Privacy Policy

How CGM Equity Holdings collects, uses, and protects your personal information.

Effective Date: July 20, 2026

1. Introduction

CGM Equity Holdings, LLC (CGM Equity, we, our, or us) is committed to protecting your privacy and the confidentiality of your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website cgmequity.lol, use our services, or otherwise engage with us in the course of our business activities as a strategic equity investment and technology advisory firm.

By accessing or using our website and services, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy. If you do not agree with the terms of this policy, please do not use our website or provide us with your personal information.

This policy applies to all information we collect through our website, email communications, phone calls, in-person meetings, and any other channel through which you interact with CGM Equity Holdings.

2. Information We Collect

We collect several categories of information to provide and improve our services, comply with legal obligations, and pursue our legitimate business interests. The types of information we collect include:

2.1 Personal Identification Information

  • Full name and title
  • Company name and position
  • Email address and phone number
  • Mailing and physical address
  • Professional background and affiliations

2.2 Business and Financial Information

  • Investment preferences and interests
  • Financial qualifications and accreditation status
  • Business plans, pitch decks, and financial statements
  • Transaction history and portfolio details
  • Due diligence documentation

2.3 Technical and Usage Data

  • IP address and device identifiers
  • Browser type and version
  • Operating system and platform
  • Pages visited, time spent, and navigation patterns
  • Referring website or source
  • Geographic location data at the city or regional level

2.4 Communication Data

  • Email correspondence and attachments
  • Contact form submissions and inquiries
  • Phone call records and notes
  • Meeting records and follow-up communications

3. How We Collect Information

We collect information through various methods, both directly from you and through automated means:

3.1 Direct Collection

We collect information directly when you contact us through our website contact form, send us an email, call our office, attend our events, participate in our investment process, or otherwise provide information to our team in the course of business discussions and partnership evaluations.

3.2 Automated Collection

When you visit our website, we automatically collect certain technical information through cookies, web beacons, server logs, and similar technologies. This data helps us understand how visitors interact with our site, improve performance, and maintain security.

3.3 Third-Party Sources

We may receive information about you from third-party sources, including publicly available databases, professional networks, credit reference agencies, business partners, and referral sources. We combine this information with data we already hold to maintain accurate records and evaluate business opportunities.

4. How We Use Your Information

We use the information we collect for the following purposes:

  • To respond to your inquiries and communicate with you about our services
  • To evaluate and process investment opportunities and partnership proposals
  • To conduct due diligence on prospective investments and business relationships
  • To manage our portfolio and monitor investment performance
  • To provide strategic advisory and technology consulting services
  • To send relevant updates, market insights, and information about our activities
  • To improve our website, services, and user experience
  • To comply with applicable legal and regulatory obligations
  • To detect, prevent, and address fraud, security breaches, and technical issues
  • To enforce our terms of service and protect our legal rights
  • To maintain internal records and support business operations

We will not use your personal information for purposes materially different from those disclosed in this policy without providing you notice and, where required by law, obtaining your consent.

6. Information Sharing and Disclosure

We do not sell, trade, or rent your personal information to third parties. We may share your information only in the following limited circumstances:

6.1 Service Providers

We engage trusted third-party service providers to perform functions on our behalf, including website hosting and analytics, email communication services, cloud storage and document management, professional advisors such as legal counsel, auditors, and compliance consultants, and IT support and cybersecurity services. These providers are contractually bound to process data only per our instructions and to implement appropriate security measures.

6.2 Business Partners and Co-Investors

We may share information with co-investors, limited partners, and strategic business partners in connection with specific investment transactions, subject to confidentiality agreements and only to the extent necessary for the transaction.

6.3 Legal and Regulatory Disclosures

We may disclose your information where required by law, court order, subpoena, or governmental regulation, or where we believe in good faith that disclosure is necessary to protect our rights, your safety, or the safety of others, investigate fraud, or respond to a government request.

6.4 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or a portion of our assets, your information may be transferred as part of that transaction. You will be notified via email or prominent notice on our website of any change in ownership or use of your information.

7. Data Retention

We retain your personal information only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable law. The specific retention period depends on the nature of the information and the purpose of its collection:

  • Business correspondence and inquiry records: retained for the duration of the business relationship plus seven years following the last interaction, consistent with applicable statutes of limitation and regulatory requirements
  • Investment and transaction records: retained in accordance with securities regulations and tax laws, typically for a minimum of seven years after the conclusion of the relevant investment or transaction
  • Website usage data: retained for up to twenty-six months from the date of collection
  • Marketing communications: retained until you unsubscribe or request deletion

When information is no longer needed, we securely delete or anonymize it in accordance with our data destruction procedures.

8. Data Security

We implement and maintain administrative, technical, and physical safeguards designed to protect your personal information against unauthorized access, disclosure, alteration, and destruction. Our security measures include:

  • Encryption of data in transit using industry-standard TLS protocols
  • Secure server infrastructure with access controls and authentication mechanisms
  • Regular security assessments, vulnerability scanning, and penetration testing
  • Employee training on data protection and confidentiality obligations
  • Physical security controls at our facilities
  • Incident response procedures and breach notification protocols

While we strive to protect your information, no method of electronic storage or transmission over the internet is completely secure. We cannot guarantee absolute security of your data. In the event of a data breach affecting your personal information, we will notify you and relevant authorities as required by applicable law.

