Last updated: July 16, 2026

Nightfox Holdings LLC (“Nightfox Holdings,” “Nightfox,” “we,” “us,” or “our”) respects your privacy and is committed to handling personal information responsibly.

This Privacy Policy explains how we collect, use, disclose, retain, and protect personal information when you visit nightfoxholdings.com, communicate with us, or otherwise interact with Nightfox Holdings through the website or related digital services collectively referred to as the “Site.”

By using the Site, you acknowledge the practices described in this Privacy Policy.

1. Scope of this Privacy Policy

This Privacy Policy applies to personal information collected through:

• The Nightfox Holdings website;
• Contact forms and other website submissions;
• Emails and other communications sent to Nightfox Holdings;
• Website analytics and similar technologies;
• Business inquiries initiated through the Site; and
• Other interactions that link or refer to this Privacy Policy.

Nightfox Holdings is a holding company with interests in independently operated businesses and ventures. This Privacy Policy applies only to Nightfox Holdings and the Site.

Portfolio companies, subsidiaries, affiliates, and third-party websites may maintain separate privacy policies governing their own websites, products, services, customers, and operations. Nightfox Holdings is not responsible for the privacy practices of independently operated websites or services that do not link to this Privacy Policy.

2. Personal Information We Collect

The information we collect depends on how you interact with the Site.

Information you provide directly

You may provide personal information when you contact us, submit an inquiry, correspond with us, or otherwise communicate with Nightfox Holdings.

This information may include:

• Your name;
• Email address;
• Telephone number;
• Company or organization;
• Professional title;
• Mailing address;
• The subject and contents of your communication;
• Information relating to a proposed business relationship, investment, transaction, service, or opportunity;
• Documents or materials you voluntarily provide; and
• Any other information you choose to submit.

Please do not send sensitive personal information through the Site unless it is reasonably necessary and specifically requested.

Information collected automatically

When you visit the Site, certain information may be collected automatically by our hosting, security, analytics, and technology providers.

This information may include:

• Internet Protocol address;
• Browser type and version;
• Device type and operating system;
• General geographic location derived from an Internet Protocol address;
• Referring and exit pages;
• Pages viewed;
• Date and time of access;
• Time spent on pages;
• Links or features used;
• Device identifiers;
• Cookie identifiers;
• Diagnostic and performance information; and
• Security, error, and access logs.

We generally use this information to operate, protect, understand, and improve the Site.

Information received from third parties

We may receive information from:

• Portfolio companies and affiliated entities;
• Business associates and professional advisers;
• Service providers;
• Publicly available sources;
• Social or professional networking platforms;
• Event organizers;
• Prospective business partners;
• Governmental or regulatory sources; and
• Other persons who refer or introduce you to Nightfox Holdings.

Information received from third parties may include professional contact details, business affiliations, publicly available information, and information relevant to an existing or proposed business relationship.

3. How We Use Personal Information

Nightfox Holdings may use personal information to:

• Operate, maintain, secure, and improve the Site;
• Respond to inquiries and communications;
• Evaluate business, investment, acquisition, financing, partnership, real estate, consulting, or strategic opportunities;
• Communicate with business contacts, advisers, vendors, and prospective counterparties;
• Manage relationships involving Nightfox Holdings or its portfolio;
• Conduct due diligence and business planning;
• Verify identities and protect against fraud or misuse;
• Monitor website performance and usage;
• Diagnose technical problems;
• Maintain records;
• Protect our rights, property, systems, personnel, and operations;
• Comply with legal, regulatory, contractual, accounting, and reporting obligations;
• Establish, exercise, or defend legal claims;
• Enforce our terms, policies, and agreements;
• Complete a corporate transaction or organizational restructuring; and
• Carry out any other purpose disclosed when the information is collected or authorized by you.

We may combine information collected from different sources when reasonably necessary for these purposes.

