Legal

Privacy Policy

Romema Capital (“Romema,” “we,” “our,” or “us”) respects your privacy and is committed to protecting the personal information you share with us. This Privacy Policy explains how we collect, use, disclose, and safeguard information when you visit www.romemacapital.com (the “Site”) or otherwise interact with us online or offline. By accessing the Site, you acknowledge that you have read, understood, and agree to the practices described below.

1. Information We Collect

We collect several types of information: personal identifiers—such as your name, email address, phone number, postal address, job title, and accreditation status—provided when you fill out forms (like “Contact Us”), register for conferences, send emails, or access our investor portal; transaction and relationship data—including your property preferences, investment interests, due-diligence materials, and signed agreements—shared through direct interactions, secure document uploads, or investor onboarding; device and usage data—such as IP address, browser and referral details, time spent on pages, clicks, and general location—captured via cookies, web beacons, and analytics tools; marketing preferences, such as your opt-in or opt-out choices for newsletters and deal announcements, recorded through subscribe or unsubscribe actions; and any user-generated content you voluntarily submit, including comments, survey responses, or uploaded files on our site or third-party platforms. We do not knowingly collect information from children under 13, nor do we target our services to them.

2. How We Use Your Information

We process information to:

• Provide Services – respond to inquiries, evaluate investment opportunities, manage investor accounts.
• Operate & Improve the Site – troubleshoot, analyze performance, develop new features.
• Communicate – send administrative messages, newsletters, deal alerts, and important notices.
• Marketing & Events – invite you to webinars, conferences, or networking events related to our business.
• Legal & Compliance – satisfy due-diligence, “Know Your Client,” AML, SEC, GDPR, and other regulatory obligations.
• Security & Fraud Prevention – detect, investigate, and prevent malicious or unauthorized activities.
• Business Transfers – support a merger, acquisition, asset sale, or similar transaction.

3. Legal Bases for Processing (EEA/UK Visitors)

Where GDPR or UK GDPR applies, we rely on the following bases:

• Performance of a Contract (e.g., investor subscription agreements)
• Legitimate Interests (e.g., improving the Site, detecting fraud)
• Consent (for optional cookies or marketing emails)
• Legal Obligation (e.g., record-keeping, KYC/AML checks)

You may withdraw consent at any time without affecting prior processing.

4. Cookies & Similar Technologies

We use first-party and third-party cookies, pixels, and local storage to remember preferences and login sessions, measure Site traffic and engagement, and improve content relevance. You can manage cookies at any time through your browser settings. Disabling cookies may affect site functionality.

5. Data Retention

We retain personal data only as long as necessary to fulfill the purposes outlined in this Policy, unless a longer retention period is required or permitted by law (e.g., tax, accounting, SEC rules). When retention is no longer necessary, we securely delete or anonymize the data.

6. International Transfers

Romema Capital is headquartered in the United States. If you access the Site from outside the U.S., your information may be transferred to—and processed in—the U.S. or other jurisdictions where privacy laws may be less protective. We implement appropriate safeguards such as Standard Contractual Clauses or rely on adequacy decisions where applicable.

7. Your Privacy Rights

California (CCPA/CPRA) Residents

You may have the right to:

• Know the categories and specific pieces of personal information we collected about you
• Request deletion or correction of your personal information
• Opt out of the sale/share of personal information (Romema does not sell/share in the CPRA sense)
• Not be discriminated against for exercising your rights

Submit requests via the contact details below. We will verify your identity before fulfilling requests.

EEA/UK Residents

You may have the right to access, rectify, erase, restrict, or object to processing, and to data portability. To exercise these rights, contact us as indicated below. You also have the right to lodge a complaint with your local data-protection authority.

8. Third-Party Links

Our Site may contain links or integrations (e.g., embedded maps) to non-Romema websites. We are not responsible for the privacy practices of those third parties; this Policy does not apply to them. Review their policies before providing personal information.

9. Changes to This Privacy Policy

We may update this Policy periodically to reflect changes in technology, legal requirements, or our practices. We will post the revised version on the Site and update the “Last updated” date. Material changes will be highlighted or communicated directly where legally required.

Contact

Questions or requests: investors@romema.capital