Privacy Policy

Last updated: November 1, 2025

Plakario Capital Management LLC ("Plakario," "we," "our," or "us") is committed to protecting the privacy and security of personal information we collect in the course of operating our website located at www.plakario.com (the "Site") and conducting our venture capital investment activities. This Privacy Policy explains what information we collect, how we use it, with whom we share it, and what rights you have with respect to your personal information.

By accessing or using our Site, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with the practices described in this policy, please do not use our Site.

1. Information We Collect

1.1 Information You Provide to Us Directly

We collect personal information that you voluntarily provide to us when you interact with our Site or contact us. This includes:

• Contact information: Name, email address, telephone number, postal address, and company or organization name when you complete contact forms, send us emails, or schedule meetings with our team.
• Pitch and business information: Business plans, financial projections, company descriptions, and other materials that founders submit to us in connection with potential investment opportunities.
• Professional background: Resume, biography, professional history, LinkedIn profile information, and other background materials provided in connection with employment inquiries or partnership discussions.
• Communications content: The content of emails, messages, and other communications you send to us directly.
• Feedback and survey responses: Responses to surveys, questionnaires, or feedback requests we may send to you.

1.2 Information We Collect Automatically

When you visit our Site, we and our service providers automatically collect certain technical and usage information, including:

• Log data: IP address, browser type and version, operating system, referring URLs, pages viewed, time spent on pages, links clicked, and date and time of access.
• Device information: Device type, device identifiers, and mobile network information.
• Cookies and similar technologies: We use cookies, web beacons, and similar tracking technologies to collect information about your browsing behavior on our Site. See Section 6 of this policy for more details on our use of cookies.
• Location data: General geographic location inferred from your IP address. We do not collect precise geolocation data.

1.3 Information We Collect From Third Parties

We may receive information about you from third parties in certain circumstances, including:

• Background check providers and data verification services used in connection with due diligence on potential investments or business partners.
• Professional networking platforms and publicly available professional databases from which we may collect information about founders and executives.
• Referral sources when a colleague, investor, or other third party introduces you to us.
• Analytics providers that supply aggregated data about usage patterns on our Site.

2. How We Use Your Information

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

2.1 Investment Activities

The primary purpose for which we collect personal information from founders and entrepreneurs is to evaluate, structure, and manage venture capital investments. Specifically, we use your information to:

• Review and assess business opportunities and funding applications submitted to us;
• Conduct due diligence on potential portfolio companies and their management teams;
• Communicate with founders and co-investors throughout the investment evaluation and negotiation process;
• Monitor and manage existing portfolio company investments;
• Fulfill legal and regulatory obligations associated with our investment activities;
• Maintain records required for fund administration, reporting to limited partners, and tax compliance.

2.2 Site Operations and Communications

• To operate and maintain our Site and ensure it functions correctly;
• To respond to inquiries and communications you send to us;
• To schedule and manage meetings and calls;
• To send you information about our investment activities, portfolio news, and thought leadership content that you have requested or that we believe may be of interest to you, subject to your right to opt out;
• To enforce our Terms of Service and other applicable agreements.

2.3 Analytics and Site Improvement

• To analyze usage patterns and understand how visitors interact with our Site;
• To improve the content, functionality, and user experience of our Site;
• To conduct research and analysis related to the venture capital and technology industries;
• To detect, prevent, and address technical issues and security incidents.

2.4 Legal and Compliance

• To comply with applicable laws, regulations, court orders, and legal processes;
• To exercise or defend our legal rights and those of our affiliates and investors;
• To detect, prevent, and respond to fraud, security threats, and other illegal activities;
• To maintain records required under investment adviser regulations and other applicable financial services regulations.

3. Legal Basis for Processing (Applicable to EEA, UK, and Swiss Residents)

If you are located in the European Economic Area, the United Kingdom, or Switzerland, we process your personal information on the following legal bases under the General Data Protection Regulation (GDPR) or applicable equivalent legislation:

• Legitimate interests: We process most of the personal information we collect for the purpose of conducting our venture capital investment business, including evaluating investment opportunities, managing portfolio companies, and operating our Site. We have concluded that our legitimate interests in conducting these activities are not overridden by your interests or fundamental rights and freedoms.
• Contract performance: When we enter into agreements with founders, co-investors, or business partners, we process personal information as necessary to perform those agreements.
• Legal obligation: We process personal information as necessary to comply with applicable laws, regulations, and court orders, including anti-money laundering, know-your-customer, and financial reporting obligations.
• Consent: For certain processing activities, such as sending marketing communications, we rely on your consent. You may withdraw your consent at any time by contacting us at the address provided at the end of this policy.

4. How We Share Your Information

We do not sell your personal information to third parties. We share personal information in the following limited circumstances:

4.1 Within the Plakario Organization

We share personal information among Plakario partners, employees, and affiliated entities as necessary to carry out our investment activities and operate our business.

4.2 With Service Providers

We engage third-party service providers to assist us with certain business functions, including IT systems and infrastructure, website hosting, analytics, email communications, legal and compliance services, accounting and tax services, and background check and due diligence services. These service providers are contractually obligated to use personal information only for the purposes for which we have engaged them and to maintain appropriate security measures.