4. Legal Bases for Processing

Where the laws of the European Economic Area, United Kingdom, Switzerland, or another jurisdiction require us to identify a legal basis, we may process personal information on one or more of the following grounds:

Legitimate interests

We may process personal information when reasonably necessary for our legitimate business interests, including:

• Operating and securing the Site;
• Responding to business inquiries;
• Evaluating opportunities;
• Administering business relationships;
• Maintaining appropriate records;
• Preventing misuse and fraud; and
• Protecting our legal and commercial interests.

We consider the nature of the information, the context of the processing, and the potential effect on the individual when relying on legitimate interests.

Consent

We may process information based on your consent where consent is requested or required. You may withdraw your consent at any time, subject to applicable law. Withdrawal does not affect processing that occurred before consent was withdrawn.

Contractual necessity

We may process personal information when necessary to:

• Take steps at your request before entering into an agreement;
• Perform an agreement with you; or
• Administer an existing contractual relationship.

Legal obligations

We may process information when necessary to comply with applicable law, a lawful request, a court order, regulatory requirements, tax obligations, accounting standards, or other legal duties.

Protection of rights and interests

In limited circumstances, we may process information to protect the vital interests of an individual or to establish, exercise, or defend legal claims.

5. Cookies and Similar Technologies

The Site may use cookies, pixels, local storage, server logs, and similar technologies.

Cookies are small files placed on a browser or device that allow websites and service providers to recognize a browser, remember certain information, support website functionality, measure usage, and improve performance.

Types of cookies

The Site may use:

Strictly necessary cookies
These support essential website functions, security, network management, and accessibility.

Preference cookies
These remember choices or settings that improve the visitor experience.

Analytics cookies
These help us understand how visitors reach and use the Site, which pages are viewed, and how the Site performs.

Third-party or embedded-content cookies
Third-party services embedded in or linked from the Site may place their own cookies or collect information under their respective privacy policies.

Managing cookies

You can configure your browser to block, restrict, or delete cookies. Doing so may affect certain features or functionality.

Where required by applicable law, nonessential cookies will be used only after obtaining the required consent. You may be able to modify your selections through a cookie-preference tool displayed on the Site.

6. Analytics

We may use third-party analytics providers to understand Site traffic, visitor interactions, device characteristics, and performance.

Analytics providers may receive information such as:

• Internet Protocol address;
• Browser and device information;
• Pages visited;
• Referring website;
• Approximate location;
• Session duration; and
• Interaction events.

We use analytics information to evaluate Site performance, identify technical issues, understand general audience activity, and improve the Site.

Where reasonably available, we may configure analytics services to reduce or limit the collection of identifying information.

7. How We Disclose Personal Information

We may disclose personal information to the following categories of recipients.

Service providers

We may provide information to companies that perform services on our behalf, including:

• Website hosting;
• Domain and infrastructure services;
• Email services;
• Cybersecurity;
• Data storage;
• Analytics;
• Information technology support;
• Professional consulting;
• Accounting;
• Legal services; and
• Records management.

Service providers are permitted to process information only for the services they provide or as otherwise allowed by applicable law and contract.

Portfolio companies and affiliated entities

We may disclose information to entities within the Nightfox Holdings portfolio when reasonably relevant to:

• An inquiry involving that entity;
• A potential business relationship;
• Shared administrative functions;
• Internal reporting;
• Legal compliance;
• Risk management; or
• A legitimate operational or strategic purpose.

Each entity may separately control personal information it receives for its own purposes.

Professional advisers

We may disclose information to attorneys, accountants, auditors, insurers, consultants, financial institutions, and other professional advisers when reasonably necessary to obtain advice, conduct business, or protect our interests.

Business counterparties

Information may be disclosed to prospective or existing investors, lenders, financing sources, acquisition targets, purchasers, sellers, joint-venture participants, landlords, tenants, contractors, and other counterparties when relevant to a proposed or existing relationship.

Where appropriate, such disclosures may be subject to confidentiality obligations.

