Privacy

Effective Date: August 18, 2026 | Last Updated: August 18, 2026

This Rotunda Capital Partners, LLC Privacy Statement (“Privacy Statement”) describes how Rotunda Capital Partners, LLC (“Rotunda,” “we,” “us,” or “our”) collects, uses, discloses, and protects the Personal Information (as defined below) you provide and that we collect in connection with your use of our website (the “Site”), features or content owned or operated by Rotunda, or business communications including email and text messages (collectively, the “Service(s)”) that reference this Privacy Statement.

Please carefully review this Privacy Statement. Your use of the Site is an acknowledgement that you have read and understood the practices described in this Privacy Statement. If you do not agree with this Privacy Statement, please do not use our Services. Please also carefully review our Site Terms of Use and Important Disclosures, as your use of the Services also constitutes your acknowledgement of the Site’s Terms of Use and Important Disclosures.

Notification of Changes

We reserve the right to amend this Privacy Statement from time to time to reflect changes in our practices or in applicable law. When we make changes, we will revise the “Last Updated” date above and post the revised Privacy Statement on this page. If we make material changes, we will provide additional notice as required by applicable law, which may include posting a prominent notice on the Site or, where appropriate, contacting you directly. We encourage you to review this Privacy Statement periodically. Except where a different effective date is required by law or stated in the notice, changes become effective when posted, and your continued use of the Services after that time indicates your awareness of the revised Privacy Statement.

Third-Party Links

Our Site may contain links to third-party websites, such as social media pages. These links are provided for your convenience only. These third-party websites and services are not operated by Rotunda and may have separate privacy policies and data collection practices. We are not responsible for these websites or their privacy practices and encourage you to review the privacy policies of any websites you visit.

How to Contact Us

If you have questions about this Privacy Statement or our privacy practices, or if you wish to exercise your privacy rights, you may contact us at privacy@rotundacapital.com or by mail at Rotunda Capital Partners, LLC, 4747 Bethesda Avenue, Suite 1150, Bethesda, MD 20814, Attn: Privacy.

Personal Information We Collect

“Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household, such as your name, email address, telephone number, and postal address. Personal Information includes pseudonymized or aggregated personal information, unless such information has been anonymized so that it can no longer reasonably be associated with you.

The categories of Personal Information we may collect, and have collected within the preceding 12 months, include:

Sources of Personal Information

Information You Provide to Us. We collect information you give us when you use our Services, for example when you contact us or submit an inquiry. Depending on the interaction, we may ask for your name, email address, and other business contact details.

Information About Your Use of Our Services. We collect information about your device and use of the Services, such as hardware model, IP address, other unique device identifiers, operating system version and settings, and Site usage information regarding traffic patterns and interactions. We use such information for diagnostic and statistical purposes, to administer and secure the Site, and to improve the user experience, including through cookies as described below.

Information Collected from Other Sources. We may receive information about you from other sources to help us correct or supplement our records, improve the quality or personalization of our Services, and prevent or detect fraud.

Cookies and Other Tracking Technologies

Cookies are small files that a site or its provider transfers to your device through your web browser, enabling the site’s system to recognize your browser and remember certain information. A cookie may be a “session” cookie, which remains only until you stop browsing, or a “persistent” cookie, which remains until it expires or is deleted. We and our providers also use similar technologies such as pixels, web beacons, and software development kits.

The cookies and technologies used on our Services may be categorized as: Strictly Necessary, which are required for the Services to operate; Functional or Preference, which remember your choices; Performance or Analytics, which collect information about how the Services are used. We do not use cookies or similar technologies for advertising or targeting purposes.

We use first-party and third-party cookies to make our Services function, to improve the Site, to make login easier, to recognize returning visitors, to analyze and enhance your experience, to remember information you have provided, and to provide a secure browsing experience.

Consent and Control. Where required by applicable law (including in the European Economic Area, the United Kingdom, and Switzerland), we deploy non-essential cookies only after obtaining your consent through our cookie banner or preference center, and you may withdraw consent at any time using that tool. Where applicable, we also honor opt-out preference signals such as the Global Privacy Control (GPC) as described in the “Notice to U.S. State Residents” section below.

Your Choices

Your browser may allow you to refuse some or all browser cookies or to remove cookies. You can exercise these preferences as outlined below.

First-Party Cookies. You can use your browser to enable, disable, or delete cookies by following the instructions provided by your browser (usually located within its “Help,” “Tools,” or “Settings” menus). If you disable cookies, you may not be able to access secure areas of the Site, and other parts of the Services may not work properly. You can find more information at allaboutcookies.org.

