Privacy policy

This policy explains what information we collect when you use this website or submit our investor access form, why we collect it, and what rights you have over it. It applies to oaktowercapital.com.

Last updated: [DATE]

Who we are

Oaktower Capital ([LEGAL ENTITY NAME]) is the controller of the personal information described here. You can reach us about privacy matters at [privacy@oaktowercapital.com].

What we collect

We only collect what you choose to give us. If you submit the investor access form, that is:

• Name and email address (required).
• Phone number (optional).
• Investor type and indicative investment amount that you select.
• Your confirmations — that you are (or expect to qualify as) an accredited investor, and that you agree to be contacted by email, phone call, or text message.

We do not ask for, and you should not send us, sensitive financial account numbers, Social Security numbers, or identity documents through this website form. If accredited-investor verification becomes necessary, we will tell you how to provide those materials securely.

How we use it

• To respond to your request and contact you about the notes, by email, phone, or text as you consented.
• To assess whether you may be eligible to receive offering materials.
• To begin accredited-investor verification, if you proceed.
• To keep records we are required to keep as a securities issuer.

We will not sell your personal information. We do not use it for advertising, and we do not share it with advertisers or data brokers.

Legal basis and consent

We contact you by email, phone call, or text message because you asked us to and checked the consent box on the form. Consent is not a condition of any investment. Message and data rates may apply to texts.

You can withdraw consent at any time — reply STOP to any text, tell us during a call, or email us asking to be removed. We will stop contacting you promptly. Withdrawing consent does not affect contact that already occurred.

Who we share it with

We share personal information only with service providers who help us operate this site and communicate with you, and only as needed:

• Web3Forms — processes the access form and delivers submissions to our email.
• Cloudflare — hosts this website and provides security and network services.
• Our email provider — receives and stores the messages sent to us.
• Professional advisers (legal, accounting, compliance) and any verification provider, where relevant.

We may also disclose information where required by law, regulation, subpoena, or a request from a securities regulator.

Cookies and analytics

This website does not set advertising or tracking cookies and does not run third-party analytics. Our host may process standard technical data (such as IP address and browser type) in server logs for security and reliability. If we add analytics in the future, we will update this policy first.

How long we keep it

We keep your information for as long as needed to respond to your request and to meet our legal and recordkeeping obligations as a securities issuer, after which it is deleted or anonymized. If you ask us to delete your information and we are not required to retain it, we will do so.

Security

We take reasonable measures to protect the information you give us, including encryption in transit (HTTPS) and limiting access to those who need it. No method of transmission or storage is completely secure, so we cannot guarantee absolute security.

Your rights

Depending on where you live, you may have the right to:

• Access the personal information we hold about you.
• Correct information that is inaccurate.
• Request deletion of your information.
• Withdraw consent to being contacted.
• Object to or restrict certain processing.

To exercise any of these, email [privacy@oaktowercapital.com]. We will respond within the time required by applicable law. California residents (CCPA/CPRA) and individuals in the EEA/UK (GDPR) may have additional rights, including the right not to receive discriminatory treatment for exercising them.

Children

This website is intended for accredited investors and is not directed to anyone under 18. We do not knowingly collect information from children.

Changes to this policy

We may update this policy from time to time. The “last updated” date above will change when we do. Material changes will be highlighted on this page.

Contact

Questions about this policy or your information: [privacy@oaktowercapital.com], [LEGAL ENTITY NAME], [ADDRESS].