blackharbor.us
Website: https://blackharbor.us