Atwells Capital, LLC - Privacy Policy

1. Introduction

Atwells Capital, LLC ("Company" or "We" or “Us” or “Our”) respects Your privacy and is committed to protecting it pursuant to this privacy policy (“Policy” or “Privacy Policy”).

This Privacy Policy describes the types of information We may collect from You or that You may provide when You visit the website www.atwellscapital.com, any subdomain, or other websites operated by the Company (Our "Website"), communicating with us through call, text message, or email, or third party service, or use or consume any of the products or services the Company provides or offers (“Services”), and Our practices for collecting, using, maintaining, protecting, and disclosing that information. "You," "Your," "you," or "your" refers to you, whether you're a visitor, user of the Website or any Services, or someone communicating with Us .

By accessing or using this Website, clicking a checkbox, using the Services, providing Personal Information to Us, contacting Us, or communicating with Us, You agree to this Privacy Policy and our “Terms of Use” , which this Privacy Policy is incorporated into.

This Privacy Policy is effective as of November 20, 2025.

2. Applicability

This Privacy Policy applies to information We collect:

On or through the Website;
In email, text, and other electronic messages between You and Us; and/or
In the course of providing You with Services.

It does not apply to information collected by:

any other website operated by any third party (including Our affiliates and subsidiaries);
any attorney(s), real estate broker(s), accountant(s), financial advisor(s), insurance agent(s), or banking institution(s); or
Any third party (including Our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on the Website.

3. Information We Collect About You and How We Collect It

We collect several types of information from and about users of Our Website or Services, including information:

By which You may be personally identified, such as name, postal address, e-mail address, telephone number, social security number, gender, birthdate, professional qualifications and information, and/or any other identifier by which You may be contacted online or offline, information We gather from background or credit checks, credit report information, banking information, employer identification number, tax ID, and driver’s license information ("Personal Information");
That is about You, but individually does not identify You, such as aggregate information; and/or
About Your internet connection, the equipment You use to access Our Website, and usage details.

We collect this information:

Directly from You when You provide it to Us, use the Website, or use Our Services, or communicate with Us.
From third parties such as current lender(s), attorney(s), real estate broker(s), accountant(s), financial advisor(s), insurance agent(s), banking institution(s) and others; and/or
From public record and/or databases, including, but not limited to, the Registry of Deeds, the Secretary of State/Corporations Division, municipal tax collectors and assessors, U.S. Treasury Department (including the Office of Foreign Assets Control), the Internal Revenue Service, Department of Homeland Security, and any other state or federal agency.
Automatically as You navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
From third parties, for example, Our business partners, third parties from whom we have purchased business contact information, and publicly accessible websites, such as a company’s website, professional network services, or press releases.

Information We Collect Through Automatic Data Collection Technologies

As You navigate through and interact with Our Website, We may use automatic data collection technologies to collect certain information about Your equipment, browsing actions, and patterns, including:

Details of Your visits to Our Website, including traffic data, location data, logs, and other communication data, and the resources that You access and use on the Website.
Information about Your computer and internet connection, including Your IP address, operating system, and browser type.

We also may use these technologies to collect information about Your online activities over time and across third-party websites or other online services (behavioral tracking).

The information We collect automatically may include Personal Information. It helps Us to improve Our Website and to deliver a better and more personalized service, including by enabling Us to:

Estimate Our audience size and usage patterns.
Store information about Your preferences, allowing Us to customize Our Website according to Your individual interests.
Speed up Your searches.
Recognize You when You return to Our Website.

The technologies We use for this automatic data collection may include:

Cookies (or browser cookies). A cookie is a small file placed on the hard drive of Your computer. You may refuse to accept browser cookies by activating the appropriate setting on Your browser. However, if You select this setting, You may be unable to access certain parts of Our Website. Unless You have adjusted Your browser settings so that it will refuse cookies, Our system will issue cookies when You direct Your browser to Our Website.
Web Beacons. Pages of Our Website and Our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

4. Third-Party Use of Cookies and Other Tracking Technologies

Some content or applications, including advertisements, on the Website are served by third parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about You when You use Our website. The information they collect may be associated with Your Personal Information, or they may collect information, including Personal Information, about Your online activities over time and across different websites and other online services. They may use this information to provide You with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties' tracking technologies or how they may be used. If You have any questions about an advertisement or other targeted content, You should contact the responsible provider directly.

