Privacy Policy

Effective date: May 1, 2026  |  Cornovus Capital LLC

This Privacy Policy explains how Cornovus Capital LLC ("Cornovus Capital," "we," "us," or "our") collects, uses, shares, and protects information in connection with your use of CornovusCapital.com and our commercial advisory services (collectively, the "Website" or "Services"). It applies to business owners, investors, developers, referral partners, and other professionals who interact with Cornovus Capital. Cornovus Capital operates as a commercial finance advisory firm and does not provide consumer credit products. This Policy is designed to meet U.S. requirements and, where applicable, the rights of individuals under laws such as the EU/UK GDPR and certain U.S. state privacy laws (e.g., CCPA/CPRA). By using the Website or submitting information, you consent to the practices described in this Policy.

1. Information We Collect

We collect information to respond to inquiries, evaluate potential transactions, and operate our advisory platform. The categories of information we may collect include:

• Contact and business information: Name, job title, company name, email address, phone number, mailing address, and information about your business or project.
• Transaction and financing information: Property details, financial statements, rent rolls, operating histories, loan balances, capital stack details, corporate structures, and related documents that you or your representatives provide.
• Communication records: Emails, call notes, meeting summaries, and other communications with Cornovus Capital.
• Technical and usage data: IP address, device identifiers, browser type, operating system, pages viewed, referring URLs, approximate location, and timestamps, collected via server logs and analytics tools.
• Cookie and tracking data: Information from cookies, pixels, tags, and similar technologies used to understand Website performance and improve user experience.
• Third-party and public sources: Information from third-party data providers (such as commercial real estate databases, hospitality performance platforms, and public records) related to markets, properties, or businesses you are involved with. This typically does not include sensitive personal data.

We do not intentionally collect sensitive personal data (such as government ID numbers, health information, or information about political views, religion, or biometric data). If you provide such information in a financing submission or communication, we will use it only for the purpose for which it was provided and will handle it with appropriate care.

2. How We Use Your Information

We use the information we collect for the following purposes:

• To respond to inquiries and evaluate whether a transaction or engagement is appropriate for our advisory platform.
• To structure, underwrite, and coordinate commercial financing solutions on your behalf.
• To communicate with you about your financing request, transaction status, market conditions, or other advisory matters.
• To operate, maintain, and improve the Website and our advisory technology platform.
• To send educational content, market reports, and advisory communications, where you have opted in or where we have a legitimate interest in doing so.
• To comply with applicable laws, regulations, and legal obligations, including responding to lawful requests from regulators or law enforcement.
• To protect against fraud, unauthorized access, or misuse of our Website or services.
• To enforce our Terms of Use and protect the rights, property, and safety of Cornovus Capital and others.

We do not sell, rent, or trade your personal information to third parties for their own marketing purposes.

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

If you are located in the European Economic Area or United Kingdom, we rely on the following legal bases to process your personal data:

• Contract: Processing is necessary to fulfill a request or transaction you have initiated or expressed interest in.
• Legitimate interests: We have a legitimate interest in operating and improving our advisory platform, communicating with prospects and clients, and protecting our business, provided those interests are not overridden by your rights.
• Consent: Where we rely on consent (for example, for marketing communications), you may withdraw it at any time.
• Legal obligation: We may process data to comply with applicable laws, regulations, or court orders.

4. How We Share Your Information

We do not sell your personal information. We may share information in the following circumstances:

• With capital partners and lenders: When you engage Cornovus Capital to structure a financing transaction, we may share relevant transaction details, financial information, and business documents with potential capital sources, lenders, or institutional investors as part of the placement process. We share only what is necessary to evaluate or process your transaction.
• With service providers: We work with third-party vendors who perform services on our behalf, including technology hosting, CRM platforms, email communications, analytics, and document management. These vendors are bound by confidentiality obligations and may not use your information for their own purposes.
• With professional advisors: We may share information with attorneys, accountants, or other professionals engaged in connection with a transaction or legal matter.
• For legal compliance: We may disclose information when required by law, regulation, legal process, or government authority, or when we believe disclosure is necessary to protect our rights, your safety, or the safety of others.
• In connection with a business transfer: If Cornovus Capital is involved in a merger, acquisition, asset sale, or restructuring, your information may be transferred as part of that transaction, subject to confidentiality obligations.

