Privacy Policy

Last updated 06/01/2026

This Privacy Policy applies to Karmel Capital Management LLC, Karmel Capital LLC, all related general partners and partnerships, and all managed funds (collectively "Karmel," "we," "us," or "our"). Investors in a Karmel-managed fund may obtain the privacy policy related to such fund and the investor relationship with Karmel directly from Karmel. This Privacy Policy describes how we collect, use, disclose, retain, and protect personal information when you visit or interact with this website and any related websites, social media sites, or pages managed by Karmel (collectively, the "Site").

The Site is not directed to children under the age of 13, and we do not knowingly collect personal information from children under age 13. This Privacy Policy does not apply to anonymized, aggregated, or de-identified information that does not identify and cannot reasonably be linked to an individual. Third-party websites and services linked from the Site may have their own privacy policies, and their practices are not governed by this Privacy Policy.

Personal Information We Collect

Information you provide. We may collect information that you provide to us, including your name, email address, company, phone number, message content, investor or prospective investor information, and any other information you choose to provide when you contact us, request information, submit a form, or otherwise communicate with us.

Automatically collected information. We may collect information automatically when you use the Site, including your IP address, browser type, device type, operating system, identifiers associated with your device, pages viewed, referring and exit pages, dates and times of visits, and information about how you interact with the Site.

Cookies and similar technologies. We may use cookies, pixels, web beacons, analytics tools, and similar technologies (collectively, "Metrics Tools") to operate the Site, understand usage, improve performance, and measure communications. You can set your browser to refuse some cookies or alert you when cookies are being sent, although some parts of the Site may not function properly without them.

Email and communications data. We may collect information regarding the effectiveness of our email and other communications, such as whether you open a message or click a link.

Sensitive personal information. We do not intentionally collect sensitive personal information through the public Site. Please do not submit Social Security numbers, account credentials, government identification numbers, health information, or other sensitive information through public website forms or email unless specifically requested through a secure channel.

How We Use Personal Information

We may use personal information to operate, maintain, and improve the Site; respond to inquiries; provide information you request; manage investor, prospective investor, vendor, and business relationships; evaluate and process potential business or investment opportunities; comply with legal, regulatory, contractual, and compliance obligations; protect our rights, property, users, and others; prevent fraud, security incidents, or misuse; and conduct internal business analytics and administration.

How We Disclose Personal Information

We may disclose personal information as described in this Privacy Policy, in applicable fund documents, or as otherwise permitted by law, including to service providers and professional advisers who support our business; affiliates and related entities; regulators, law enforcement, courts, or other parties when required or permitted by law; parties involved in a business transaction such as a merger, financing, reorganization, or asset transfer; and other parties with your consent or at your direction.

If you are an investor in, or apply to invest in, a Karmel-managed fund, we may collect and disclose nonpublic personal information as described in applicable fund governing documents, subscription materials, privacy notices, and as permitted or required by federal and state financial privacy laws. To the extent those laws apply, those notices and documents may govern in addition to, or instead of, portions of this Privacy Policy.

California Privacy Notice

This section applies to California residents and supplements the rest of this Privacy Policy. California law, including the California Consumer Privacy Act as amended by the California Privacy Rights Act ("CCPA"), may provide California residents with rights regarding personal information, subject to applicable exemptions and limitations. Certain information we collect in connection with investor relationships may be exempt from some CCPA requirements because it is governed by federal or state financial privacy laws.

In the preceding 12 months, we may have collected the following categories of personal information: identifiers such as name, email address, IP address, and contact information; customer records information such as business contact details and investor-related information; commercial or professional information such as company, role, investment interest, or transaction-related details; internet or other electronic network activity information such as Site usage and device information; geolocation information derived from IP address; and inferences drawn from the information above for business purposes. We collect this information from you, your devices, service providers, affiliates, business partners, publicly available sources, and other parties that provide information to us.

We use these categories of personal information for the business and commercial purposes described in this Privacy Policy. We may disclose these categories to service providers, contractors, professional advisers, affiliates, regulators, transaction counterparties, and other parties described above. We retain personal information for as long as reasonably necessary for the purposes described in this Privacy Policy, including to meet legal, regulatory, accounting, reporting, and recordkeeping obligations.

We do not sell personal information for money. We also do not knowingly sell or share personal information of individuals under 16. To the extent any use of third-party analytics or advertising technologies is considered a "sale" or "sharing" under California law, you may contact us using the information below to opt out or use a legally recognized browser-based opt-out preference signal where required. We do not use or disclose sensitive personal information for purposes that would require a right to limit under the CCPA.

Subject to applicable exemptions, California residents may have the right to request access to personal information, receive information about our collection and disclosure practices, request correction of inaccurate personal information, request deletion of personal information, opt out of the sale or sharing of personal information, limit certain uses of sensitive personal information where applicable, and not be discriminated against for exercising privacy rights.

To submit a California privacy request, contact us using the information in the "Contact Us" section below. We may need to verify your identity and authority before fulfilling a request, and we will use information provided in connection with a request only to verify and respond to that request. You may authorize an agent to submit a request on your behalf where permitted by law.

California residents may also request information regarding certain disclosures of personal information to third parties for their direct marketing purposes, if applicable. Karmel does not currently disclose personal information to third parties for their own direct marketing purposes.

European Economic Area, United Kingdom, and Switzerland Privacy Rights

If you are located in the European Economic Area, the United Kingdom, or Switzerland, applicable data protection laws, including the General Data Protection Regulation ("GDPR") and UK GDPR, may provide you with additional rights. Karmel is the controller of personal information processed through the Site unless otherwise stated.

Our legal bases for processing personal information may include your consent; performance of a contract or steps taken at your request before entering a contract; compliance with legal or regulatory obligations; and our legitimate interests, including operating the Site, communicating with you, administering our business, evaluating business and investment opportunities, protecting our rights and systems, and complying with fund, adviser, and financial services obligations.

Depending on your location and subject to applicable limitations, you may have the right to request access to, correction of, deletion of, or portability of your personal information; object to or restrict certain processing; withdraw consent where processing is based on consent; and lodge a complaint with a supervisory authority. Where processing is based on legitimate interests, you may object to that processing as permitted by law. To exercise these rights, contact us using the information below.

We are based in the United States, and personal information may be processed in the United States and other jurisdictions that may not provide the same level of data protection as your home jurisdiction. Where required, we rely on appropriate safeguards or lawful transfer mechanisms for international transfers, which may include contractual, regulatory, or other safeguards recognized under applicable law.

Retention

We retain personal information for as long as reasonably necessary to fulfill the purposes for which it was collected, to comply with legal, regulatory, contractual, accounting, reporting, and recordkeeping obligations, to resolve disputes, and to enforce agreements. We may retain aggregated, anonymized, or de-identified information indefinitely.

Do Not Track and Global Privacy Signals

Some browsers may transmit "Do Not Track" signals. Because there is not a uniform industry standard for such signals, the Site may not respond to them. Where required by applicable law, we will honor legally recognized opt-out preference signals, such as Global Privacy Control, for the browser or device that sends the signal.

Security

We use reasonable administrative, technical, and physical safeguards designed to protect personal information. However, no method of transmission over the Internet or method of electronic storage is completely secure, and we cannot guarantee absolute security.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time. The "Last updated" date above indicates when it was last revised. Your continued use of the Site after an update means you acknowledge the revised Privacy Policy.

Contact Us

You can contact us with questions, comments, or privacy rights requests by emailing ir@karmelcap.com, calling 858.208.3636, or by mail at:

Karmel Capital Management LLC
512 Via de la Valle, Suite 207
Solana Beach, CA 92075