Corporate transactions

We may transfer or disclose information in connection with:

• A merger;
• Acquisition;
• Sale of assets;
• Financing;
• Reorganization;
• Restructuring;
• Bankruptcy;
• Dissolution;
• Formation of a joint venture; or
• Transfer of all or part of a business or ownership interest.

Information may be shared during evaluation, negotiation, due diligence, or completion of such a transaction.

Legal and protective disclosures

We may disclose information when we reasonably believe disclosure is necessary to:

• Comply with applicable law;
• Respond to a subpoena, court order, or lawful governmental request;
• Cooperate with regulators or law-enforcement authorities;
• Detect or prevent fraud, security incidents, or misuse;
• Protect the safety or rights of Nightfox Holdings, its affiliates, its personnel, another person, or the public;
• Enforce agreements or policies; or
• Establish, exercise, or defend legal claims.

At your direction

We may disclose information when you authorize or direct us to do so.

8. Sale and Sharing of Personal Information

Nightfox Holdings does not sell personal information for monetary consideration.

Nightfox Holdings does not knowingly disclose personal information for cross-context behavioral advertising.

Certain privacy laws define terms such as “sell,” “share,” or “targeted advertising” broadly and may classify some website analytics, advertising technology, or third-party cookie activity as a sale or sharing even when no money is exchanged.

To the extent Nightfox Holdings engages in activity legally defined as a sale or sharing, eligible individuals may exercise the applicable opt-out right by contacting:

legal@nightfoxholdings.com

Where required by applicable law and supported by the Site’s systems, Nightfox Holdings will process recognized browser-based opt-out preference signals.

9. Data Retention

We retain personal information only for as long as reasonably necessary for the purposes described in this Privacy Policy, including to:

• Respond to communications;
• Maintain business and professional relationships;
• Evaluate and document opportunities;
• Fulfill contractual obligations;
• Maintain security and operational records;
• Meet legal, tax, accounting, insurance, and regulatory requirements;
• Resolve disputes; and
• Establish, exercise, or defend legal claims.

Retention periods may vary depending on:

• The nature and sensitivity of the information;
• The purpose for which it was collected;
• Whether a business relationship exists;
• Applicable limitation periods;
• Legal or regulatory obligations;
• The risk of harm from unauthorized use or disclosure; and
• Whether the information can be deleted, aggregated, or de-identified.

When information is no longer reasonably required, we may delete it, anonymize it, aggregate it, or securely isolate it until deletion is practicable.

10. Data Security

We use reasonable administrative, technical, and organizational safeguards designed to protect personal information against unauthorized access, destruction, loss, alteration, misuse, or disclosure.

These safeguards may include:

• Access controls;
• Authentication measures;
• Secure hosting;
• Encryption where appropriate;
• System monitoring;
• Malware protection;
• Software maintenance;
• Service-provider oversight;
• Data minimization; and
• Incident-response procedures.

The FTC recommends that businesses identify the information they hold, retain only what is needed, protect retained information, dispose of it appropriately, and prepare for security incidents.

No website, transmission, network, storage system, or security measure is completely secure. Accordingly, we cannot guarantee the absolute security of information transmitted to or maintained by us.

You should use care when transmitting confidential or sensitive information electronically.

11. International Data Transfers

Nightfox Holdings and its service providers may process or store personal information in the United States and other countries that may have privacy laws different from those in your jurisdiction.

Where required by applicable law, we use appropriate safeguards for international transfers, which may include:

• Contractual protections;
• Standard contractual clauses approved by the relevant authority;
• Transfers to jurisdictions recognized as providing adequate protection;
• Your explicit consent where legally permitted; or
• Another lawful transfer mechanism.

Regardless of where information is processed, we handle it in accordance with this Privacy Policy and applicable legal obligations.