Opt-Out Preference Signals. Where required by law, we treat recognized browser-based opt-out preference signals (such as GPC) as a valid request to opt out of the “sale” or “sharing” of Personal Information and of targeted advertising for the browser or device from which the signal is sent.

Most web browsers provide help pages relating to cookie preferences.

How We Use Your Personal Information

We use your Personal Information as described in this Privacy Statement or as otherwise disclosed to you before processing takes place, including to:

Provide Our Services. To provide information or perform services you request. Where a service is provided by a third party, we may disclose applicable information to that party, which is contractually obligated to protect your information consistent with this Privacy Statement.

Operate and Improve Our Business. To further our business, including analyzing how the Services are used (such as pages visited and links clicked, which may be associated with an IP address) to provide a more meaningful experience and, in aggregated or de-identified form, to develop and improve our Services.

Provide Support and Respond to You. To respond to your questions, concerns, feedback, or issues. Without your Personal Information, we cannot respond to you.

Enforce Our Terms and Protect the Services. To monitor, investigate, prevent, and mitigate prohibited or unlawful activity; to enforce our terms, agreements, and policies; and to combat spam, malware, and security risks, including by verifying identity so that unauthorized users do not gain access.

Maintain Legal and Regulatory Compliance. To comply with applicable laws and regulations, including tax, recordkeeping, anti-money-laundering, and other obligations, and to establish, exercise, or defend legal claims.

Engage in Marketing Activities. To send you marketing communications and information about events, products, and services, in each case consistent with applicable law and your choices.

Disclosure of Your Personal Information

We may disclose your Personal Information to the categories of recipients described below. We do not disclose Personal Information except as described in this Privacy Statement.

Within Our Organization. Rotunda is part of an organization that includes multiple legal entities, partners, business processes, and systems. We may share your Personal Information within our organization to provide the Services and act on your requests.

Affiliated Businesses. We work closely with affiliated businesses, which will identify themselves at the time of data collection. As permitted by law or with your consent, Personal Information related to a transaction with an affiliated business may be shared with that business.

Service Providers and Business Partners. We share Personal Information with service providers, contractors, and business partners that perform services on our behalf (such as hosting, analytics, communications, and security). These parties are permitted to use Personal Information only to perform services for us and are contractually obligated to protect it, and they have no independent right to use or disclose it except as we direct.

Corporate Transactions. If Rotunda is involved in a merger, acquisition, financing, reorganization, divestiture, sale of assets, or similar transaction, Personal Information may be disclosed to prospective or actual counterparties and their advisors, subject to appropriate confidentiality protections.

Legal and Regulatory. We may disclose Personal Information in response to subpoenas, warrants, court orders, or other legal or regulatory process, or as otherwise required by law. Where permitted, we will attempt to notify you before responding.

To Protect You, Us, or Others. We may disclose Personal Information where we believe in good faith that doing so is necessary to protect the rights, property, or safety of you, Rotunda, our personnel, or others.

“Sale” and “Sharing” of Personal Information

Rotunda does not sell your Personal Information for monetary consideration. We do not use cookies or similar technologies for cross-context behavioral or targeted advertising, and we do not “share” Personal Information for those purposes under U.S. state privacy laws. You may nonetheless exercise the opt-out rights described in the “Notice to U.S. State Residents” section, including by using recognized opt-out preference signals. We do not “sell” or “share” the Personal Information of individuals we know to be under 16 years of age. We do not sell or share your mobile telephone number or text-messaging data with third parties for their own marketing purposes.

Retention and Security of Personal Information

We consider the protection of Personal Information to be a sound business practice and employ appropriate technical, administrative, and organizational measures, including physical, electronic, and procedural safeguards, to protect Personal Information in our possession or under our control. No method of transmission or storage is completely secure, however, and we cannot guarantee absolute security.

We retain Personal Information for as long as necessary to fulfill the purposes described in this Privacy Statement, unless a longer retention period is required or permitted by law. To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the information; the potential risk of harm from unauthorized use or disclosure; the purposes for which we process it; and applicable legal, regulatory, tax, accounting, and recordkeeping requirements (including obligations applicable to SEC-registered investment advisers). We ask that you also take responsibility for safeguarding the Personal Information you share with us.

Children

Our Services are directed to a professional audience and are not intended for, and we do not knowingly collect Personal Information from, individuals under the age of 18. Consistent with the U.S. Children’s Online Privacy Protection Act (COPPA) and applicable state laws, if we become aware that we have collected Personal Information from a child under the age of 13 (or a higher age where required by applicable law) without appropriate consent, we will take reasonable steps to delete such information. If you believe a minor has provided us with Personal Information, please contact us using the information above.

