Privacy Policy

1. INTRODUCTION

PivotPt Capital LLC (“PivotPt Capital,” “we,” “us,” or “our”) operates the website located at pivotptcapital.com (the “Site”). This Privacy Policy explains how we collect, use, disclose, and protect information about you when you visit the Site or communicate with us in connection with our investment activities.

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

2. WHO WE ARE

PivotPt Capital is a private investment management firm focused on boutique hotel acquisitions. The Site is intended for use by accredited investors, prospective limited partners, and professional counterparties. It is not directed to the general public for solicitation purposes.

3. INFORMATION WE COLLECT

Information you provide directly:

Name, email address, phone number, and professional title submitted via contact or inquiry forms

Accreditation status and investment interest information you choose to share

Communications you send to us by email or through the Site

Information collected automatically:

IP address, browser type, operating system, and device identifiers

Pages visited, time spent on pages, and referring URLs

Cookies and similar tracking technologies (see Section 7)

Information from third parties:

Professional background information from publicly available sources (LinkedIn, regulatory filings, press) used in connection with investor qualification

Data from service providers who assist with investor relations, email delivery, and platform operations

4. HOW WE USE YOUR INFORMATION

We use the information we collect to:

Respond to inquiries and communicate with prospective and current limited partners

Evaluate investor eligibility and maintain required records under applicable securities regulations

Deliver investor materials, fund updates, and distribution notices

Operate, maintain, and improve the Site

Comply with legal obligations, including anti-money laundering (AML) and know-your-customer (KYC) requirements

Protect against fraud, unauthorized access, and other harmful activity

We do not sell your personal information to third parties. We do not use your information for behavioral advertising.

5. LEGAL BASIS FOR PROCESSING

Where applicable law requires a legal basis for processing personal data, we rely on the following:

Contractual necessity: to fulfill obligations to limited partners and counterparties

Legitimate interests: to operate the Site, communicate with prospective investors, and protect the firm

Legal obligation: to comply with securities law, AML/KYC requirements, and regulatory recordkeeping

Consent: where you have affirmatively provided it, such as by submitting an inquiry form

6. HOW WE SHARE YOUR INFORMATION

We may share your information with:

Service providers who perform functions on our behalf, including email delivery (SendGrid), cloud infrastructure (Google Cloud), and investor CRM platforms, under confidentiality obligations

Legal and regulatory authorities when required by law, court order, or regulatory inquiry

Professional advisors including attorneys, accountants, and auditors, subject to confidentiality obligations

Successor entities in the event of a merger, acquisition, or fund restructuring, subject to customary confidentiality protections

We do not share investor information with other portfolio companies, hotel operators, or consumer-facing entities, including Beco Collective LLC.

7. COOKIES AND TRACKING

The Site uses cookies and similar technologies to support basic site functionality and to understand how visitors use the Site. We do not use third-party advertising cookies.

You may configure your browser to refuse cookies. Some Site features may not function properly if cookies are disabled. We do not respond to Do Not Track signals at this time, as no uniform standard has been adopted.

8. DATA RETENTION

We retain personal information for as long as necessary to fulfill the purposes described in this Policy, or as required by law. Information related to investor relationships and fund records is retained for a minimum of seven years in accordance with applicable securities regulations. Contact and inquiry records are retained for up to three years unless a business relationship develops.

9. SECURITY

We implement administrative, technical, and physical safeguards designed to protect your information against unauthorized access, disclosure, alteration, and destruction. These include access controls, encrypted transmission (TLS), and restricted access to investor data within our platform.

No security measure is perfect. We cannot guarantee that unauthorized parties will never defeat our safeguards.

10. THIRD-PARTY LINKS

The Site may contain links to third-party websites, including regulatory filings, news sources, or service provider portals. We are not responsible for the privacy practices of those sites and encourage you to review their policies independently.

11. CHILDREN’S PRIVACY

The Site is not directed to individuals under the age of 18. We do not knowingly collect personal information from minors. If we become aware that we have collected such information, we will delete it promptly.

12. YOUR RIGHTS AND CHOICES

Depending on your jurisdiction, you may have rights including:

Access: request a copy of the personal information we hold about you

Correction: request correction of inaccurate or incomplete information

Deletion: request deletion of your information, subject to legal retention requirements

Objection or restriction: object to or request restriction of certain processing activities

Portability: receive your information in a structured, machine-readable format

To exercise any of these rights, contact us at the address below. We will respond within the timeframe required by applicable law. We may need to verify your identity before processing your request.

California residents may have additional rights under the California Consumer Privacy Act (CCPA), including the right to know what categories of personal information we have collected and the right to opt out of sale (we do not sell personal information).

13. INTERNATIONAL DATA TRANSFERS

PivotPt Capital is based in the United States. If you access the Site from outside the United States, your information may be transferred to, stored, and processed in the United States, where data protection laws may differ from those in your country. By using the Site, you consent to this transfer.

14. CHANGES TO THIS POLICY

We may update this Privacy Policy from time to time. When we do, we will revise the Effective Date at the top of this page. Material changes will be communicated to known investors by email. Your continued use of the Site following any update constitutes acceptance of the revised Policy.

15. CONTACT

For questions, requests, or concerns regarding this Privacy Policy, contact:

PivotPt Capital LLC Privacy Inquiries

privacy@pivotptcapital.com