Attention: This is a site-wide announcement.

Privacy Policy

Last updated 11/30/2022

The Privacy listed below apply to Karmel Capital Management LLC, Karmel Capital LLC, all related general partners and partnerships, and all managed funds (collectively “Karmel”). Investors in a Karmel-managed fund may obtain the privacy policy related to such fund and the investor relationship with Karmel from Karmel directly. The Privacy Policy included below relates to use of the Site. By visiting the Site, you are consenting to our collection, use, disclosure, retention, and protection of information about you and devices you use as described in this Privacy Policy. Our Site is not directed to children under the age of 13. We do not knowingly collect personal information from children under age 13. This Privacy Policy does not apply to anonymized or aggregated data that does not allow us or third parties to identify or contact you.This Notice only addresses our own information practices. This Notice does not apply to information you share with third parties even if we link to those third parties from a Site. These third parties may have their own privacy policies governing their use of information that you can access from their websites.Please note that other parties may collect personally identifiable information about your online activities over time and across different websites when you use our Site.

What Information Does Karmel Gather?

Information You Give Us. We may collect and retain any information from you or your devices provided to us when you visit the Site, including when you: use our service; register for an account; or communicate with us

Automatically Collected Information.

We may collect information automatically when you visit our Site or use our mobile applications, such as:your IP address; the type of browser, devices and operating systems you use; identifiers associated with the device(s) you use to access our Site; the pages you visit, vehicles you view or configure, and the features you use, including dates and times; if you navigated from or navigate to another website, the address of that website; and information regarding your internet service provider.In addition, we may collect information about your activities on our Sites through the use of cookies, clear GIFs or web beacons, local shared objects or Flash cookies, or through other identifiers or technologies, including similar technologies as they may evolve over time. We refer to these technologies collectively as Metrics Tools.We may allow third parties to use Metrics Tools on our Sites. The information collected by Metrics Tools may be shared with and used by us, by others acting on our behalf, or by third parties subject to their own privacy policies. Information collected by Metrics Tools may be used on this Site or on other websites or services, including those that may not be operated by us.


We may collect information regarding the effectiveness of our email and other communications with you. For example, we may know if you follow a link in an email we send to you.Mobile. We may collect session and geolocation information from your mobile device. Geolocation information includes data such as your device’s physical location and may include GPS-based, WiFi-based or cell-based location information.

How Does Karmel Use Information About Me?

We and others acting on our behalf may use the information that we collect or receive to operate our business, including our Site, as described below:

Operate and Support our Site and Services.

We use the information that we gather in order to operate our Site and our services. For example, we may use the information that we collect or receive to provide assistance that you request. If you establish user account with us, we may use information about you to manage or support your account. We may identify your use of our Site across devices, and we may use information we collect from you and receive from others to optimize your use of the Site and our services as you use different devices.

Other Contacts.

We may contact you through telephone or email as permitted by law.

When Does Karmel Share Information?

We only share information about you as described or permitted by this Privacy Policy or other governing document, unless you consent to other sharing. If you are an investor in a Karmel fund we may be required to share information about you as further disclosed in the fund’s governing documents and privacy policy.We may share information about you in the following ways: Business Transfer. We may share information we have collected from you in connection with the sale or merger of our business or the transfer of assets.Protection of Ourselves and Others. We may use and share the information we gather to enforce our rights and protect our property and those of our affiliates, customers and members of the public, to comply with applicable law, legal process, legal advice and for preventing fraud, theft, and injury to you, us or others.Service Providers. We may share information with third-party service providers who help us operate our business or provide services on our behalf.

What Choices Do I Have Regarding My Information?

You may limit and control the information provided to us in a number of ways. You may not be able to use all features of our Site if you limit the information you share with us.Your browser and your device may provide you the option to limit the use of cookies or other Metrics Tools. You should consult documentation for your browser or device for more information. Your mobile device may have settings that allow you to prevent sharing geolocation information with us. You should consult your mobile device’s settings or help documentation for more information about exercising these options.Upon request we will remove your personal information from our active database. We will discard your personally identifiable data, but we may retain certain data for internal business purposes, such as analysis of non-personally identifiable data or as may be required by applicable law.

