Privacy Policy

Last updated: October 13, 2025

This Privacy Policy describes how Willton Investment Group (“we,” “us,” or “our”) collects, uses, shares, and safeguards personal information when you visit https://willtongroup.com, use our investor materials or data rooms, communicate with us, or otherwise engage our services (collectively, the “Services”).

By using the Services, you consent to the practices described in this Privacy Policy. If you do not agree, please discontinue use.

1) Information We Collect

We may collect the following categories of personal information:

A. Information you provide directly

• Identity & contact data: name, email, phone, job title, company, address, investor status (e.g., accredited/qualified purchaser), and preferences.
• Deal & diligence data (if applicable): KYC/AML documentation, proof of identity, tax forms, subscription documents, signatures, wire instructions, and related investment records.
• Communications: inquiries, meeting notes, call recordings (with notice), event registrations, survey responses.

B. Information collected automatically

• Usage data: pages viewed, referring/exit pages, time on page, clicks, scrolling, and general site interactions.
• Technical data: IP address, device identifiers, browser type, operating system, approximate location, and cookies or similar technologies (see Cookie Policy).

C. Information from third parties

• Service providers & partners: analytics platforms, marketing tools, CRM, event hosts, verification vendors (e.g., KYC/AML), and fund administrators.
• Public & professional sources: company websites, filings, social/professional networks, conference lists, and industry databases.

We do not intentionally collect sensitive personal information unless required by law (e.g., identity verification) and will process such data only for the specific purpose for which it was collected.

2) How We Use Personal Information

We use personal information to:

• Provide, operate, and improve the Services and our business operations.
• Respond to inquiries; schedule meetings; send transaction, support, and administrative messages.
• Evaluate investment opportunities, conduct due diligence, and manage investor relations.
• Verify eligibility (e.g., accredited investor checks) and fulfill legal/regulatory obligations (KYC/AML, sanctions screening, tax, recordkeeping).
• Personalize content, measure campaign performance, and conduct analytics.
• Detect, prevent, and investigate fraud, security, or technical issues.
• Comply with law, enforce terms, and protect our rights, users, and the public.

3) Legal Bases for Processing (EEA/UK/Switzerland)

Where applicable, we rely on: (i) legitimate interests (e.g., operating and securing the Services, investor relations, analytics), (ii) contract (to provide requested materials or portals), (iii) consent (for certain marketing/cookies), and (iv) legal obligations (KYC/AML, tax, recordkeeping).

4) How We Share Information

We may share personal information with:

• Vendors/Service providers (confidentiality-bound): hosting, security, analytics, CRM, email delivery, event platforms, compliance/KYC, fund administration, and professional advisors (law, audit, tax).
• Transaction counterparties and partners, as reasonably necessary for diligence or closing.
• Regulators and authorities when required by law, legal process, or to protect rights and safety.
• Corporate transfers: in connection with a merger, acquisition, financing, or sale of assets. We will continue to protect personal information per this Policy.

We do not sell personal information, and we do not share personal information for cross-context behavioral advertising as defined by certain U.S. state laws. See your state privacy rights below.

5) Retention

We retain personal information for as long as necessary for the purposes described, including to meet legal, accounting, or reporting requirements (e.g., AML/tax recordkeeping). Retention periods consider the nature and sensitivity of the data, legal requirements, and our legitimate business needs.

6) Security

We implement administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, destruction, loss, alteration, or misuse. No method of transmission or storage is 100% secure. If you believe your information has been compromised, contact us immediately (see Section 12).

7) Your Choices

• Marketing: You may opt out of marketing emails at any time via the unsubscribe link or by contacting us.
• Cookies/Tracking: Manage preferences through our Cookie Preferences link (footer) and your browser settings. See our Cookie Policy for details.

8) Your Privacy Rights

Your rights depend on your location. Subject to applicable law, you may have the right to request access, correction, deletion, portability, restriction/objection to processing, or to withdraw consent. To exercise rights, see How to Contact Us.

U.S. State Privacy Disclosures (e.g., CA, CO, CT, UT, VA)

• Right to know/access the categories and specific pieces of personal information we collected about you.
• Right to delete personal information we collected from you, subject to legal exceptions.
• Right to correct inaccurate personal information.
• Right to opt out of sales or sharing for cross-context behavioral advertising (we do not sell/share as defined by these laws).
• Right to limit the use and disclosure of sensitive personal information (we do not use sensitive data for inferring characteristics).
• Right to appeal a denial of your request (where applicable).
• Non-discrimination for exercising your rights.

How to submit a request: Email info@willtonmanagement.com with “Privacy Request” in the subject and indicate your state of residence. We will verify your identity and respond within the time required by law. You may authorize an agent to act on your behalf with appropriate documentation.

9) International Transfers

If you access the Services from outside NY, USA, your information may be processed in countries with different data protection laws. Where required, we use appropriate safeguards (e.g., Standard Contractual Clauses) for cross-border transfers.

10) Children’s Privacy

Our Services are not directed to children under 16, and we do not knowingly collect personal information from them. If we learn we have collected such information, we will delete it.

11) Investor Portal & GLBA Notice (If Applicable)

If you invest in a fund or SPV managed by us, additional notices may apply. Certain investor information may be governed by the Gramm–Leach–Bliley Act (GLBA) and handled by our fund administrator or broker-dealer. Where GLBA applies, the GLBA privacy notice provided at or after subscription controls in the event of any conflict.

12) How to Contact Us

Willton Investment Management
Address: 350 Fifth Avenue, Suite 4820, New York, NY 10118
Email: info@willtonmanagement.com
Phone: (646) 757 4613

13) Changes to This Policy

We may update this Privacy Policy from time to time. The “Last updated” date indicates the effective date of the current version. Material changes will be posted on this page and, where appropriate, notified to you.