Notice to U.S. State Residents

This section provides additional information for residents of U.S. states that have enacted comprehensive consumer privacy laws (including, as applicable, California, Colorado, Connecticut, Virginia, Maryland, Texas, and other states with laws in effect). It supplements the rest of this Privacy Statement. The specific rights available to you, and any exceptions, depend on the law of your state of residence. Certain information we process may be exempt from these laws, including information subject to the Gramm-Leach-Bliley Act (GLBA) and other financial-services regulations.

Your State Privacy Rights

Subject to certain exceptions and depending on your state of residence, you may have the right to:

• Know / Access – confirm whether we process your Personal Information and request access to it, including the categories collected, sources, purposes, and categories of recipients;
• Delete – request deletion of Personal Information we have collected from you;
• Correct – request correction of inaccurate Personal Information;
• Data Portability – obtain a copy of your Personal Information in a portable and, to the extent technically feasible, readily usable format;
• Opt Out of Sale/Sharing and Targeted Advertising – direct us not to “sell” or “share” your Personal Information or use it for targeted advertising;
• Opt Out of Profiling – opt out of profiling in furtherance of decisions that produce legal or similarly significant effects (we do not currently engage in such profiling);
• Limit Sensitive Personal Information – limit the use and disclosure of sensitive Personal Information where applicable; and
• Non-Discrimination – not receive discriminatory treatment for exercising your rights.

How to Exercise Your Rights

You may submit a request by emailing finance@rotundacapital.com or using the contact information above. To opt out of the sale/sharing of Personal Information or of targeted advertising, you may also enable a recognized opt-out preference signal, such as the Global Privacy Control (GPC), in your browser. We will treat a valid GPC signal as a request to opt out for the applicable browser or device.

Verification. For your protection, we may need to verify your identity before responding to a request, and we may decline requests we cannot reasonably verify.

Authorized Agents. You may use an authorized agent to submit a request on your behalf where permitted by law. We may require the agent to provide proof of authorization and may require you to verify your identity directly.

Appeals. If we decline to take action on your request, you may appeal by replying to our response or contacting us at the address above. Where required by law, if your appeal is denied you may contact your state Attorney General.

California “Shine the Light.” California Civil Code § 1798.83 permits California residents to request certain information about disclosure of Personal Information to third parties for their direct-marketing purposes. We do not disclose Personal Information to third parties for their own direct-marketing purposes.

Notice to Individuals in the EEA, the United Kingdom, and Switzerland

This section applies to individuals who access or use our Services while located in the European Economic Area (EEA), the United Kingdom (UK), or Switzerland (collectively, the “Designated Countries”). We may ask you to identify your country, or we may rely on your IP address. Where we rely on IP address, we cannot apply this section to any individual who masks or hides their location. If any term in this section conflicts with another term of this Privacy Statement, this section applies for users in the Designated Countries.

Controller. Rotunda is the controller of Personal Information collected from individuals who access or use the Services. A “controller” determines the purposes and means of processing Personal Information.

Legal Bases for Processing

Where the GDPR (or the UK GDPR) applies, we process your Personal Information on one of the following legal bases:

• Consent – where you have given consent (Article 6(1)(a)); you may withdraw consent at any time without affecting prior processing;
• Contract – where processing is necessary to perform a contract with you or to take pre-contractual steps at your request (Article 6(1)(b));
• Legal Obligation – where processing is necessary to comply with a legal obligation, such as anti-money-laundering requirements (Article 6(1)(c)); and
• Legitimate Interests – where processing is necessary for our or a third party’s legitimate interests that are not overridden by your rights, such as securing our Services and establishing or defending legal claims (Article 6(1)(f)).

International Transfers of Personal Information

We may store, process, and transmit Personal Information in locations outside your country or jurisdiction, including in the United States, which may have data-protection laws that differ from those where you reside. When we transfer Personal Information out of the Designated Countries, we implement appropriate safeguards required by applicable law. These safeguards may include the European Commission’s Standard Contractual Clauses, and the UK International Data Transfer Agreement or UK Addendum, and the Swiss addendum, as applicable (which is our primary transfer mechanism where appropriate), Binding Corporate Rules where applicable, and—where a recipient in the United States is self-certified—the EU-U.S. Data Privacy Framework, together with the UK Extension and the Swiss-U.S. Data Privacy Framework. You may request a copy of the relevant safeguards using the contact information above.

