Privacy Policy

Hawthorne Capital and its affiliated entities (“we,” “us,” or “our”) respects your privacy and is committed to protecting the personal information you share with us through this website. This Policy explains what data we collect, how we use it, and the choices you have.

1. Introduction
This Privacy Policy (“Policy”) describes how Hawthorne Capital and its affiliate entities (“Hawthorne,” “we,” “our,” or “us”) collects, uses, and discloses personal information obtained through this website (the “Site”). This Policy is intended to comply with applicable United States federal and state privacy laws, including the California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CCPA/CPRA”). Capitalized terms not defined herein have the meaning set forth in the CCPA.
By using the Site, you acknowledge and agree to the terms of this Policy.

2. Information We Collect
We may collect the following information:
• Personal Information that you voluntarily provide through a form (e.g., name, email address, phone number, investment interest, etc).
• Automatically Collected Data such as IP address, browser type, device information, and pages visited via cookies and Google Analytics.
We do not intentionally collect sensitive personal information (such as Social Security numbers, government IDs, financial account details, or health information) through the Site unless required for investor verification. Please do not submit sensitive information unless specifically requested during authorized processes.

3. Legal Basis for Processing
We process personal information based on:
• Your consent;
• Our legitimate interest in operating and improving the Site;
• Compliance with legal obligations;
• Performance of a contract or pre-contractual steps; and
• Our legitimate interest in evaluating investment relationships.

4. How We Use Your Information
We use the information we collect to:
• Operate and improve our website and services.
• Respond to inquiries and provide requested information.
• Evaluate investor and partner relationships.
• Analyze website traffic and visitor behavior through Google Analytics.
• Comply with legal obligations.
We do not sell your personal information.

5. Cookies and Analytics
Our site uses cookies and Google Analytics (via Google Site Kit) to help us understand how visitors use our website.
• Google Analytics may collect IP addresses, browser data, and interaction metrics.
• Data is processed under Google’s Privacy Policy.
• You can opt out by disabling cookies in your browser or installing the
Google Analytics Opt-Out Browser Add-on
If you visit our site from jurisdictions that require consent for cookies, a banner may appear allowing you to accept or reject non-essential cookies. Some browsers allow users to send a “Do Not Track” signal. We do not respond to such signals at this time because there is no uniform industry standard governing their use.

6. Sharing of Information
We may share information with:
• Service providers who help operate our website or manage communications.
• Legal authorities if required to comply with law or protect our rights.
• Advisors or vendors under confidentiality agreements (e.g., fund administrators, auditors, marketing platforms).
• Entities in the Hawthorne Capital family of companies.
• We do not share personal data for third-party marketing.
If we engage in a merger, acquisition, restructuring, or sale of assets, personal information may be transferred as part of that transaction, subject to confidentiality obligations.

7. Your Privacy Rights
Depending on your location, you may have rights to:
• Access, correct, or delete your data.
• Opt out of analytics tracking.
• Request a copy of the information we hold about you.

To exercise your rights, contact us at:
California residents may also request information about how their data is shared under the CCPA/CPRA. Residents of certain U.S. states (such as Colorado, Virginia, Connecticut, Utah, and others) may have additional rights related to access, correction, deletion, and appeals. We honor such requests to the extent required by applicable law.

8. Information Security
We maintain administrative and technical safeguards designed to protect your information from unauthorized access, use, or disclosure. However, no online transmission is completely secure.

9. Third-Party Links
Our website may link to third-party sites (e.g., investment partners, social media, or news sources). We are not responsible for their privacy practices. Please review those sites’ policies separately.

10. Children’s Privacy
Our services are not directed to children under 13. We do not knowingly collect personal information from children.

11. Updates to This Policy
We may update this Privacy Policy from time to time. Any changes will be posted on this page with a revised “Last updated” date.

12. Contact Us
If you have questions or concerns about this Privacy Policy or our data practices, please contact us using the email address shown at the bottom of our website’s home page.