PRIVACY POLICY

Emerald Creek Capital, LLC

Effective Date: April 30, 2026 | Last Updated: April 30, 2026

1. Introduction

Emerald Creek Capital, LLC (“ECC,” “we,” “us,” or “our”) is committed to protecting the privacy and security of the personal information we collect. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website (www.emeraldcreekcapital.com), use our contact or inquiry forms, or otherwise interact with our services.

Please read this policy carefully to understand our policies and practices regarding your information and how we treat it. By using our website or providing your personal information to us, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with the practices described herein, please do not use our website or services.

We do not warrant the accuracy, completeness, or usefulness of information obtained though our website. To the fullest extent permitted by applicable law, (a) any reliance you place on such information is strictly at your own risk; and (b) we disclaim all liability and responsibility arising from any reliance placed on such materials (i) by you or any other visitor of our website, or (ii) by anyone who may be informed of any of its contents.

2. Information We Collect

2.1 Information You Provide Directly

We collect personal information that you voluntarily provide to us, including:

Contact and Inquiry Forms: Name, email address, phone number, and the content of your message or inquiry.

Communications: Records of correspondence when you contact us by email, phone, or through our website.

2.2 Information Collected Automatically

When you visit our website, we automatically collect certain information through cookies and similar tracking technologies, including:

Device and Browser Data: IP address, browser type and version, operating system, device identifiers, screen resolution, and language preferences.

Usage Data: Pages visited, links clicked, time spent on pages, referring URL, and navigation paths through our website.

Location Data: Approximate geographic location inferred from your IP address.
Cookie and Tracking Data: Information collected through cookies, pixel tags, web beacons, and similar technologies (see Section 5 for details).

3. How We Use Your Information

We use the personal information we collect for the following business purposes:

Business Services: Processing and responding to inquiries submitted through our website.
Communications: Responding to your inquiries, sending transactional communications, and providing customer support.
Marketing: Sending promotional materials about our products and services through organic channels such as email and social media (with your consent where required).
Analytics and Improvement: Analyzing website usage patterns, improving our website and services, and conducting market research.
Legal and Compliance: Complying with applicable laws and regulations, enforcing our terms and conditions, and protecting our legal rights.
Security: Detecting, investigating, and preventing security incidents and unauthorized access to our systems.

4. How We Share Your Information

ECC does not sell your personal information. However, we may share your personal information in the following circumstances:

4.1 Service Providers

We share personal information with third-party vendors and service providers who perform services on our behalf, such as cloud hosting providers, email delivery services, and analytics providers. These service providers are contractually obligated to use your information only for the purposes for which it was disclosed and to maintain its confidentiality.

4.2 Sharing with Analytics and Marketing Partners

Under certain laws, certain disclosures of personal information may constitute “sharing” of personal information. When you interact with our website, data collected through cookies and tracking technologies—including identifiers, browsing behavior, and interaction data—may be transmitted to third-party analytics and marketing partners such as Google Analytics, LinkedIn, HubSpot and YouTube. These partners may use this data to analyze website traffic, measure the effectiveness of our organic marketing efforts, and improve our outreach. You may opt out of this sharing through our cookie consent banner or by submitting a request as described in Section 9.

4.3 Legal Obligations and Protection of Rights

We may disclose your information where required by law, regulation, legal process, or governmental request, or where we believe disclosure is necessary to protect our rights, your safety, or the safety of others, investigate fraud, or respond to a government request.

5. Cookies and Tracking Technologies

5.1 Cookie Consent Banner

When you first visit our website, you will be presented with a cookie consent banner that allows you to accept or decline non-essential cookies. Necessary cookies are always active because they are required for the basic functioning of our website. All other cookies are only activated after you provide your affirmative consent through the banner.

You may change your cookie preferences at any time. If you decline non-essential cookies, certain features of our website may not function as intended.

5.2 Categories of Cookies

Our website uses the following categories of cookies:

Category	Description	Required?
Necessary	Necessary cookies are required to enable the basic features of this site, such as consent preference management. These cookies may include online identifiers used solely to provide core site functionality and are not used for advertising, analytics, or cross site tracking. The website cannot function properly without these cookies.	Yes
Preferences	Preference cookies enable a website to remember information that affects how the website behaves or appears, such as your preferred language or region. These cookies are not strictly necessary for the website to function and are only used with your consent.	No
Statistics	Statistic cookies help website owners understand how visitors interact with the website by collecting and reporting information in aggregated form.	No
Marketing	Marketing cookies are used to track visitors across websites and enable the display of targeted advertising based on browsing activity, making advertisements more relevant to users and more valuable to publishers and third party advertisers.	No
Unclassified	Unclassified cookies are cookies that are in the process of being classified. These cookies will not be used unless and until they are properly classified and, where required, you have provided consent.	No

5.3 Third-Party Tracking Technologies

Our website integrates the following third-party services that may set cookies or use similar tracking technologies:

Google Analytics (GA4): Collects anonymized usage data to help us understand how visitors interact with our site. Google may process this data on servers in the United States.
LinkedIn: Provides analytics on how visitors from LinkedIn interact with our website, helping us understand the effectiveness of our organic LinkedIn presence. This tag may collect data about your browsing behavior on our site.
HubSpot: Provides marketing automation, lead tracking, and analytics. HubSpot cookies track your interactions with our website and marketing emails to help us personalize communications.
YouTube: Our website embeds video content hosted on YouTube (a Google service). When you view a page containing an embedded YouTube video, YouTube may set cookies and collect data about your interaction with the video, including your IP address and viewing behavior. YouTube’s data practices are governed by Google’s Privacy Policy.