Your Individual Rights

Subject to conditions and exceptions under applicable law, you have the rights described below. To the extent permitted by applicable law, we may limit a request where: (a) denial is required or authorized by law; (b) granting it would adversely affect the rights of others; (c) it is necessary to protect our rights or property; or (d) the request is manifestly unfounded, excessive, or repetitive. When we fulfill a request for correction, erasure, or restriction, we will notify third parties handling the relevant Personal Information unless doing so proves impossible or involves disproportionate effort.

• Right of Access – to obtain confirmation of, and access to, your Personal Information free of charge. However, we may charge a ‘reasonable fee’ if we consider that your request is excessive to help us cover the costs of locating the information you have requested;
• Right to Rectification – to have inaccurate or incomplete Personal Information corrected or updated;
• Right to Erasure – to request deletion of your Personal Information in certain circumstances. Please note that this may not always be possible due to legal obligations;
• Right to Object – to object to certain processing, including for (i) direct marketing; (ii) for research or statistical purposes; or (iii) where processing is based on legitimate interests;
• Right to Restriction – to request that we stop processing your Personal Information (other than storing it) if: (i) you contest the accuracy of it (until the accuracy is verified); (ii) you believe the processing is against the law; (iii) you believe that we no longer need your Personal Information for the purposes for which it was collected; or (iv) you object to the processing, and we are verifying whether our legitimate grounds to process your Personal Information override your own rights;
• Right to Data Portability – to receive your Personal Information in a structured, commonly used, machine-readable format;
• Right to Withdraw Consent – to withdraw consent if you previously gave us your consent (by a clear affirmative action) to allow us to process your Personal Information for a particular purpose, and you no longer wish to consent to us doing so, you may contact us to let us know that you withdraw that consent; and
• Automated Decision-Making – the right not to be subject to a decision based solely on automated processing, including profiling, that produces legal or similarly significant effects. We do not subject your Personal Information to such processing.

We may ask you to verify your identity before responding. To exercise your rights, contact us at finance@rotundacapital.com. You also have the right to lodge a complaint with a supervisory authority, such as your local EEA data protection authority, the UK Information Commissioner’s Office (ICO), or the Swiss Federal Data Protection and Information Commissioner (FDPIC).

Financial-Services Privacy Notice

To the extent Rotunda collects nonpublic personal information about individuals who obtain financial products or services primarily for personal, family, or household purposes, that information is handled in accordance with the Gramm-Leach-Bliley Act and SEC Regulation S-P, and may be provided under a separate privacy notice. Information subject to those requirements may be exempt from certain provisions of the state privacy laws described above.

Text Messaging Disclosures

Use of Text Messaging

We may communicate with business contacts via text message (SMS/MMS) for business purposes, including scheduling, follow-up, and other business communications, and, where permitted by applicable law and with requisite consent, informational or marketing messages.

Consent to Receive Text Messages

By providing your mobile telephone number to us, to the extent permitted by applicable law, you consent to receive text messages from us at that number. Your consent is not a condition of purchasing any product or service. Message frequency varies. Message and data rates may apply.

Information Collection and Use

In connection with our text-messaging program, to the extent permitted by applicable law, we may collect your mobile phone number and contact details, and message content, delivery data, and interaction history. We use this information to deliver requested communications and services, respond to inquiries and provide support, maintain records as required under applicable securities laws, and comply with legal and regulatory obligations. Text-messaging data forms part of our required business communications and will be retained in accordance with applicable SEC recordkeeping obligations.

Opt-Out and Help

You may opt out of receiving text messages at any time by replying “STOP” to any message or by contacting us using the information in this Privacy Statement. After you opt out, we will cease sending text messages except as required for administrative, regulatory, or legal purposes. For help, reply “HELP” to any message or contact us using the information above.

Data Sharing and Service Providers

We do not sell or share your mobile number or SMS data with third parties for their marketing or lead-generation purposes. We may share such information with trusted service providers solely to facilitate delivery of text messages or to support our operations, subject to appropriate confidentiality and security obligations. No mobile information will be shared with third parties or affiliates for marketing or promotional purposes.

Data Security and Additional Disclosures

We maintain reasonable administrative, technical, and physical safeguards designed to protect your Personal Information, including information collected through SMS communications, and retain such information as necessary to fulfill the purposes described above and to comply with legal and regulatory requirements. Text messaging may not be a secure method of communication; you should avoid transmitting sensitive personal or financial information via text message unless specifically requested and appropriate safeguards are in place. Carriers are not liable for delayed or undelivered messages.