Privacy

This privacy policy is written to cover the website located at https://www.zenithcapital.partners only. It is not intended to cover the Zenith Capital Capital Access investment portal. Information about the privacy policy for the investment portal can be accessed via the portal itself.

TL;DR - Personal Data

This website does not collect personal data, except when users knowingly send us a message using the contact form. At that time, we capture and store only the information you provide to us in the form. That information is only accessed by our staff and is not shared with any 3rd parties.

TL;DR - Cookies

This website does not employ cookies directly. It does use some 3rd party websites that may employ cookies for functional purposes. They are: Cloudinary (CDN), Jotform (contact form), and Google Recaptcha (contact form security), Sentry.io (error monitoring). Our analytics provider is Plausible.io which does not use cookies.

TL;DR - Privacy Summary

As a visitor to this website, you can expect the following:

• No personal information is collected
• No personally identifiable information is shared with, sent to or sold to third-parties
• No information is shared with advertising companies
• No information is mined and harvested for personal and behavioral trends
• No information is monetized

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

Business

for the purpose of the CCPA (California Consumer Privacy Act), refers to the Company as the legal entity that collects Consumers' personal information and determines the purposes and means of the processing of Consumers' personal information, or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers' personal information, that does business in the State of California.

Company

(referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to Zenith Capital Partners, LLC 1061 E Indiantown Road, Suite 318, Jupiter, FL 33477

For the purpose of the GDPR, the Company is the Data Controller.

Consumer

for the purpose of the CCPA (California Consumer Privacy Act), means a natural person who is a California resident. A resident, as defined in the law, includes (1) every individual who is in the USA for other than a temporary or transitory purpose, and (2) every individual who is domiciled in the USA who is outside the USA for a temporary or transitory purpose.

Cookies

are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.

Country

refers to: Florida, United States

Data Controller

for the purposes of the GDPR (General Data Protection Regulation), refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.

Device

means any device that can access the website such as a computer, a cellphone or a digital tablet.

Personal Data

is any information that relates to an identified or identifiable individual.

For the purposes for GDPR, Personal Data means any information relating to You such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity.

For the purposes of the CCPA, Personal Data means any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with You.

Sale

for the purpose of the CCPA (California Consumer Privacy Act), means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer's personal information to another business or a third party for monetary or other valuable consideration.

Service Provider

means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the website, to provide the website on behalf of the Company, to perform websites related to the website or to assist the Company in analyzing how the website is used.

For the purpose of the GDPR, website Providers are considered Data Processors.

Usage Data

refers to data collected automatically, either generated by the use of the website or from the website infrastructure itself (for example, the duration of a page visit).

Website

refers to the Zenith Capital Partners website, accessible from https://www.zenithcapital.partners

You

means the individual accessing or using the website, or the company, or other legal entity on behalf of which such individual is accessing or using the website, as applicable.

Under GDPR (General Data Protection Regulation), You can be referred to as the Data Subject or as the User as you are the individual using the website.

Collecting and Using Your Personal Data

Types of Data Collected

Your Personal Data

When completing the contact form we may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

• Email address
• First name and last name
• Phone number
• Usage Data

Your Usage Data

Some Usage Data may be collected automatically when using the website.

Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our website that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When You access the website by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit our website or when You access the website by or through a mobile device.

Tracking Technologies and Cookies

We or our 3rd party technology providers may use Cookies and similar tracking technologies to track the activity on Our website and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our website. The technologies We use may include:

Cookies or Browser Cookies

A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent.

Web Beacons

Certain sections of our website and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).

Session storage and Persistent Cookies may be used for the purposes set out below:

Necessary / Essential Cookies

Type: Session Cookies

Administered by: Us

This website does not directly employ cookies. The only cookies used on this site will be ones administered by third parties as outlined below.

Functionality Cookies

Type: Persistent Cookies

Administered by: Us

This website does not directly employ cookies. The only cookies used on this site will be ones administered by third parties as outlined below.

