GENERAL PRIVACY NOTICE

INTRODUCTION

This is the privacy policy (Privacy Policy) of Cloud Capital Advisors LLC and its affiliated companies including Cloud Capital LLP (Cloud Capital, or we, us and our). We can be contacted at [email protected].

We have adopted the Privacy Policy to explain what Personal Information may be collected on our website at www.cloudcapital.com (the Website), how we use this Personal Information, and under what circumstances we may disclose the Personal Information to third parties. This Privacy Policy applies only to Personal Information we collect through the Website and does not apply to our collection of information from other sources.

Personal Information means any information about an individual from which that person can be identified (directly or indirectly).

This Privacy Policy, together with the Terms and Conditions (which can be found here) and our Cookie Policy (which can be found here), set forth the basis on which you may use our Website.

HOW WE USE YOUR PERSONAL INFORMATION

In the operation of the Website, and as further explained in our Cookie Policy, we collect information and data some of which may be regarded as Personal Information, such as the browser type, internet protocol (IP) addresses, language preference, referring site, and the date and time of each user visit.

We will only use your Personal Information where data protection or privacy law allows us to do so. We will use your Personal Information in the following circumstances:

To enable you to use the Website in accordance with the Terms and Conditions;
Where we have a legitimate interest in doing so, for example to run and operate the Website and to manage and administer our business, where our doing so will not unduly affect your rights;
If we need to comply with a legal obligation;

To better understand how Cloud Capital’s visitors use its Website. From time to time, Cloud Capital may analyse such information and data in the aggregate, e.g., to make a report on trends in the use of its Website.

COLLECTION OF PERSONAL INFORMATION

Users of the Website may choose to interact with the Website in ways that require us to collect Personal Information. The amount and type of information that we collect in this way gathers depends on the nature of the interaction and our Cookie Policy. For example, when you contact us through the Website, we collect the Personal Information that you provide to us, which may include your name, email address, and other contact details. In interacting with this Website, you are consenting to the collection of your Personal Information for the purposes set out in this Privacy Policy.

We will only retain your Personal Information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

Any information that the Website collects as a result of your registration or use is subject to this Privacy Policy and our Terms and Conditions.

LINKS TO EXTERNAL SITES

The Website may contain links to external sites that are not operated by us. If you click on a third party link, you will be directed to that third party’s site.

We strongly advise you to review the privacy policy and terms and conditions of every website you visit. We have no control over, and assume no responsibility for the content, privacy policies or practices of any third party websites, products or services.

COOKIES AND OTHER TRACKING

For information about the cookies we use in the operation of our Website and how you can change the settings of your browser to disable any of them, please see our Cookie Policy here. By continuing to navigate to our Website without changing your cookie settings, you hereby acknowledge and agree to the Website’s use of cookies. If you disable some of the cookies, please note that the Website may not function as intended and it may compromise your ability to use the Website.

PRIVACY POLICY CHANGES

Cloud Capital may change this Privacy Policy from time to time in our sole discretion or to reflect changes in applicable law. Cloud Capital encourages visitors to frequently check this page for any changes to its Privacy Policy. Your continued use of this website after any change in this Privacy Policy will constitute your acceptance of any such changes.

YOUR EU/UK LEGAL RIGHTS AND DISCLOSURES

Cloud Capital LLP is the data controller of the Personal Information under this Privacy Policy. We process Personal Information for the purposes identified in the “How We Use Your Personal Information” and “How We Disclose Your Personal Information” sections pursuant to the following legal bases:

Performance of a contract to which you are a party or taking steps at your request prior to entering into a contract;
Compliance with a legal or statutory obligation to which we are subject;
Your consent, when appropriate; and
Our legitimate interests in providing and improving our services, operating our business, promoting our brand and services, maintaining relationships with you, enforcing our policies, and protecting rights, property, and safety of our company and others.

If applicable to you, you have certain rights under European Union and United Kingdom data protection laws in relation to your Personal Information that we control. You have the right to:

Request access to your Personal Information;
Request correction of the Personal Information that we hold about you;
Request erasure of your Personal Information, in certain circumstances;
Object to the processing of your Personal Information where we are relying on a legitimate interest (or those of a third party);
Request restriction of processing of your Personal Information, in certain circumstances;
Request the transfer of your Personal Information to you or to a third party; and
Withdraw consent at any time where we are relying on consent to process your Personal Information.

If you wish to exercise any of the rights set out above, please contact [email protected] for further details. You additionally have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance via [email protected].

Due to the international nature of our business, your personal data may be transferred to countries outside of the UK, such as to jurisdictions where we or our clients conduct business or have a service provider, including countries that may not have the same level of data protection as that afforded by the Data Protection Act 2018, Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, and any code of practice or guidance issued by the Information Commissioner’s Office in the United Kingdom (the UK General Data Protection Regulation) or other data protection rules applicable to us. In these circumstances, we take steps to ensure that the recipient agrees to keep your information confidential and that it is held securely in accordance with the requirements of data protection laws, such as by requesting appropriate contractual undertakings in our legal agreements with service providers.

