Privacy policy.

This Privacy Policy describes how Fundviews Capital LLC ("Fundviews," "we," "our," or "us"), a Florida limited liability company registered as an Exempt Reporting Adviser with the U.S. Securities and Exchange Commission, collects, uses, discloses, and safeguards information about you.

It covers two related but distinct relationships:

• Part 1 — Website Privacy Notice, which applies to anyone who visits fundviewscapital.com, uses the public pricing calculator, submits a launch-plan intake, subscribes to our insights newsletter, or otherwise interacts with our public-facing properties.
• Part 2 — Advisory Client Privacy Notice (Regulation S-P / GLBA), which applies to clients of Fundviews' investment-adviser business under Title V of the Gramm-Leach-Bliley Act and SEC Regulation S-P (17 CFR §§ 248.1–248.30).

If a section conflicts between Part 1 and Part 2, the section that more specifically addresses your relationship with Fundviews controls.

Fundviews is committed to safeguarding the confidentiality, integrity, and security of personal information entrusted to us. We do not sell personal information.

Part 1 — Website Privacy Notice

1.1 Scope

This Part 1 applies to information collected through our public website at fundviewscapital.com (the "Site") and any web-based intake or contact form we host (collectively, the "Site Services"). It does not apply to the Fundviews client portal at portal.fundviewscapital.com, which is governed by separate client engagement terms and the WISP referenced in Section 4.

1.2 Information we collect

We collect information you provide directly, information collected automatically when you use the Site, and information from limited third-party sources.

Information you provide directly. When you fill out a form on the Site — the launch-plan intake, the pricing calculator's "save and email me my results" flow, the newsletter signup, or the contact form — we collect the information you give us. Depending on the form, that may include your name, firm name, email address, phone number, role, the strategy and structure information you enter into the calculator or intake, and any free-text notes you choose to share.

Information collected automatically. When you visit the Site we receive limited technical information from your browser, including IP address, approximate location derived from IP, browser type and version, device type, referring URL, pages visited, time spent, and similar usage data. We use this to operate, secure, and improve the Site.

Cookies and similar technologies. The Site uses a small number of cookies and equivalent storage mechanisms, including (a) strictly necessary cookies that keep the Site functioning and (b) analytics cookies that help us understand how visitors interact with the Site so we can improve it. We do not use cookies for cross-site advertising or for joint marketing with third parties. You can disable non-essential cookies at any time through your browser settings; doing so may degrade some Site functionality but will not prevent the Site from loading.

Information from third parties. If you book a meeting through our scheduling tool (Front) or submit a form that integrates with a third-party service, we may receive your name, email, and meeting details from that service. If you contact us through LinkedIn or another social channel, we may receive whatever profile information that platform makes available to us in the ordinary course.

1.3 How we use information

We use information collected through the Site to:

• Respond to your inquiry, send you the materials you requested, and prepare a Launch Plan, pricing estimate, or follow-up materials;
• Operate, maintain, secure, and improve the Site;
• Send our monthly insights newsletter, if you subscribed, and let you unsubscribe at any time using the link in any newsletter email;
• Comply with applicable law, respond to lawful requests from regulators and courts, enforce our agreements, and protect Fundviews and others;
• Manage our internal sales pipeline and CRM records, including notes on conversations and prospect status.

1.4 AI-assisted Launch Plan drafts

When you submit a Launch Plan intake on the Site, your responses are processed in two ways. First, the intake answers are sent to our business development inbox so a Fundviews team member can review them. Second, your intake answers are sent to Anthropic PBC ("Anthropic"), the operator of the Claude AI service, which generates an internal draft of a Launch Plan from your responses based on a Fundviews-authored prompt and template.

The AI-generated draft is delivered to Fundviews staff only. It is not sent to you automatically. A Fundviews team member reviews and edits the draft before deciding whether to send anything to you. The AI does not provide legal, tax, accounting, or investment advice. Pricing references in any AI-generated draft are preliminary and are confirmed independently before being shared with you.

Per Anthropic's standard API terms, Anthropic does not use API submissions to train Anthropic's models by default. Your intake answers and the resulting draft are stored in our Supabase database (see Section 1.6) so we can audit the draft, regenerate if needed, and respond to your follow-up questions.

If you would prefer that your intake not be processed by an AI service, email bd@fundviewscapital.com before submitting and we will accept your intake by email and prepare the plan manually.

1.5 How we share information

We share information with limited categories of recipients, only for the purposes described in this Notice and only where the recipient is bound by appropriate contractual confidentiality and security obligations.

• Service providers. We share information with vendors that help us run the Site and our business — listed in Section 1.6.
• Professional advisers. We may share information with our legal counsel (including Riveles Wahab LLP, our default counsel), our accountants, and our auditors, where reasonably necessary in connection with their services to Fundviews.
• Legal compliance and protection. We may share information when we believe in good faith that disclosure is necessary to comply with applicable law, respond to a lawful request from a government authority or court, enforce our agreements, or protect the rights, property, or safety of Fundviews, our clients, or others.
• Business transactions. If Fundviews is involved in a merger, acquisition, financing, reorganization, or sale of assets, information may be shared with the counterparties and their advisers, subject to customary confidentiality protections.

We do not sell personal information to third parties, and we do not participate in joint marketing arrangements that share your personal information.

1.6 Third-party service providers

The following service providers process information collected through the Site on our behalf, under contractual confidentiality and security obligations. The list is current as of the "Last Updated" date and may change; the most recent list is the one published on this page.