Tracking and Performance Cookies

Type: Persistent Cookies

Administered by: Third-Parties

Purpose: These Cookies are used to track information about traffic to the Website and how users use the Website. The information gathered via these Cookies may directly or indirectly identify you as an individual visitor. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access the Website.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

To contact You

To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication -- this applies only to users who have submitted a message to us using the contact form. We do not collect email addresses or phone numbers from users who have not submitted a message to us.

To manage Your requests

To attend and manage Your requests to Us.

We may share Your personal information in the following situations:

For business transfers

We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our website, or We are legally obligated to retain this data for longer time periods.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other legal requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

• Comply with a legal obligation
• Protect and defend the rights or property of the Company
• Prevent or investigate possible wrongdoing in connection with the website
• Protect the personal safety of Users of the website or the public
• Protect against legal liability

Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

Detailed Information on the Processing of Your Personal Data

The website Providers We use may have access to Your Personal Data. These third-party vendors collect, store, use, process and transfer information about Your activity on Our website in accordance with their Privacy Policies.

Analytics

We may use third-party website providers to monitor and analyze the use of our website.

Plausible Analytics

Even though the purpose of Plausible Analytics is to track the usage of a website, this can still be done without collecting any personal data or personally identifiable information (PII), without using cookies and while respecting the privacy of your website visitors.

By using Plausible Analytics, all the site measurement is carried out absolutely anonymously. Cookies are not set and no personal data is collected. All data is in aggregate only. The website owner gets some actionable data to help them learn and improve, while the visitor keeps having a nice and enjoyable experience. For more information on the privacy practices and data policies of Plausible Analytics, please visit the Plausible website:https://plausible.io/data-policy

Usage, Performance and Miscellaneous

We may use third-party website Providers to provide better improvement of our website.

Invisible reCAPTCHA

We use an invisible captcha website named reCAPTCHA. reCAPTCHA is operated by Google.

The reCAPTCHA website may collect information from You and from Your Device for security purposes.

The information gathered by reCAPTCHA is held in accordance with the Privacy Policy of Google:https://www.google.com/intl/en/policies/privacy/

GDPR Privacy

Legal Basis for Processing Personal Data under GDPR

We may process Personal Data under the following conditions:

Consent

You have given Your consent for processing Personal Data for one or more specific purposes.

Performance of a contract

Provision of Personal Data is necessary for the performance of an agreement with You and/or for any pre-contractual obligations thereof.

Legal obligations

Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.

Vital interests

Processing Personal Data is necessary in order to protect Your vital interests or of another natural person.

Public interests

Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Company.

Legitimate interests

Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.

In any case, the Company will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Your Rights under the GDPR

The Company undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights.

You have the right under this Privacy Policy, and by law if You are within the EU, to:

Request access to Your Personal Data

The right to access, update or delete the information We have on You. Whenever made possible, you can access, update or request deletion of Your Personal Data directly within Your account settings section. If you are unable to perform these actions yourself, please contact Us to assist You. This also enables You to receive a copy of the Personal Data We hold about You.

Request correction of the Personal Data that We hold about You

You have the right to have any incomplete or inaccurate information We hold about You corrected.

Object to processing of Your Personal Data

This right exists where We are relying on a legitimate interest as the legal basis for Our processing and there is something about Your particular situation, which makes You want to object to our processing of Your Personal Data on this ground. You also have the right to object where We are processing Your Personal Data for direct marketing purposes.

Request erasure of Your Personal Data

You have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it.

Request the transfer of Your Personal Data

We will provide to You, or to a third-party You have chosen, Your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which You initially provided consent for Us to use or where We used the information to perform a contract with You.

Withdraw Your consent

You have the right to withdraw Your consent on using your Personal Data. If You withdraw Your consent, We may not be able to provide You with access to certain specific functionalities of the website.

Exercising of Your GDPR Data Protection Rights

You may exercise Your rights of access, rectification, cancellation and opposition by contacting Us. Please note that we may ask You to verify Your identity before responding to such requests. If You make a request, We will try our best to respond to You as soon as possible.

You have the right to complain to a Data Protection Authority about Our collection and use of Your Personal Data. For more information, if You are in the European Economic Area (EEA), please contact Your local data protection authority in the EEA.

CCPA Privacy

This privacy notice section for California residents supplements the information contained in Our Privacy Policy and it applies solely to all visitors, users, and others who reside in the State of California.

Categories of Personal Information Collected

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer or Device. The following is a list of categories of personal information which we may collect or may have been collected from California residents within the last twelve (12) months.

Please note that the categories and examples provided in the list below are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact collected by Us, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been collected. For example, certain categories of personal information would only be collected if You provided such personal information directly to Us.

Category A: Identifiers

Examples: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver's license number, passport number, or other similar identifiers.

Collected: Yes. Collection is limited to name, email, and telephone number, or any additional information you provide to us via the contact form.

Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))

Examples: A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.

Collected: Collection is limited to name, email, and telephone number, or any additional information you provide to us via the contact form.

Category C: Protected classification characteristics under California or federal law

Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

Collected: No.

Category D: Commercial information

Examples: Records and history of products or websites purchased or considered.

Collected: No.

Category E: Biometric information

Examples: Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

Collected: No.

Category F: Internet or other similar network activity

Examples: Interaction with our website or advertisement.

Collected: No.

Category G: Geolocation data

Examples: Approximate physical location.

Collected: No.

Category H: Sensory data

Examples: Audio, electronic, visual, thermal, olfactory, or similar information.

Collected: No.

Category I: Professional or employment-related information

Examples: Current or past job history or performance evaluations.

Collected: No.

Category J: Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))

Examples: Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

Collected: No.

Category K: Inferences drawn from other personal information

Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Collected: No.

Under CCPA, personal information does not include:

• Publicly available information from government records
• De-identified or aggregated consumer information
• Information excluded from the CCPA's scope, such as:
• Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data
• Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994

Sources of Personal Information

We obtain the categories of personal information listed above from the following categories of sources:

Directly from You

For example, from the forms You complete on our website, preferences You express or provide through our web contact form.

Automatically from You

For example, through cookies We or our website Providers set on Your Device as You navigate through our website.

From website Providers

For example, when you submit the contact form on this website, your message is first sent to Jotform servers, before it is sent to us.

Use of Personal Information for Business Purposes or Commercial Purposes

We may use or disclose personal information We collect for"business purposes" or"commercial purposes" (as defined under the CCPA), which may include the following examples:

• To operate our website and provide You with our website.
• To provide You with support and to respond to Your inquiries, including to investigate and address Your concerns and monitor and improve our website.
• To fulfill or meet the reason You provided the information. For example, if You share Your contact information to ask a question about our website, We will use that personal information to respond to Your inquiry.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to You when collecting Your personal information or as otherwise set forth in the CCPA.
• For internal administrative and auditing purposes.
• To detect security incidents and protect against malicious, deceptive, fraudulent or illegal activity, including, when necessary, to prosecute those responsible for such activities.

Please note that the examples provided above are illustrative and not intended to be exhaustive. For more details on how we use this information, please refer to the"Use of Your Personal Data" section.

If We decide to collect additional categories of personal information or use the personal information We collected for materially different, unrelated, or incompatible purposes We will update this Privacy Policy.

Disclosure of Personal Information for Business Purposes or Commercial Purposes

We may use or disclose and may have used or disclosed in the last twelve (12) months the following categories of personal information for business or commercial purposes:

Category A

Identifiers

Category B

Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))

Category F

Internet or other similar network activity

Please note that the categories listed above are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact disclosed, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been disclosed.

When We disclose personal information for a business purpose or a commercial purpose, We enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

Sale of Personal Information

We do not sell personal information received through this website.

Share of Personal Information

We do not share personal information received through this website.

Sale of Personal Information of Minors Under 16 Years of Age

We do not knowingly collect personal information from minors under the age of 16 through our website, although certain third party websites that we link to may do so. These third-party websites have their own terms of use and privacy policies and we encourage parents and legal guardians to monitor their children's Internet usage and instruct their children to never provide information on other websites without their permission.

We do not sell the personal information of Consumers at anytime ever.

If You have reason to believe that a child under the age of 13 (or 16) has provided Us with personal information, please contact Us with sufficient detail to enable Us to delete that information.

Your Rights under the CCPA

The CCPA provides California residents with specific rights regarding their personal information. If You are a resident of California, You have the following rights:

The right to notice

You have the right to be notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.

The right to request

Under CCPA, You have the right to request that We disclose information to You about Our collection, use, sale, disclosure for business purposes and share of personal information. Once We receive and confirm Your request, We will disclose to You:

• The categories of personal information We collected about You
• The categories of sources for the personal information We collected about You
• Our business or commercial purpose for collecting or selling that personal information
• The categories of third parties with whom We share that personal information
• The specific pieces of personal information We collected about You
• If we sold Your personal information or disclosed Your personal information for a business purpose, We will disclose to You:
• The categories of personal information categories sold
• The categories of personal information categories disclosed

The right to say no to the sale of Personal Data (opt-out)

You have the right to direct Us to not sell Your personal information. But we do not sell personal information, so you do not need to opt-out.

The right to delete Personal Data

You have the right to request the deletion of Your Personal Data, subject to certain exceptions. Once We receive and confirm Your request, We will delete (and direct Our website Providers to delete) Your personal information from our records, unless an exception applies. We may deny Your deletion request if retaining the information is necessary for Us or Our website Providers to:

• Complete the transaction for which We collected the personal information, provide a good or website that You requested, take actions reasonably anticipated within the context of our ongoing business relationship with You, or otherwise perform our contract with You.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if You previously provided informed consent.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on Your relationship with Us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which You provided it.
• The right not to be discriminated against.

You have the right not to be discriminated against for exercising any of Your consumer's rights, including by:

• Denying goods or websites to You
• Charging different prices or rates for goods or websites, including the use of discounts or other benefits or imposing penalties
• Providing a different level or quality of goods or websites to You
• Suggesting that You will receive a different price or rate for goods or websites or a different level or quality of goods or websites

Exercising Your CCPA Data Protection Rights

In order to exercise any of Your rights under the CCPA, and if You are a California resident, You can contact Us:

By message

https://www.zenithcapital.partners/contact

By mail

Zenith Capital Partners, LLC 1061 E Indiantown Road, Suite 318, Jupiter, FL 33477

Only You, or a person registered with the California Secretary of State that You authorize to act on Your behalf, may make a verifiable request related to Your personal information.

Your request to Us must:

• Provide sufficient information that allows Us to reasonably verify You are the person about whom We collected personal information or an authorized representative
• Describe Your request with sufficient detail that allows Us to properly understand, evaluate, and respond to it

We cannot respond to Your request or provide You with the required information if We cannot:

• Verify Your identity or authority to make the request
• And confirm that the personal information relates to You

We will disclose and deliver the required information free of charge within 45 days of receiving Your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonable necessary and with prior notice.

Any disclosures We provide will only cover the 12-month period preceding the verifiable request's receipt.

For data portability requests, We will select a format to provide Your personal information that is readily useable and should allow You to transmit the information from one entity to another entity without hindrance.

Do Not Sell My Personal Information

We do not sell personal information. Opt-out of the sale of Your personal information is your right, but not necessary.

"Do Not Track" Policy as Required by California Online Privacy Protection Act (CalOPPA)

Our website does not respond to Do Not Track signals.

However, some third party websites do keep track of Your browsing activities. If You are visiting such websites, You can set Your preferences in Your web browser to inform websites that You do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of Your web browser.

Children's Privacy

Our website does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.

Your California Privacy Rights (California's Shine the Light law)

Under California Civil Code Section 1798 (California's Shine the Light law), California residents with an established business relationship with us can request information once a year about sharing their Personal Data with third parties for the third parties' direct marketing purposes.

If you'd like to request more information under the California Shine the Light law, and if You are a California resident, You can contact Us using the contact information provided below.

Links to Other Websites

Our website may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or websites.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, You can contact us:

By message: https://www.zenithcapital.partners/contact

By mail: Zenith Capital Partners LLC. 1061 E Indiantown Road, Suite 318, Jupiter, FL 33477

Last Update

Last updated: October 31, 2023