5.4 Do Not Track Signals

Some browsers include a “Do Not Track” (DNT) feature that signals to websites that you do not want your online activity tracked. Our website currently responds to DNT signals by disabling non-essential tracking when such signals are detected. However, because there is no uniform standard for DNT compliance, we also recommend using our cookie consent banner to manage your tracking preferences.

6. Tracking Compliance

Certain laws prohibit the interception or recording of confidential communications without the consent of all parties. In the context of our website:

Consent-Based Tracking: All non-essential cookies and tracking technologies on our website are only activated after you provide explicit consent through our cookie consent banner. No tracking, recording, or monitoring of your browsing activity occurs prior to your consent (except for strictly necessary cookies required for website operation).
Transparency: This Privacy Policy and our cookie consent banner clearly disclose the types of data collected by each tracking technology, the purposes for which such data is used, and the third parties that may receive this data.
No Wiretapping: ECC does not use session replay tools, keystroke loggers, or any technology that records your real-time communications or keystrokes on our website.

By providing your consent through our cookie consent banner, you are expressly consenting to the collection of data through the tracking technologies described in this policy, in accordance with applicable law.

7. Data Retention

We retain your personal information only for as long as is necessary to fulfill the purposes for which it was collected, including to satisfy legal, regulatory, accounting, or reporting requirements. Specific retention periods include:

Inquiry and Contact Data: Retained for as long as reasonably necessary to fulfill the purpose for which it was collected, including for business, legal, or compliance purposes.
Cookie and Analytics Data: Retained in accordance with the retention settings of each third-party service (typically 14 to 26 months for analytics data).
Marketing Data: Retained until you opt out of marketing communications or request deletion.

8. Data Security

We implement reasonable administrative, technical, and physical safeguards designed to protect your personal information from unauthorized access, use, alteration, and destruction. These measures include encryption of sensitive data in transit and at rest, access controls, regular security assessments, and employee training on data protection practices.

However, no method of transmission over the Internet or electronic storage is completely secure. While we strive to protect your personal information, we cannot guarantee its absolute security. To the fullest extent allowed by law, any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on our services.

The safety and security of your information also depends on you. We urge you to be careful about giving out information in public areas. The information you share in public areas may be viewed by the public. You are responsible for maintaining the confidentiality of any account credentials and for notifying us immediately if you suspect unauthorized access to your account. Please limit the information you provide to us in connection with your use of our website.

9. Your Privacy Choices and Rights

Depending on your jurisdiction, you may have certain privacy rights under applicable law. We will honor such rights to the extent required by applicable law and/or regulations and subject to certain limitations.

9.1 Right to Know (Access)

You may have the right to request that we disclose the categories and specific pieces of personal information we have collected about you, the categories of sources from which your information was collected, the business or commercial purposes for collection, and the categories of third parties with whom we share your information.

9.2 Right to Delete

You have the right to request deletion of your personal information, subject to certain exceptions (such as when the information is necessary to complete a transaction, detect security incidents, or comply with legal obligations).

9.3 Right to Correct

You have the right to request that we correct inaccurate personal information that we maintain about you.

9.4 Right to Opt Out

You may have the right to opt out of the “sharing” of your personal information with third-party analytics and marketing partners. You may exercise this right by adjusting your preferences through our cookie consent banner, which is available on every page of our website, or submitting a request using the contact methods in Section 11.

9.5 Right to Non-Discrimination

We will not discriminate against an individual for exercising any of their applicable rights. We will not deny such individuals services, charge different prices, provide a different quality of service, or suggest that such individual will receive a different level of service for exercising their rights.

9.6 How to Submit a Request

To exercise any of your rights, as applicable, you or your authorized agent may submit a verifiable consumer request by:

Email: info@emeraldcreekcapital.com
Website: Visiting the “Privacy Policy” page on www.emeraldcreekcapital.com

We will verify your identity before processing your request. This may require providing information that matches our records. We will respond to your request within 45 days of receipt, with the possibility of a 45-day extension if reasonably necessary (with prior notice to you).

9.7 Appeals

Certain jurisdictions require that, if we decline to take action regarding your request, you may appeal our decision by emailing us. We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may submit a complaint to your state attorney general.

9.8 State-Specific Disclosures

California ”Shine The Light” Law: California Civil Code Section 1798.83, also known as the ”Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us.

10. Children’s Privacy

Our website and services are not directed to individuals under the age of 18. We do not knowingly collect personal information from children. If we become aware that we have inadvertently collected personal information from a child under 18, we will take steps to delete that information promptly. If you believe a child has provided us with personal information, please contact us at the address below.

11. Contact Us

If you have any questions or concerns about this Privacy Policy, our data practices, or wish to exercise your privacy rights, please contact us:

Company	Emerald Creek Capital, LLC
Email	info@emeraldcreekcapital.com
Website	www.emeraldcreekcapital.com
Attention	Compliance Department

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other factors. When we make material changes, we will update the “Last Updated” date at the top of this policy and, where appropriate, provide additional notice (such as a prominent notice on our website or an email notification).

We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your information.