5. How We Use Your Information

We use information that We collect about You or that You provide to Us, including any Personal Information:

To present Our Website and its contents to You.
To provide You with information, products, or Services that You request from Us.
To call You or send You SMS or text messages regarding Your inquiry, transaction, or request for information, information on our Services, reminders on appointments, and other upcoming deadlines related to Services you requested (The procedure for opting out of any SMS or text messages is set forth in our Terms of Use. In addition, for the sake of clarity, as set forth in Section 6, We do not sell your phone number, which falls under the definition of Personal Information in this Privacy Policy, to third parties for marketing purposes.).
To fulfill any other purpose for which You provide it.
To provide You or send You notices or reminders about the Services, including expiration and renewal notices, or reminders about payment.
To carry out Our obligations and enforce Our rights arising from any contracts entered into between You and Us, including for billing and collection.
To notify You about changes to Our Website or any products or Services We offer or provide through it.
To conduct data analysis, audits, and to improve Our services.
To allow You to participate in interactive features on Our Website.
In any other way We may describe when You provide the information.
To send You automated promotional or marketing email messages regarding our offerings or services. These promotional or marketing email messages may contain web beacons and other features that help Us make sure that You received and were able to open the message.
For any other purpose with Your consent.

6. Disclosure of Your Information

We may disclose aggregated information about Our users and information that does not identify any individual, without restriction.

We may disclose Personal Information that We collect or You provide as described in this Privacy Policy:

To Our subsidiaries and affiliates.
To contractors, service providers, and other third parties We use to support Our business or Services or reasonably related thereto, including, but not limited to, brokers, title companies, appraisers, insurance companies, underwriting services, processing services, printing companies, software providers, cloud service providers, background check providers, attorneys, financial institutions, etc.
To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by Us about Our Website users or users of Our Services is among the assets transferred.
To fulfill the purpose for which You provide it.
For any other purpose disclosed by Us when You provide the information.
With Your consent.

We may also disclose Your Personal Information:

To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
To enforce or apply Our terms of use, and other agreements related to Our Services, including for billing and collection purposes.
If We believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

We do not rent or sell Personal Information about You with third parties or non-affiliated companies for valuable consideration.

7. Your Choices On How We Use and Disclose Your Information

We strive to provide You with choices regarding the Personal Information You provide to Us. We have created mechanisms to provide You with the following control over Your information:

Tracking Technologies. You can set Your browser to refuse all or some browser cookies, or to alert You when cookies are being sent. If You disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
Promotional or Marketing Emails from the Company. If We have sent You an automated promotional or marketing email, You may send Us a return email asking to be omitted from future automated promotional or marketing email distributions, or follow the instructions in the automated promotional or marketing email to opt out. This opt-out does not apply to email messages related to the use of our Services or other transactional emails.

We do not directly engage in targeting advertising based on information that we collect from you directly or through automated means. However, We do not control third parties' collection or use of Your information to serve interest-based advertising. These third parties may provide You with ways to choose not to have Your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative ("NAI") on the NAI's website.

8. Data Security

We have implemented measures designed to reasonably secure Your Personal Information from unauthorized access, use, alteration, and disclosure. These safeguards vary based on the sensitivity of information that We collect, process, and store, and the current state of technology.

Unfortunately, the transmission of information via the internet is not completely secure. As such, We cannot guarantee the security of Your Personal Information transmitted to or through Our Website, to Us via any other means, or stored or used by Us. Any transmission of Personal Information is at Your own risk. We are not responsible for circumvention of any privacy settings or security measures.

9. Children Under the Age of 18

Our Website and/or Services are not intended for children under 18 years of age. No one under age 18 may provide any information to or on the Website. We do not knowingly collect Personal Information from children under 18. If You are under 18, do not use or provide any information on this Website, through any of its features, register on the Website, make any purchases through the Website, use any of the interactive or public comment features of this Website, or provide any information about yourself to US, including Your name, address, telephone number, email address, or any screen name or user name You may use, social security number, etc. If We learn We have collected or received Personal Information from a child under 18 without verification of parental consent, We will delete that information. If You believe We may have any information about a child under 18, please contact Us.

10. Changes to Our Privacy Policy

In Our sole discretion, We may update this Privacy Policy from time to time. When we do so, We will revise the effective date appearing above. In some instances, in Our sole discretion, We may also take reasonable steps as necessary, depending on the nature of the changes, including providing notice of changes. Notwithstanding the foregoing sentence, You are expected to check this page and the Website from time to time, so You are aware of any changes, as they are binding on You. This Privacy Policy supersedes any prior versions of this Privacy Policy published or distributed by Us.

11. Contact Information

To ask questions or comment about this Privacy Policy and Our privacy practices, contact Us at: ntella@atwellscapital.com