PRIVACY POLICY FOR BERKELEY & ROSS CAPITAL LLC

1. Introduction

Berkeley & Ross Capital LLC (“Berkeley & Ross Capital,” “Company,” “we,” “our,” or “us”) is committed to protecting the privacy and confidentiality of individuals who access or use our website, https://www.berkeleyrosscapital.com/ (the “Website”).

This Privacy Policy describes how we collect, use, disclose, and safeguard personal information in accordance with applicable U.S. privacy and data protection laws.

By accessing or using our Website, you acknowledge that you have read and understood this Privacy Policy.

2. Information We Collect

We may collect both personal and non-personal information, including but not limited to:

2.1 Personal Information

Information voluntarily provided by users, such as:

  • Full legal name
  • Email address
  • Telephone number
  • Company or business affiliation
  • Investment interests or inquiries
  • Any information submitted via contact forms, subscription forms, or email correspondence

2.2 Automatically Collected Information

When you access the Website, we may automatically collect:

  • IP address
  • Browser type and version
  • Device identifiers
  • Operating system
  • Pages viewed and navigation paths
  • Date and time of access
  • Referral URLs
  • Cookie and tracking data

3. Lawful Basis & Purpose of Processing

We process collected information for legitimate business purposes, including:

  • Responding to inquiries and communications
  • Providing investment-related information and services
  • Client relationship management
  • Website administration and performance monitoring
  • Marketing communications (where permitted by law)
  • Compliance with legal, regulatory, and reporting obligations
  • Fraud detection, cybersecurity, and risk management

4. Disclosure of Information

We may disclose personal information in the following circumstances:

4.1 Service Providers

To third-party vendors providing:

  • IT infrastructure and hosting
  • Analytics services
  • CRM systems
  • Administrative support

All vendors are contractually obligated to maintain confidentiality.

4.2 Legal & Regulatory Authorities

  • By law, subpoena, or court order
  • To regulators or enforcement agencies
  • To protect legal rights and prevent fraud

4.3 Corporate Transactions

  • Mergers
  • Acquisitions
  • Corporate restructuring
  • Asset sales

5. Data Retention

We retain personal information only for as long as necessary to:

  • Fulfill the purposes outlined in this Policy
  • Comply with legal and regulatory obligations
  • Resolve disputes and enforce agreements

6. Data Security

We implement commercially reasonable safeguards, including:

  • Encrypted data transmission (SSL)
  • Secure servers and firewalls
  • Access controls and authentication protocols
  • Internal confidentiality policies

Despite these measures, no system can guarantee absolute security.

7. Your Privacy Rights

Subject to applicable law, individuals may have rights to:

  • Access personal data
  • Request correction or updates
  • Request deletion (where permissible)
  • Restrict or object to processing
  • Withdraw consent (where applicable)

Requests should be submitted to:

Berkeley & Ross Capital LLC
Office 211, East 43th Street
New York, NY 10017
Phone: 212-401-6958
Email: burnett@brosscapital.com

8. International Data Transfers

If you access the Website from outside the United States, you acknowledge that information may be transferred to and processed in the U.S., where data protection laws may differ.

9. Third-Party Links

The Website may contain links to third-party websites. We are not responsible for the privacy practices or content of external sites.

10. Policy Updates

We reserve the right to amend this Privacy Policy at any time. Updates will be posted with a revised Effective Date.