12. Your Privacy Rights

Depending on where you reside and subject to applicable exemptions, you may have the right to:

• Request confirmation of whether we process your personal information;
• Request access to personal information we maintain about you;
• Request correction of inaccurate information;
• Request deletion of personal information;
• Request restriction of processing;
• Object to certain processing;
• Withdraw consent;
• Request a portable copy of certain information;
• Opt out of the sale or sharing of personal information;
• Opt out of targeted advertising;
• Limit certain uses of sensitive personal information;
• Request information about categories of information collected, used, or disclosed;
• Request information about categories of recipients;
• Appeal a decision relating to a privacy request; and
• Lodge a complaint with an appropriate privacy or data-protection authority.

These rights are not absolute. We may decline or limit a request where permitted by law, including when information must be retained to comply with legal obligations, complete a transaction, protect rights, maintain security, prevent fraud, or establish or defend legal claims.

The European Commission identifies rights including access, correction, erasure, restriction, portability, objection, and protections relating to certain automated decisions.

13. Exercising Your Privacy Rights

To submit a privacy request, contact:

legal@nightfoxholdings.com

Please include:

• Your name;
• The jurisdiction in which you reside;
• The nature of your request;
• The email address or other information associated with your interaction with us; and
• Sufficient detail for us to understand and evaluate the request.

We may need to verify your identity before completing a request. Verification may require confirming information already known to us or requesting additional information reasonably necessary to protect against unauthorized access or deletion.

We will use information submitted in connection with a privacy request only to verify and process that request, maintain legally required records, and protect against fraudulent requests.

Where applicable, an authorized agent may submit a request on your behalf. We may require evidence of the agent’s authority and may also require you to verify your identity directly.

We will respond within the time required by applicable law. When legally permitted, we may extend the response period and will provide notice of the extension.

14. Appeals

Where applicable law provides a right to appeal a decision regarding a privacy request, you may submit an appeal by emailing:

legal@nightfoxholdings.com

Please use the subject line:

Privacy Request Appeal

Include the original request, our response, and the reason you believe the decision should be reconsidered.

15. Nondiscrimination

Nightfox Holdings will not unlawfully discriminate against an individual for exercising an applicable privacy right.

Exercising a privacy right will not result in unlawful:

• Denial of goods or services;
• Different pricing;
• Reduced quality of service; or
• Retaliation.

Differences reasonably related to the value of information or otherwise permitted by law are not prohibited.

16. California Privacy Notice

This section supplements the remainder of this Privacy Policy for California residents.

Depending on how you interact with us, we may collect the following categories of personal information:

• Identifiers;
• Contact information;
• Internet or electronic network activity;
• Geolocation information at an approximate level;
• Professional or employment-related information;
• Commercial or transactional information;
• Communications and submitted content;
• Inferences reasonably derived from other information; and
• Other information that identifies, relates to, or could reasonably be linked with an individual or household.

We collect and use these categories for the business and commercial purposes described in this Privacy Policy.

We may disclose these categories to:

• Service providers;
• Contractors;
• Portfolio companies and affiliates;
• Professional advisers;
• Business counterparties;
• Government authorities; and
• Parties involved in a corporate transaction.

Subject to the applicability of California law and available exemptions, California residents may have the right to request access, correction, deletion, and information about collection and disclosure practices, as well as the right to opt out of a sale or sharing. California regulations govern how covered businesses provide notices, verify requests, and facilitate consumer rights.

Nightfox Holdings does not knowingly sell or share the personal information of individuals under 16 years of age.

17. European Economic Area and United Kingdom Residents

For purposes of applicable European or United Kingdom data-protection law, Nightfox Holdings LLC is generally the controller of personal information collected through the Site.

Individuals in the European Economic Area or United Kingdom may have the right to:

• Access their information;
• Correct inaccurate information;
• Request erasure;
• Restrict processing;
• Object to processing based on legitimate interests;
• Object to direct marketing;
• Receive certain information in a portable format;
• Withdraw consent; and
• File a complaint with their local supervisory authority.

You may first contact us at legal@nightfoxholdings.com so that we have an opportunity to address your concern.

