Privacy Policy

Privacy Policy

Larnach Capital LLC

Effective Date: August 2026 | Last Updated: August 2026

1. Introduction

Larnach Capital LLC ("Larnach Capital," "we," "us," or "our") respects your privacy and is committed to protecting the personal information of visitors to our website located at www.larnachcapital.com (the "Site") and of individuals who interact with us in connection with our capital raising, real estate, and alternative asset advisory activities.

This Privacy Policy explains what information we collect, how we use and share it, and the choices available to you. By using the Site or providing information to us, you agree to the terms of this Privacy Policy.

This Privacy Policy does not apply to information you provide directly within formal offering documents (such as subscription agreements, private placement memoranda, or investor questionnaires) for a specific investment vehicle. That information is governed by the confidentiality and privacy terms contained in those offering documents.

2. Information We Collect

a) Information You Provide to Us

• Contact information (name, email address, phone number, mailing address)
• Information submitted through contact forms, webinar registrations, or "request information" forms
• Investor accreditation-related information, if voluntarily submitted in connection with expressing interest in an investment opportunity
• Communications you send to us, including emails and messages

b) Information Collected Automatically

• IP address, browser type, device information, and operating system
• Pages visited, time spent on pages, referring URLs, and general usage patterns
• Cookies and similar tracking technologies (see Section 5 below)

c) Information from Third Parties

We may receive information about you from third parties, such as:

• Due diligence, accreditation verification, or KYC/AML service providers
• Co-sponsors, fund administrators, or operating partners on a specific deal
• Publicly available sources, where relevant to evaluating an investment opportunity

3. How We Use Your Information

We use the information we collect to:

• Respond to inquiries and provide requested information about investment opportunities
• Evaluate prospective investor eligibility and accreditation status
• Communicate with you about webinars, market updates, or new offerings (where you have opted in)
• Operate, maintain, and improve the Site
• Comply with applicable securities laws, including Regulation D requirements, and other legal or regulatory obligations
• Prevent fraud and protect the security of our systems and communications
• Fulfill our contractual obligations to investors and business partners

4. How We Share Your Information

We do not sell your personal information. We may share information with:

• Service providers who perform functions on our behalf (e.g., fund administrators, CPAs and accountants, legal counsel, IT and hosting providers, email/CRM platforms we use to manage and send our own communications, accreditation verification services), under confidentiality obligations
• Co-sponsors and operating partners on a specific deal, where necessary to evaluate or process an investment
• Regulators and government authorities, where required by law or in connection with a regulatory inquiry
• Successors, in the event of a merger, acquisition, or sale of business assets
• Professional advisors, such as our own attorneys or auditors, as needed
• Our website hosting and infrastructure provider, which processes certain data (such as form submissions, site analytics, and hosting logs) on our behalf to operate the Site

We may also share information with your consent or at your direction.

Note on mobile/text messaging information: The categories above describe our general data-sharing practices and do not apply to mobile phone numbers or SMS opt-in consent collected through our text messaging program. That information is subject to the stricter, separate non-sharing commitment described in Section 6 below, and is never shared with any third party for marketing, lead generation, or analytics purposes.

5. Cookies and Tracking Technologies

The Site places certain cookies that are necessary for the Site to function (e.g., session management, security, and load balancing) and may also use cookies for analytics purposes on our behalf to recognize your browser and understand how the Site is used.

You can review and manage cookie preferences through your browser settings; disabling cookies may affect certain Site functionality. We do not currently use cookies to serve targeted third-party advertising.

6. Text Messaging (SMS/RCS) Privacy Practices

Larnach Capital LLC sends SMS messages to individuals who have opted in through a widget on our website and who have an existing, substantive relationship with the firm as prospective or current real estate investment partners. When you opt in, we collect your mobile phone number and your consent status in order to send those messages.

Types of messages you may receive:

• Promotional/Marketing messages — e.g., invitations to investor webinars, deal-related opportunity updates, and personal outreach from Larnach Capital principals regarding specific investment opportunities
• Transactional/Informational messages — e.g., webinar and event reminders, scheduling confirmations, and one-to-one conversational replies from firm principals responding to your questions or requests

Consent to one message type is not a condition of receiving the other, and you may opt in or out of each independently. Message frequency is occasional and tied to specific investment opportunities or scheduled events — we do not send messages on a recurring or high-volume basis.

• No third-party sharing: Text messaging originator opt-in data and consent will not be shared with any third parties, excluding aggregators and providers of the text message services themselves (i.e., the vendors we use to technically deliver the messages). This mobile information will never be shared with third parties or affiliates for marketing, lead generation, or third-party analytics purposes under any circumstances.
• Use of information: We use the information collected through our messaging program solely to send you the informational and promotional messages you've opted in to receive, and to manage your consent and opt-out status. Message and data rates may apply, and message frequency varies.
• Consent: By opting in through our website widget, which discloses our messaging intent and provides opt-out instructions, you consent to the collection, use, and disclosure of your information as described in this section.
• Opt-out: You may opt out of text messages at any time by texting STOP. For help, reply HELP.

This section supplements, and should be read together with, the SMS/RCS disclosures on our Disclaimer page, which also govern the specific messaging terms and conditions for our text program.

7. Data Security

We use reasonable administrative, technical, and physical safeguards designed to protect personal information from unauthorized access, use, or disclosure. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

8. Data Retention

We retain personal information for as long as necessary to fulfill the purposes described in this Privacy Policy, including to satisfy legal, accounting, regulatory, or reporting obligations (which, for investor-related records, may extend for several years following the conclusion of an investment relationship, consistent with applicable securities recordkeeping requirements).

9. Your Choices and Rights

• You may opt out of marketing communications at any time by using the unsubscribe link in our emails or contacting us directly.
• Depending on your state of residence, you may have additional rights regarding your personal information, such as the right to request access to, correction of, or deletion of certain information we hold about you. To make such a request, contact us using the information in Section 14.
• We will not discriminate against you for exercising any privacy rights available to you under applicable law.

10. Third-Party Links

The Site may contain links to third-party websites. We are not responsible for the privacy practices or content of those sites. We encourage you to review the privacy policies of any third-party site you visit.

11. Children's Privacy

The Site is not directed to individuals under 18, and we do not knowingly collect personal information from children. If you believe a child has provided us with personal information, please contact us so we can delete it.

12. International Visitors

The Site is intended for visitors located in the United States. If you access the Site from outside the United States, your information will be transferred to and processed in the United States.

13. Changes to This Policy

We may update this Privacy Policy from time to time. The "Last Updated" date at the top of this page reflects the most recent revision. Material changes will be posted on this page or communicated to you directly where appropriate.

14. Contact Us

Please contact us through our Contact page.