9. Cookies and Tracking Technologies

9.1 What Are Cookies

Cookies are small text files placed on your device when you visit a website. They are widely used to make websites work efficiently and provide information to site owners. We use cookies and similar technologies such as web beacons, pixels, and local storage to enhance your experience and collect analytics data.

9.2 Types of Cookies We Use

  • Essential cookies: necessary for the basic functionality of our website, such as session management and security features. These cannot be disabled.
  • Analytics cookies: help us understand how visitors interact with our website by collecting and reporting information anonymously. We use these to improve site performance and content.
  • Functional cookies: enable enhanced functionality and personalization, such as remembering your preferences.

9.3 Your Cookie Choices

Most web browsers allow you to control cookies through their settings preferences. You can set your browser to refuse cookies, delete existing cookies, or alert you when cookies are being sent. Please note that disabling certain cookies may affect the functionality of our website.

We do not currently respond to Do Not Track signals from web browsers. However, you may opt out of certain analytics tracking by adjusting your browser settings or using third-party opt-out tools.

10. Third-Party Services and Links

Our website may contain links to third-party websites, platforms, and services that are not owned or controlled by CGM Equity Holdings. This Privacy Policy does not apply to those third-party services. We encourage you to review the privacy policies of any third-party sites you visit.

We may use third-party analytics services such as Google Analytics to understand website usage. These services may use cookies and similar technologies to collect information about your interactions with our site. The data collected is generally aggregated and anonymized.

We are not responsible for the privacy practices, content, or security of any third-party websites or services linked to or from our website.

11. International Data Transfers

CGM Equity Holdings is headquartered in the United States, and your information will be stored and processed in the United States. If you are located outside the United States and choose to provide information to us, please be aware that your data will be transferred to, processed, and maintained on servers located in the United States.

By providing us with your personal information, you consent to this transfer, storage, and processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy, regardless of where it is processed.

Where applicable law requires additional safeguards for cross-border data transfers, we will implement appropriate measures such as standard contractual clauses or rely on adequacy decisions as appropriate.

12. Your Privacy Rights

Depending on your jurisdiction and applicable law, you may have the following rights regarding your personal information:

12.1 Right to Access

You may request access to the personal information we hold about you, along with details about how we process it and with whom we share it.

12.2 Right to Rectification

You may request that we correct or update any inaccurate or incomplete personal information we hold about you.

12.3 Right to Erasure

You may request that we delete your personal information in certain circumstances, subject to applicable legal obligations that may require us to retain certain records.

12.4 Right to Restrict Processing

You may request that we limit how we process your personal information in certain circumstances, such as while we verify the accuracy of contested data.

12.5 Right to Data Portability

You may request a copy of your personal information in a structured, machine-readable format and have it transmitted to another controller where technically feasible.

12.6 Right to Object

You may object to the processing of your personal information for direct marketing purposes or where processing is based on our legitimate interests.

12.7 Right to Withdraw Consent

Where processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of processing conducted prior to withdrawal.

To exercise any of these rights, please contact us using the details provided in the Contact Information section below. We will respond to your request within the timeframe required by applicable law. We may need to verify your identity before processing your request.

13. California Privacy Rights

If you are a California resident, the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA) may provide you with additional rights regarding our collection and use of your personal information.

13.1 Categories of Information Collected

As described in Section 2 of this policy, we collect identifiers, professional and employment-related information, commercial information, internet and electronic network activity, and geolocation data. We collect this information for the business and commercial purposes described in Section 4.

13.2 Your California Rights

California residents have the right to know what personal information we collect, use, disclose, and sell; the right to request deletion of personal information; the right to opt out of the sale or sharing of personal information (we do not sell personal information); and the right to not be discriminated against for exercising these rights.

13.3 Authorized Agents

You may designate an authorized agent to submit requests on your behalf. We may require verification that the agent is authorized to act on your behalf before processing the request.

To exercise your California privacy rights, please contact us using the details in Section 16. We will verify your identity before responding to any request, which may require you to provide sufficient information to confirm you are the individual about whom we have collected personal information.

14. Childrens Privacy

Our website and services are not directed to individuals under the age of 18. We do not knowingly collect, use, or disclose personal information from anyone under 18 years of age. If we become aware that we have inadvertently collected personal information from a child under 18 without verified parental consent, we will take prompt steps to delete that information from our records.

If you believe that we might have information from or about a child under 18, please contact us immediately using the details provided in this policy.

15. Changes to This Privacy Policy

We reserve the right to update or modify this Privacy Policy at any time to reflect changes in our practices, legal requirements, or operational needs. When we make material changes, we will post the updated policy on this page and update the Effective Date at the top of the document.

We may also notify you of significant changes via email if you have provided us with your email address and have an active business relationship with us, or through a prominent notice on our website prior to the changes taking effect.

We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your information. Your continued use of our website and services after any changes to this policy constitutes your acceptance of the updated terms.

16. Contact Information

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, or if you wish to exercise any of your privacy rights, please contact us using the following details:

CGM Equity Holdings, LLC

2554 N Geranium Dr
Saratoga Springs, UT 84045-6701
United States

Email: talk@cgmequity.lol
Phone: +1 (707) 705-1682

We will acknowledge receipt of your inquiry and respond within the timeframe required by applicable law. If you have unresolved concerns about our handling of your personal information, you may also have the right to lodge a complaint with your local data protection supervisory authority.