The European Commission requires privacy notices to describe matters such as the controller, purposes, legal bases, recipients, retention, international transfers, rights, and complaint procedures.

18. Nevada Residents

Nightfox Holdings is based in the United States and may interact with Nevada residents.

Where Nevada law applies, an eligible Nevada consumer may submit a verified request concerning the sale of covered information by contacting:

legal@nightfoxholdings.com

Nightfox Holdings does not sell covered information for monetary consideration as that activity is ordinarily understood.

19. Do Not Track Signals

Some browsers offer a “Do Not Track” setting.

Because there is not a universally accepted technical standard for responding to Do Not Track signals, the Site may not respond to all such signals.

Where applicable law requires recognition of a legally valid opt-out preference signal, we will process that signal as required by law and to the extent supported by the Site’s systems.

20. Children’s Privacy

The Site is intended for a general business audience and is not directed to children under 13 years of age or any higher minimum age established by applicable local law.

We do not knowingly collect personal information from children through the Site.

If you believe a child has submitted personal information to us, contact legal@nightfoxholdings.com. We will review the matter and take appropriate action, including deletion where required.

The FTC’s Children’s Online Privacy Protection Act guidance emphasizes evaluating what information is collected from children, why it is needed, how long it is retained, and how it is secured and deleted.

21. External Links

The Site may contain links to websites operated by:

• Portfolio companies;
• Affiliates;
• Business partners;
• Government agencies;
• Media organizations;
• Professional platforms; and
• Other third parties.

We do not control these external websites or their privacy practices. This Privacy Policy does not apply to information collected by a third party after you leave the Site.

We encourage you to review the privacy policy of any external website you visit.

22. Embedded Content and Third-Party Features

The Site may include content or features provided by third parties, such as:

• Maps;
• Videos;
• Fonts;
• Social-media links;
• Document viewers;
• Website analytics;
• Security tools; or
• Other hosted resources.

These providers may collect technical information or place cookies when their content loads. Their handling of information is governed by their respective terms and privacy policies.

23. Email Communications

When you email Nightfox Holdings, we collect your email address, message content, attachments, and related communication information.

We use this information to:

• Respond to your message;
• Maintain records;
• Evaluate inquiries;
• Manage relationships;
• Protect our interests; and
• Comply with legal obligations.

Email is not necessarily secure. Do not send highly sensitive information by ordinary email unless appropriate safeguards have been arranged.

24. Business-to-Business Information

We may collect professional contact information concerning employees, representatives, owners, officers, advisers, and contractors of organizations with which we communicate or conduct business.

We use this information for ordinary business purposes, including:

• Communicating with the relevant organization;
• Evaluating opportunities;
• Managing contracts and relationships;
• Conducting due diligence;
• Maintaining business records; and
• Complying with legal obligations.

Where required by applicable law, business contacts may exercise the rights described in this Privacy Policy.

25. De-Identified and Aggregated Information

We may create information that has been aggregated, anonymized, or de-identified so that it cannot reasonably be associated with a particular individual.

We may use and disclose such information for lawful business purposes, including analytics, research, planning, security, reporting, and Site improvement.

Where required by law, we will maintain de-identified information in de-identified form and will not attempt to reidentify it except as legally permitted to evaluate the effectiveness of de-identification measures.

26. Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect:

• Changes to the Site;
• Changes to our information practices;
• Changes to service providers;
• Changes to our organizational structure;
• New legal or regulatory requirements; or
• Other operational developments.

The updated policy will be posted on this page with a revised “Last updated” date.

Where required by law, we will provide additional notice or request consent before applying a material change to information previously collected.

The FTC has cautioned that materially expanding the use or sharing of previously collected information without appropriate notice or consent may be unfair or deceptive.

27. Contact Nightfox Holdings

Questions, concerns, complaints, and privacy-rights requests may be directed to:

Nightfox Holdings LLC
Email: legal@nightfoxholdings.com

Please use the subject line Privacy Inquiry or Privacy Rights Request, as applicable.