YOUR CALIFORNIA PRIVACY RIGHTS

Last updated December 2025

This notice to California residents is provided under California law, including disclosures required by the California Consumer Privacy Act (CCPA). This notice supplements our Privacy Policy by explaining your California privacy rights if you are a California resident and provides certain mandated disclosures about our collection or other use of California residents’ Personal Information that is subject to the CCPA. If you have a disability, you may access this notice through a screen-reader friendly PDF.

For the purposes of this CCPA Notice, Personal Information means information that identifies, relates to, describes, or is capable of being associated with, a particular individual. Personal information does not include information that is (i) lawfully made available to the general public from federal, state, or local government records, (ii) de-identified/ aggregated, or (iii) subject to Health Insurance Portability and Accountability Act or the Gramm-Leach Bliley Act.

How we collect your Personal Information

We collect Personal Information from the following categories of sources:

Directly from you, such as from your communications with us;
Through tracking technologies we deploy on our Website;
Third parties, including, but not limited to administrators, lenders, banks, brokers, auditors, law firms, consultants, placement agents, employment agencies, credit bureaus;
Affiliates not under the Cloud Capital brand;
Portfolio companies; and
; Government entities.

How we use your Personal Information

We generally use your Personal Information to deliver our products and services, to comply with our legal obligations, and to operate our business. This includes, for example:

Communicating with you, including about our products and services, our performance, and other updates;
Complying with our legal obligations, such as satisfying our regulatory reporting obligations and performing KYC checks;
Protecting against fraud and security incidents, including verifying and authenticating identities and accounts, detecting and protecting against illegal activity, and testing, debugging and patching our online properties;
Performing research and analytics, such as analysing information and data about our Website traffic and reporting on that analysis;
Maintaining and improving our services, such as running and operating the Website, managing and administering our business, and enabling you to use the Website;
For other internal business purposes, including in the context of transactions and reporting; and
For other purposes that may be disclosed to you at the time we collect your Personal Information.

How we disclose your Personal Information

Over the past 12 months, we have not sold your Personal Information or shared your Personal Information for targeted advertising purposes. We have also not used your Personal Information to make automated decisions that could product legal or significantly similar effects.

The categories of personal information the site handles may include identifiers, contact and account details, customer record information, protected classification characteristics, commercial and transaction data, internet or other electronic network activity information, geolocation data, audio/visual or similar recordings, professional or employment-related information, non‑public education information, inferences drawn from other data, and sensitive personal information. For all of these categories, the personal information may be disclosed for business purposes to the same limited set of third parties, namely: service providers, group affiliates, legal or governmental authorities where required by law, other entities in connection with a corporate or business transaction, and other entities where the disclosure has been authorised by you

We only use and disclose your sensitive personal information for the following purposes: (i) performing services or providing goods reasonably expected by an average consumer; (ii) detecting security incidents; (iii) resisting malicious, deceptive, or illegal actions; (iv) ensuring the physical safety of individuals; (v) for short-term, transient use, including non-personalized advertising; (vi) performing or providing internal business services; or (vii) verifying or maintaining the quality or safety of a service or device.

You have the right to request the following with respect to the Personal Information we maintain about you:

Right to access/know: You have the right to request, up to two times each year: (a) the categories and specific pieces of Personal Information we collect about you; (b) the categories of sources from which we collect your Personal Information; (c) our business or commercial purposes for collecting, selling or sharing your Personal Information; and (d) the categories of Personal Information disclosed for a business purpose, sold, or shared with third parties (for cross-context behavioral advertising) and the categories of persons to whom it was disclosed, sold, or shared (and with respect to Personal Information that is sold or shared, organized by category or categories of Personal Information for each category of third parties to whom the Personal Information was sold or shared).
Right to correct: You have the right to request we correct any inaccurate Personal Information maintained about you.
Right to delete: You have the right to request that we delete Personal Information that we collect from you, subject to applicable legal exceptions.
Right to opt out of sale/sharing: You have the right to “opt out” of the “sale” of your Personal Information or the sharing of your Personal Information for the purpose of “cross-context behavioral advertising.” As stated above, Cloud Capital does not sell or share Personal Information (as those terms are defined in the CCPA).

You may submit requests to exercise your rights email at [email protected].

We may take steps to verify your identify by asking you to authenticate yourself by providing information about you so that we can match it to the information we maintain in our records. If we are unable to verify your identity, we may need to deny your request.

You may designate an authorized agent to make a request on your behalf, and we reserve the right to seek proof that you have given the authorized agent signed permission to act on your behalf.

We endeavor to respond to a verifiable request within 45days of its receipt. If we require more time, we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. You have the right not to receive discriminatory treatment for the exercise of your privacy rights.

California Shine the Light. If you are a California resident, you may opt out of sharing your Personal Information with third parties for the third parties’ direct marketing purposes by emailing us at [email protected].