How Can I Access and Update My Information?

Please contact us if you would like to access or update your information.

How does Karmel manage California Residents’ Privacy Rights?

If you are a resident of California, you have certain privacy rights under the California Consumer Privacy Act (“CCPA”). We honor those rights, as described below, and we are prohibited by law from discriminating against you for exercising any of those rights.

A.   Right to Know

Subject to the exemption and exceptions mentioned below, if you are a California resident, you have the right to know what information we have collected about you, why we collected it, and the categories of third parties (excluding service providers) with whom we have shared the information during the past 12 months. (See below on “How to Submit a Request.”) You may request that we provide a description of the categories of information we have collected (a “Categories Request”) or a request for access to the specific pieces of information we have collected (a “Specific Pieces Request”).If you make a Categories Request, we will need to verify your identity to a reasonable degree of certainty. A reasonable degree of certainty may include you providing us with at least two data elements specific to you, so that we can verify your identity. After we confirm that your request is a verifiable consumer request, we will disclose to you:The categories of information we collected about youThe categories of sources for the information we collected about you (e.g., social media websites and government records available to the public)Our business or commercial purpose for collecting that informationThe categories of third parties other than service providers (if any) with whom we shared the informationIf you make a Specific Pieces Request, we’ll need to verify your identity to a reasonably high degree of certainty. In order to verify your identity, a reasonably high degree of certainty may include you providing us at least three data elements specific to you. After we confirm that your request is a verifiable consumer request, we will disclose to you:The specific pieces of information we collected about you that you requested

B.   Right to Request Deletion

You have the right to request that we delete any of your information that we collected from you and retained, other than Personal Customer Information (as defined above). We are not obligated to comply with your request if we have a legal basis to retain the information. If you make a request for us to delete information, and you do not have any type of account with us, we may need you to provide us with at least two data elements specific to you so that we can verify your identity. Once we receive and confirm that your request is a verifiable consumer request (see below on “How to Submit a Request”), we will inform you whether we have deleted (and have directed our service providers to delete) your information from our records, or whether we are declining to grant your request to delete due to an exception to the CCPA deletion requirements.

C.   Exceptions

Certain information is protected by federal and state privacy law other than the CCPA and thus the specific rights described above do not apply in the case of that information. Specifically, if you are, or apply to become, an investor in a Karmel managed fund, the non-public information we obtain from you in that context (“Personal Customer Information”) is protected under other state and federal law rather than the CCPA. Your rights as an investor are governed in the respect fund’s governing documents.  

D.   How to Submit a Request

To request access to or deletion of your information as described above, please submit a verifiable consumer request Clicking here  or contacting at the address detailed below.We cannot respond to your request or provide you with information if we cannot verify your identity or authority to make the request and confirm that the information relates to you.  This may require that you provide additional information following your request.We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 45 additional days), we will inform you of the reason and extension period in writing. We will only use information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Does Karmel Retain Information?

We retain information for as long as necessary to achieve the purpose for which it was collected, to fulfill legal or contractual obligations, or for as long as permitted by applicable law. We may retain aggregated or de-identified information indefinitely.

Does Karmel manage Do Not Track Signals?

Your browser may allow you to send us a “do-not-track signal” to communicate your privacy preferences to us. Our site may or may not respond to browser do-not-track signals.

How Does Karmel Protect the Security of the Personal Information it Collects?

We endeavor to protect the privacy of your account and other personal information we hold in our records. However, no method of information transfer over the Internet is 100% secure and we cannot guarantee the security of your information during its transmission or storage in our systems. We will assume that anyone who has the required login/password information for your account is you, so please keep this information confidential. If you believe that information about you has been subject to unauthorized disclosure, please let us know by contacting us.

How Can Karmel Capital be Contacted Regarding Privacy Issues?

You can contact us with questions or comments about our privacy practices or this Notice by contacting us or you can reach us by mail at:

Karmel Capital Management LLC
512 Via de la Valle, Suite 209
Solana Beach, CA 92075