5. Cookies, Analytics, and Tracking Technologies

We use cookies and similar tracking technologies to understand how visitors interact with our Website, measure performance, and improve user experience. These may include:

• Essential cookies: Required for the Website to function properly. These cannot be disabled.
• Analytics cookies: Used to measure traffic, page views, and user behavior. We use tools such as Google Analytics to understand how visitors use our Website.
• Marketing and retargeting cookies: Used to display relevant advertising on third-party platforms to visitors who have previously visited our Website.

You may manage cookie preferences through your browser settings or through cookie consent tools presented on the Website. Disabling certain cookies may affect Website functionality.

6. Advertising, Retargeting, and CRM Integrations

Cornovus Capital may use advertising platforms (such as Google Ads or LinkedIn Ads) and CRM integrations to reach prospective clients and track the performance of our marketing efforts. These platforms may use cookies, pixels, or other identifiers to build audience segments. We do not share personal financing or transaction information with advertising platforms. If you prefer not to receive targeted advertising, you may opt out through the applicable platform's privacy settings or industry opt-out tools such as the Digital Advertising Alliance (DAA) at optout.aboutads.info.

7. AI, Automation, and Limited Profiling

Cornovus Capital may use artificial intelligence tools to support content development, market research, preliminary document analysis, and internal workflows. All content and advisory recommendations generated or assisted by AI tools are reviewed by principals before use or distribution. We do not make binding credit decisions, issue loan commitments, or determine eligibility for financing through fully automated processes. Any AI-assisted analysis is used as a supplemental input, not a substitute for human judgment in advisory and underwriting decisions.

We do not engage in automated decision-making that produces legal or similarly significant effects on individuals without human review.

8. Data Retention

We retain personal information for as long as necessary to fulfill the purposes described in this Policy, including to maintain business records, comply with legal obligations, resolve disputes, and enforce our agreements. Transaction-related information may be retained for a period consistent with applicable legal, regulatory, and professional standards. When information is no longer needed, we take reasonable steps to delete or de-identify it.

9. International Visitors and Data Transfers

Cornovus Capital is based in the United States. If you are accessing our Website from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States, where data protection laws may differ from those in your jurisdiction. By using the Website, you consent to the transfer of your information to the United States. Where required, we implement appropriate safeguards for international transfers, such as standard contractual clauses.

10. Your Rights and Choices

Depending on your location and applicable law, you may have the following rights with respect to your personal information:

• Access: Request a copy of the personal information we hold about you.
• Correction: Request correction of inaccurate or incomplete information.
• Deletion: Request deletion of your personal information, subject to legal retention requirements.
• Portability: Request transfer of your personal information to another organization, where technically feasible.
• Objection or restriction: Object to or request restriction of certain processing activities.
• Opt-out of marketing: Unsubscribe from marketing communications at any time using the unsubscribe link in any email or by contacting us directly.
• CCPA/CPRA rights (California residents): You have the right to know what personal information is collected, to opt out of the sale or sharing of personal information (we do not sell or share personal information), to request deletion, and to non-discrimination for exercising these rights.

To exercise any of these rights, contact us at info@cornovuscapital.com. We will respond within the timeframe required by applicable law.

11. Children's Privacy

Our Website and services are directed exclusively to business professionals and are not intended for individuals under the age of 18. We do not knowingly collect personal information from children. If we become aware that we have inadvertently collected information from a minor, we will take steps to delete it promptly.

12. Data Security

We implement reasonable and appropriate technical and organizational measures to protect personal information against unauthorized access, disclosure, alteration, or destruction. These measures include encrypted transmission of data, access controls, and vendor security requirements. However, no method of transmission over the internet or electronic storage is completely secure. We cannot guarantee absolute security and encourage you to use caution when transmitting sensitive information electronically.

13. Third-Party Websites and Services

Our Website may contain links to third-party websites, platforms, or services that are not operated or controlled by Cornovus Capital. This Privacy Policy does not apply to those third-party sites. We encourage you to review the privacy policies of any third-party sites you visit. Cornovus Capital is not responsible for the privacy practices or content of third-party websites.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or operational needs. When we make material changes, we will update the effective date at the top of this Policy. We encourage you to review this Policy periodically. Your continued use of the Website following any update constitutes your acceptance of the revised Policy.

15. Contact Cornovus Capital

If you have questions, concerns, or requests regarding this Privacy Policy or how we handle your information, please contact us:

• Email: info@cornovuscapital.com
• Phone: 513-653-4246
• Mail: Cornovus Capital LLC, 10260 Alliance Road, Suite 200, Cincinnati, OH 45242