Privacy Policy

1. INTRODUCTION & SCOPE Rodeo Capital Technologies Inc. ("Rodeo Capital", "We", "Our", or "Us") is committed to safeguarding the privacy and financial confidentiality of our investors, ranch operators, and platform visitors. This Privacy Policy outlines our practices regarding the collection, encryption, use, disclosure, and protection of personal and financial information across our website and investment portal. 2. CATEGORIES OF INFORMATION WE COLLECT To provide institutional livestock syndication services and satisfy federal regulatory compliance mandates, we collect the following categories of data: (a) Personal Identification Information: Legal full name, date of birth, residential and mailing address, phone number, email address, Social Security Number (SSN), Individual Taxpayer Identification Number (ITIN), or Employer Identification Number (EIN). (b) Government Documentation & Biometric Verification: Government-issued photo identification (passport, driver's license, or national identity card) and real-time biometric facial scans processed through our accredited identity verification partner (Persona / Stripe Identity) to prevent identity theft. (c) Financial & Accreditation Records: Bank account details (account and routing numbers), annual income statements (W-2s, 1099s), tax returns, CPA/broker-dealer accreditation letters, net worth verification schedules, and transaction receipts. (d) Technical & Telemetry Data: IP address, device fingerprints, operating system, browser specifications, login timestamps, and session activity logs recorded for fraud prevention and audit compliance. 3. STATUTORY LEGAL BASES & USE OF INFORMATION We process your personal information strictly for legitimate commercial and statutory compliance purposes, including: (a) Regulatory Mandates: Satisfying mandatory Customer Due Diligence (CDD), Bank Secrecy Act (BSA), FinCEN regulations, and OFAC sanctions list verifications; (b) Securities Qualification: Complying with SEC Regulation D Rule 506(c) verification obligations requiring reasonable steps to verify accredited investor status; (c) Transaction Execution: Facilitating custodial bank escrow transfers, issuing fractional livestock title units, and crediting quarterly cash yield disbursements; (d) Livestock Telemetry: Delivering real-time certified scale tickets, electronic RFID pasture logs, and veterinary health audit updates to your investor portal; (e) Tax Reporting: Compiling and delivering annual IRS Schedule K-1 or Form 1099 statements. 4. WE DO NOT SELL YOUR PERSONAL INFORMATION Rodeo Capital has never sold, rented, leased, or monetized personal, financial, or biometric data to third-party data brokers, marketers, or advertisers. We will never do so. 5. AUTHORIZED THIRD-PARTY DISCLOSURES We share your information solely with essential service providers bound by strict confidentiality and data protection covenants: (a) Qualified Escrow & Banking Partners: Evolve Bank & Trust / Plaid for processing secure ACH deposits and distribution disbursements; (b) Identity & Accreditation Verifiers: Third-party verification providers operating under SOC-2 Type II protocols to authenticate credentials; (c) State Brand & Agricultural Authorities: State brand inspection boards and county livestock registrars for verifying legal ownership title; (d) Independent Tax & Audit Professionals: Licensed certified public accountants and legal counsel assisting with annual fund accounting; (e) Legal & Regulatory Authorities: When required by subpoena, court order, or federal regulatory mandate. 6. DATA SECURITY & CRYPTOGRAPHIC STANDARDS We implement institutional cybersecurity defenses to protect your sensitive records: (a) Encryption in Transit: All data transmitted between your browser and our servers is secured using Transport Layer Security (TLS 1.3); (b) Encryption at Rest: All biometric records, tax identification numbers, and banking details are encrypted using Advanced Encryption Standard (AES-256); (c) Access Controls: Principle of least privilege enforced via multi-factor authentication (MFA) and automated session timeout controls; (d) Immutable Audit Trails: Key actions (identity verification, terms acceptance, distribution approvals) generate tamper-evident audit records. 7. DATA RETENTION POLICY In compliance with federal securities, banking, and anti-money laundering regulations, Rodeo Capital is statutorily required to retain investor identification records, accreditation documentation, and transaction histories for a minimum of seven (7) years following the closure of your account or the liquidation of your last active syndicate. After the mandatory retention period expires, data is securely destroyed in accordance with NIST 800-88 guidelines. 8. YOUR STATUTORY PRIVACY RIGHTS Depending on your state of residence (including California under CCPA/CPRA, Texas under TDPSA, and other applicable state statutes), you may possess specific rights regarding your personal information: (a) Right to Know: You may request disclosure of the specific categories and pieces of personal data we have collected about you; (b) Right to Correct: You may request correction of inaccurate personal or banking data in your profile; (c) Right to Delete: You may request deletion of your personal information, subject to our statutory record retention obligations under federal banking and securities laws; (d) Non-Discrimination: We will never discriminate against you for exercising your lawful privacy rights. To exercise these rights, submit a written inquiry to our compliance officer at privacy@rodeocapitaltradingsi.com. We verify all requests using your registered credentials before processing. 9. COOKIES & TRACKING TECHNOLOGIES We use essential session cookies strictly necessary to maintain authenticated login sessions, CSRF security tokens, and user preferences. We do not use third-party behavioral advertising cookies or cross-site tracking pixels. 10. POLICY UPDATES AND CONTACT We may revise this Privacy Policy periodically to reflect technological, operational, or legal developments. When material changes occur, we will update the version number and notify registered users via email. For inquiries regarding our privacy standards, contact: Rodeo Capital Technologies Inc. Attn: Chief Compliance Officer Email: privacy@rodeocapitaltradingsi.com Website: https://rodeocapitaltradingsi.com Address: Austin, Texas, United States