Iron Gate Capital Group, LLC

PRIVACY POLICY

Last Modified: October 24, 2025

1. INTRODUCTION

Iron Gate Capital Group (“we,” “our,” or “the Company”) values the privacy and protection of personal information. This Privacy Policy outlines the manner in which we collect, use, disclose, and safeguard the personal information of clients, employees, and other stakeholders. By engaging with Iron Gate Capital Group, you consent to the practices described in this Policy.

2. SCOPE

This Policy applies to all personal information collected, processed, or stored by Iron Gate Capital Group in connection with its operations. It governs interactions with clients, employees, contractors, vendors, and other third parties. This Policy is applicable regardless of the method of collection, whether electronic, paper-based, or verbal.

3. DEFINITIONS

• Personal Information: Any information that identifies or can reasonably identify an individual, including but not limited to name, contact details, financial information, and identification numbers.
• Processing: Any operation performed on personal information, including collection, use, storage, disclosure, or destruction.
• Data Subject: An individual whose personal information is collected or processed.

4. INFORMATION COLLECTION

We may collect the following categories of personal information:

1. Client Information: Name, address, contact information, financial records, and transaction history.
2. Employee Information: Employment history, payroll data, contact details, and identification documents.
3. Vendor and Contractor Information: Contact information, contractual records, and payment information.
4. Website and Communication Data: IP addresses, email correspondence, cookies, and usage metrics.

5. PURPOSE OF PROCESSING

Personal information is collected and processed for legitimate business purposes, including but not limited to:

• Providing financial services and investment management.
• Managing employee and contractor relationships.
• Complying with legal, regulatory, and contractual obligations.
• Conducting internal audits and risk management.
• Communicating with clients, employees, and vendors.
• Improving operational efficiency and service delivery.

6. LEGAL BASIS FOR PROCESSING

We rely on one or more of the following legal bases when processing personal information:

• Consent of the individual.
• Performance of a contract.
• Compliance with a legal obligation.
• Protection of vital interests.
• Legitimate business interests pursued by Iron Gate Capital Group, provided such interests are not overridden by the rights of the individual.

7. INFORMATION SHARING & DISCLOSURE

Personal information may be shared under the following circumstances:

• Service Providers: With trusted third-party service providers who assist in business operations.
• Regulatory Authorities: When required by law, regulation, or legal process.
• Business Transfers: In connection with mergers, acquisitions, or corporate restructuring.
• Consent-Based Sharing: With third parties as authorized by the data subject.

We ensure that third parties adhere to privacy and security standards equivalent to those outlined in this Policy.

8. DATA RETENTION

Personal information will be retained only for as long as necessary to fulfill the purposes outlined in this Policy, comply with legal obligations, or resolve disputes. After the retention period, information will be securely destroyed or anonymized.

9. DATA SECURITY

We implement administrative, technical, and physical safeguards to protect personal information against unauthorized access, disclosure, alteration, or destruction. Access is restricted to authorized personnel on a need-to-know basis.

10. RIGHTS OF DATA SUBJECTS

Individuals have the following rights regarding their personal information:

• Right to access and obtain a copy of their personal information.
• Right to correct or update inaccurate information.
• Right to request deletion or restriction of processing.
• Right to object to processing based on legitimate interests.
• Right to withdraw consent at any time where processing is based on consent.
• Right to lodge a complaint with relevant supervisory authorities.

Requests can be submitted to Iron Gate Capital Group’s Data Protection Officer at privacy@irongatecg.com

11. CROSS-BORDER TRANSFERS

Personal information may be transferred to jurisdictions outside the country of collection, including countries that may not have equivalent data protection laws. In such cases, we implement appropriate safeguards, such as contractual clauses, to protect the data.

12. UPDATES TO THE POLICY

Iron Gate Capital Group reserves the right to modify this Privacy Policy at any time. Material changes will be communicated via email, website updates, or other appropriate channels. Continued use of our services constitutes acceptance of any amended Policy.

13. CONTACT INFORMATION

For questions, concerns, or requests related to this Privacy Policy or personal information processing, please contact: privacy@irongatecg.com

---