4.3 With Co-Investors and Limited Partners

In connection with our investment activities, we may share certain information about portfolio companies and their founders with our co-investors, limited partners, and investment committees as required for investment decision-making, fund reporting, and governance purposes. We take reasonable steps to ensure that such disclosures are limited to information that is necessary and appropriate.

4.4 For Legal and Compliance Reasons

We may disclose personal information when required to do so by law or legal process, including in response to court orders, subpoenas, or requests from law enforcement or regulatory authorities. We may also disclose information when we believe in good faith that disclosure is necessary to protect our rights or the rights of others, to prevent harm, or to investigate or detect fraud or other illegal activities.

4.5 Business Transfers

In the event of a merger, acquisition, restructuring, sale of assets, or other business combination involving Plakario, personal information may be transferred as part of that transaction, subject to standard confidentiality protections.

5. Data Retention

We retain personal information for as long as necessary to fulfill the purposes for which it was collected, to comply with our legal and regulatory obligations, and to resolve disputes and enforce our agreements. The specific retention periods applicable to different categories of information depend on factors including the nature of our relationship, applicable legal requirements, and our operational needs.

In general:

• Information collected in connection with investment evaluations that do not result in an investment is retained for a period of three years following the conclusion of the evaluation process, after which it is securely deleted or anonymized.
• Information related to active portfolio company investments is retained for the duration of the investment and for a period of seven years following the exit or wind-down of the investment, as required for tax and regulatory compliance purposes.
• Marketing communications records and preferences are maintained until you request removal or opt out, plus a period sufficient to demonstrate compliance with our opt-out obligations.
• Website analytics data is retained in aggregated, de-identified form for up to thirty-six months.

6. Cookies and Tracking Technologies

Our Site uses cookies and similar technologies to enhance your experience and to collect information about how visitors use the Site. Cookies are small text files that are stored on your device when you visit a website. We use the following types of cookies:

• Strictly necessary cookies: These cookies are essential for the operation of our Site and cannot be disabled. They include cookies that enable you to navigate the Site and use its features, and cookies that remember your cookie consent preferences.
• Performance and analytics cookies: These cookies collect information about how visitors use our Site, including which pages are visited most often and whether visitors receive error messages. This information is used in aggregated form to improve the performance and user experience of our Site.
• Functionality cookies: These cookies allow the Site to remember choices you have made and to provide enhanced, more personalized features.

You can control and manage cookies in several ways. Most browsers allow you to refuse or delete cookies through the browser settings. Please note that disabling cookies may affect your ability to use certain features of our Site.

For more detailed information about the cookies we use and your choices regarding them, please see our Cookie Policy.

7. Data Security

We implement technical, administrative, and physical security measures designed to protect personal information against unauthorized access, disclosure, alteration, and destruction. These measures include encrypted data transmission, access controls, regular security assessments, and employee training on data handling requirements.

However, no security system is impenetrable, and we cannot guarantee the complete security of information transmitted to us over the internet. If you believe your personal information has been compromised, please contact us immediately at the address provided below.

8. Your Privacy Rights

8.1 Rights Under the GDPR (EEA, UK, and Swiss Residents)

If you are located in the European Economic Area, the United Kingdom, or Switzerland, you have the following rights with respect to your personal information:

• Right of access: You have the right to request confirmation of whether we process your personal information and, if so, to receive a copy of that information.
• Right to rectification: You have the right to request correction of inaccurate or incomplete personal information.
• Right to erasure: You have the right to request deletion of your personal information in certain circumstances, including when it is no longer necessary for the purposes for which it was collected.
• Right to restriction: You have the right to request that we restrict the processing of your personal information in certain circumstances.
• Right to data portability: You have the right to receive personal information you have provided to us in a structured, machine-readable format, and to transmit that information to another controller.
• Right to object: You have the right to object to our processing of your personal information where that processing is based on our legitimate interests.
• Right to withdraw consent: Where processing is based on consent, you have the right to withdraw that consent at any time without affecting the lawfulness of processing prior to withdrawal.

8.2 California Privacy Rights (California Residents)

California residents have additional rights under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA), including the right to know what personal information is collected, the right to request deletion of personal information, the right to opt out of the sale or sharing of personal information, and the right to non-discrimination for exercising privacy rights. Plakario does not sell or share personal information for cross-context behavioral advertising purposes.

9. Children's Privacy

Our Site is not directed to individuals under the age of eighteen. We do not knowingly collect personal information from minors. If you believe we have inadvertently collected personal information from a minor, please contact us and we will promptly delete such information.

10. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, applicable law, or operational requirements. We will notify you of material changes by posting the updated policy on our Site with a revised effective date. We encourage you to review this policy periodically.

11. Contact Us

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

Plakario Capital Management LLC
1270 Avenue of the Americas, Suite 2400
New York, NY 10020
United States
Email: privacy@plakario.com
Phone: +1 (212) 555-0174