Privacy Policy

Overview

Cabochon Capital, LLC ("Cabochon Capital," "we," "us," or "our") is a Wyoming limited liability company that respects the privacy of visitors to cabochoncapital.com (the "Website"). This Privacy Policy describes how we collect, use, and protect information obtained through the Website.

This Website is not directed to retail consumers. By accessing the Website, you represent that you are an institutional investor, qualified purchaser, or accredited investor as defined under applicable U.S. securities laws.

Information We Collect

We may collect the following types of information when you access the Website or submit a contact inquiry:

• Contact information — name, organization, professional email address, and any message content you submit voluntarily
• Investor classification — your represented investor status when provided
• Usage data — standard server logs including IP address, browser type, referring URLs, and pages visited
• Cookie data — session cookies used for website functionality (see Cookie Policy below)

We do not collect sensitive personal information such as Social Security numbers, financial account details, or government identification numbers through this Website.

How We Use Information

Information collected through this Website is used solely for the following purposes:

• To respond to your inquiry and evaluate whether a relationship may be appropriate
• To maintain the security and operation of the Website
• To comply with applicable legal and regulatory obligations
• To enforce our Terms of Use

We do not sell, rent, or otherwise transfer your personal information to third parties for marketing purposes.

Disclosure to Third Parties

We may disclose information in the following limited circumstances:

• Service providers — third-party vendors who assist in website hosting, security, and operations, under confidentiality obligations
• Legal compliance — when required by law, regulation, or valid legal process
• Business transfers — in connection with a merger, acquisition, or sale of assets, subject to standard confidentiality protections

Cookie Policy

This Website uses a limited number of cookies strictly necessary for website functionality, including maintaining your acknowledgment of the required investor disclosure. We do not use advertising or behavioral tracking cookies.

Our website infrastructure is provided by Cloudflare, Inc. As part of standard website security and performance operations, Cloudflare may set cookies on your device for security verification and traffic management purposes. These cookies are set by Cloudflare independently of Cabochon Capital and are governed by Cloudflare's own privacy practices.

You may disable cookies in your browser settings; however, doing so may affect the functionality of certain website features.

Data Security

We implement reasonable administrative, technical, and physical safeguards to protect information collected through this Website against unauthorized access, disclosure, alteration, or destruction. However, no internet transmission is completely secure, and we cannot guarantee absolute security.

Data Retention

We retain contact inquiry information for as long as reasonably necessary to evaluate the inquiry and comply with applicable legal obligations, typically no longer than three years absent an ongoing business relationship or regulatory requirement.

Your Rights

Depending on your jurisdiction, you may have rights to access, correct, or delete personal information we hold about you. To exercise such rights or to ask questions about our privacy practices, please contact us at the address below.

Changes to This Policy

We reserve the right to modify this Privacy Policy at any time. Changes will be reflected by updating the effective date above. Continued access to the Website constitutes acceptance of any revised policy.

Contact

Privacy inquiries and requests may be directed to: