Privacy Policy

Effective Date: August 4, 2026
Last Updated: August 4, 2026

Blum Pulido Capital Group, LLC (“Blum Pulido Capital Group,” “BPCG,” “we,” “us,” or “our”) respects your privacy. This Privacy Policy explains how we collect, use, disclose, and protect information when you visit blumpulidocapital.com and any related webpages, forms, investor portals, communications, or online services that link to this Privacy Policy collectively, the “Services.”

By using the Services or providing information to us, you acknowledge the practices described in this Privacy Policy.

1. Information We Collect

We may collect information directly from you, automatically when you use the Services, and from third parties.

Information You Provide to Us

Depending on how you interact with us, you may provide:

• Your first and last name
• Email address
• Mobile or work telephone number
• Preferred method of contact
• Mailing address
• Company or professional information
• Information about how you learned about us
• Your stated accredited-investor status
• Investment interests and preferences
• Information included in messages, inquiries, applications, surveys, or questionnaires
• Appointment and scheduling information
• Newsletter and marketing preferences
• Any other information you voluntarily provide

Submitting information indicating that you are an accredited investor does not confirm your eligibility to participate in any investment offering. Additional verification may be required through separate offering or subscription documents.

Investor and Transaction Information

When you consider or participate in an investment opportunity, we or our service providers may collect additional information, including:

• Identity-verification information
• Date of birth
• Government-issued identification
• Tax forms and taxpayer-identification information
• Financial or banking information
• Investment-entity information
• Accreditation-verification documentation
• Beneficial-ownership information
• Anti-money-laundering and compliance information
• Signed agreements and subscription documents
• Investment amounts, distributions, and transaction history

This information may be collected through a third-party investor portal, fund administrator, payment processor, compliance provider, attorney, accountant, financial institution, or other service provider. Those providers may maintain separate privacy policies governing their own collection and use of information.

Information Collected Automatically

When you use the Services, we and our service providers may automatically collect information such as:

• Internet Protocol address
• Browser type and version
• Device type and operating system
• General geographic location
• Referring and exit pages
• Pages viewed and links selected
• Dates and times of visits
• Time spent on webpages
• Form and website interactions
• Cookie identifiers and similar online identifiers
• Information used to detect security threats, abuse, or technical problems

We may collect this information using cookies, pixels, log files, analytics tools, and similar technologies.

2. Cookies and Similar Technologies

Cookies are small files stored on your device that help websites function, remember preferences, measure traffic, and understand how visitors interact with content.

We may use:

• Essential cookies required for website operation and security
• Preference cookies that remember selections or settings
• Analytics cookies that help us understand website usage and performance
• Marketing cookies that help measure campaigns or deliver relevant communications

Your browser may allow you to reject, delete, or restrict cookies. Disabling certain cookies may affect the availability or functionality of parts of the Services.

Where required by applicable law, we will request consent before placing nonessential cookies on your device.

We do not currently use personal information collected through the Services to sell personal information for monetary consideration. Some state laws define “sale,” “sharing,” or “targeted advertising” broadly enough to include certain advertising or analytics technologies. Where legally required, we will provide an applicable method to opt out.

3. How We Use Information

We may use collected information to:

• Operate, maintain, secure, and improve the Services
• Respond to questions and contact requests
• Add individuals to our investor or newsletter lists
• Evaluate interest in potential investment opportunities
• Provide educational content, company news, and market updates
• Schedule and manage calls or meetings
• Communicate about potential or existing investments
• Verify investor eligibility and accreditation when applicable
• Process investment documents and transactions
• Administer investor relationships, records, reporting, and distributions
• Personalize website content and communications
• Analyze website traffic and campaign performance
• Detect, prevent, and investigate fraud, abuse, or security incidents
• Maintain legal, tax, accounting, and business records
• Comply with legal and regulatory obligations
• Establish, exercise, or defend legal claims
• Enforce our agreements and policies
• Complete a merger, financing, acquisition, restructuring, or similar business transaction
• Carry out other purposes disclosed when information is collected or with your consent

4. Email, Telephone, and Text Communications

When you provide contact information, you may receive communications relating to your inquiry, appointments, investor interest, educational content, company updates, or potential investment opportunities.

You may unsubscribe from promotional emails by selecting the unsubscribe link included in those messages. Even after unsubscribing from marketing messages, we may continue sending administrative, transactional, compliance-related, or legally required communications.

When you expressly consent to receive text messages, we may contact you at the telephone number provided. Message frequency may vary. Message and data rates may apply. Consent to receive marketing text messages is not a condition of making an investment or purchasing any service.

You may opt out of promotional text messages by replying STOP. You may reply HELP for assistance or contact us using the information below.

We are not responsible for fees imposed by your telephone or internet-service provider.

5. How We Disclose Information

We may disclose information in the following circumstances:

Service Providers

We may provide information to vendors that perform services on our behalf, such as:

• Website hosting and maintenance
• Customer-relationship management
• Email and newsletter distribution
• Telephone and text-message communications
• Appointment scheduling
• Website analytics
• Cybersecurity and fraud prevention
• Cloud storage and data hosting
• Investor-portal administration
• Accreditation and identity verification
• Accounting, tax, audit, and legal services
• Banking and payment processing
• Property management and investment administration

These providers are authorized to use information only as necessary to perform services for us or as otherwise permitted by their own agreements and applicable law.

Professional Advisers and Investment Partners

We may disclose information to attorneys, accountants, auditors, consultants, lenders, insurers, brokers, property managers, fund administrators, investment partners, and other professionals involved in evaluating, structuring, administering, financing, or operating an investment.

Legal and Safety Requirements

We may disclose information when we reasonably believe disclosure is necessary to:

• Comply with a law, regulation, subpoena, court order, or governmental request
• Cooperate with an investigation
• Protect our legal rights, property, personnel, investors, users, or the public
• Detect or prevent fraud, misuse, security threats, or unlawful activity
• Enforce our agreements or policies

Business Transactions

Information may be disclosed or transferred as part of a merger, acquisition, financing, asset sale, reorganization, bankruptcy, or similar transaction involving all or part of our business.

With Your Direction or Consent

We may disclose information when you direct us to do so, request an interaction involving a third party, or otherwise consent.

6. Personal Information We Do Not Sell

We do not sell personal information for monetary consideration.

We also do not knowingly sell or share the personal information of children under 16 for cross-context behavioral advertising.

Should our practices change, we will revise this Privacy Policy and provide any opt-out rights required by applicable law.

7. Data Retention

We retain personal information for as long as reasonably necessary to:

• Provide the Services
• Manage investor and business relationships
• Complete the purposes described in this Privacy Policy
• Comply with legal, tax, accounting, securities, and recordkeeping obligations
• Resolve disputes
• Prevent fraud
• Enforce agreements
• Protect our legitimate business interests

Retention periods may vary depending on the nature of the information, the relationship involved, and applicable legal requirements.

8. Data Security

We use reasonable administrative, organizational, technical, and physical safeguards intended to protect personal information.

However, no website, communication system, database, or electronic-storage method is completely secure. We cannot guarantee that information will never be intercepted, accessed, lost, altered, or disclosed without authorization.

You are responsible for protecting any account credentials and promptly notifying us of suspected unauthorized access.

9. Your Privacy Choices

Depending on where you live and applicable law, you may have the right to request that we:

• Confirm whether we process your personal information
• Provide access to certain personal information
• Correct inaccurate personal information
• Delete certain personal information
• Provide a portable copy of certain information
• Restrict or object to certain processing
• Opt you out of certain sales, sharing, profiling, or targeted advertising
• Withdraw consent where processing is based on consent
• Explain or appeal a decision concerning a privacy request

These rights are not absolute. Applicable law may allow or require us to deny or limit a request, including when information must be retained for regulatory, contractual, fraud-prevention, security, tax, legal, or investment-recordkeeping purposes.

To make a privacy request, email [email protected] with the subject line Privacy Request.

We may need to verify your identity before processing a request. Authorized agents may submit requests where permitted by law, subject to verification of their authority.

We will not unlawfully discriminate against you for exercising an applicable privacy right.

10. Global Privacy Control and Browser Signals

Some browsers and extensions support preference signals such as Global Privacy Control.

Where applicable law requires us to recognize a valid browser-based opt-out preference signal, we will treat the signal as a request to opt out for the browser or device sending it.

Because there is not yet a universally accepted standard for all “Do Not Track” signals, the Services may not respond to every browser setting or signal.

11. Third-Party Websites and Services

The Services may contain links to third-party websites, investor portals, scheduling platforms, social networks, or other services.

We do not control and are not responsible for the privacy, security, content, or practices of third parties. This Privacy Policy does not apply to information independently collected by those third parties.

You should review the privacy policy of each third-party service before providing information.

12. Children’s Privacy

The Services are intended for adults and are not directed to children under 13.

We do not knowingly collect personal information from children under 13 through the Services. If we learn that such information has been collected, we will take reasonable steps to delete it.

A parent or legal guardian who believes a child has submitted personal information may contact us at [email protected].

13. International Visitors

Blum Pulido Capital Group is based in the United States. If you access the Services from outside the United States, your information may be transferred to, stored in, or processed in the United States or another jurisdiction where our service providers operate.

Those jurisdictions may have data-protection laws that differ from those in your country.

14. Changes to This Privacy Policy

We may revise this Privacy Policy periodically.

When we make changes, we will update the “Last Updated” date. Material changes may also be communicated through the website or another reasonable method.

Your continued use of the Services after an updated Privacy Policy becomes effective signifies your acknowledgment of the revised policy.

15. Contact Us

Questions, requests, or concerns regarding this Privacy Policy may be directed to:

Blum Pulido Capital Group, LLC
Email: [email protected]
Telephone: +1 (425) 749-2604
Website: blumpulidocapital.com