If we add or replace a material data processor, we will update this list and, where required by law, notify you. We require all of the providers above to implement reasonable administrative, technical, and physical safeguards appropriate to the sensitivity of the information processed.

1.7 Data retention

We retain information collected through the Site for as long as reasonably necessary to operate the Site, respond to your inquiry, run our sales pipeline, comply with our regulatory record-keeping obligations under the Investment Advisers Act of 1940 and SEC rules thereunder, and resolve disputes. Different categories of data have different retention periods: for example, our pipeline and CRM records are retained for as long as the relationship is active and for a reasonable period thereafter; technical and analytics logs are retained for a shorter period; AI-generated Launch Plan drafts are retained until they are obsolete or you ask us to delete them.

1.8 Your rights and choices

You can:

• Unsubscribe from our newsletter at any time using the link in any newsletter email or by emailing compliance@fundviewscapital.com.
• Request access, correction, or deletion of personal information about you that we hold, subject to applicable law and Fundviews' regulatory record-keeping obligations.
• Object to or restrict certain uses of your information.
• Opt out of having your Launch Plan intake processed by an AI service, as described in Section 1.4.

To exercise any of these rights, email compliance@fundviewscapital.com. We will respond within the period required by applicable law. We may need to verify your identity before fulfilling certain requests.

State-specific rights. Residents of certain U.S. states (including California, Colorado, Connecticut, Virginia, and Utah, among others) may have additional rights under state privacy laws, including the right to know what personal information we collect, the right to delete, the right to correct, the right to opt out of "sales" or "sharing" (we do not sell or share for cross-context behavioral advertising), and the right to non-discrimination. To exercise these rights, email compliance@fundviewscapital.com. Fundviews has not "sold" personal information of California residents in the preceding 12 months.

1.9 International users

The Site is operated in the United States. If you access the Site from outside the United States, your information will be transferred to, stored, and processed in the United States. By using the Site you consent to that transfer.

1.10 Children

The Site is not directed at children under 18 and we do not knowingly collect personal information from children. If you believe we have collected personal information from a child, contact us at compliance@fundviewscapital.com and we will delete it.

1.11 Security

We maintain administrative, technical, and physical safeguards designed to protect personal information. Our safeguards are described in Fundviews' Written Information Security Program (WISP), which is updated periodically and incorporated by reference. Highlights include encrypted transport (HTTPS), encryption at rest for sensitive data stores, role-based access controls, service-role-only database policies for the Site database, and incident response procedures. No method of transmission over the internet or electronic storage is fully secure, and we cannot guarantee absolute security.

Part 2 — Advisory Client Privacy Notice (Reg S-P / GLBA)

This Part 2 applies to clients of Fundviews' investment-adviser business and is provided pursuant to Title V of the Gramm-Leach-Bliley Act and SEC Regulation S-P (17 CFR §§ 248.1–248.30). It supersedes prior versions of our client privacy notice, including the version dated July 2024.

2.1 Our commitment

We are committed to safeguarding the use of nonpublic personal information ("NPI") about our clients. We protect the security and confidentiality of NPI we have collected and make efforts to ensure that it is used for proper business purposes in connection with the management or servicing of your account.

We do not sell NPI to anyone. We do not provide NPI to others except for discrete and proper business purposes in connection with the servicing and management of your account, as described below.

2.2 Definitions

• Affiliates — companies related by common ownership or control. We do not share NPI with affiliates except as described in this Notice.
• Non-affiliates — companies not related by common ownership or control. We do not share NPI with non-affiliates except as described in this Notice.
• Joint marketing — a formal agreement between non-affiliated financial companies that together market financial products or services to you. We do not engage in joint marketing.

2.3 NPI we collect

In conducting our advisory business we collect, or may collect, the following categories of NPI:

• Information you provide. Information you provide in connection with any securities account or other financial product or service, such as name, address, social security number, tax ID, assets, income, investment objectives, financial situation, and beneficial ownership information — obtained in writing, in person, by telephone, electronically, or by other means; and information collected for the purpose of tax reporting, including disclosures on IRS forms.
• Information about your transactions. Information relating to account balances, payment history, trading activity, capital calls and distributions, and other transactions in respect of which we provide advisory or operational services; and information collected as part of servicing your account(s).
• Information from non-affiliated third parties. Information from fund administrators, custodians, auditors, tax preparers, and other service providers as needed to provide our services; and information received pursuant to law, rule, regulation, standard industry practice, or legal process, including information shared in response to a subpoena or other legal process.

2.4 NPI we share

We share NPI with affiliates and non-affiliated third parties only in connection with providing advisory or operational services or otherwise conducting our business. Such disclosures may include:

• Disclosures to service providers — fund administrators, custodians, auditors, tax preparers, banks, KYC/AML vendors, IT vendors, and similar — who supply us with services that require access to NPI to perform;
• Disclosures to securities clearing agencies, transfer agents, and similar entities involved in the processing of transactions;
• Disclosures required by law, rule, regulation, or legal process; and
• Disclosures made with your consent.

2.5 Former customers

We disclose NPI about former clients only as permitted or required by law or legal process, or with the former client's consent.

2.6 When you can limit sharing

Federal law gives you the right to limit the sharing of your NPI when (i) the sharing is for affiliates' everyday business purposes, (ii) the sharing is done to allow affiliates to market to you, or (iii) the sharing is done to allow non-affiliates to market to you. We do not share NPI in any of these ways. State laws and individual companies may give you additional rights to limit sharing.

2.7 Confidentiality and security

We are committed to implementing and maintaining commercially reasonable and appropriate measures to maintain NPI in a secure and confidential fashion. Our information security procedures are described in Fundviews' WISP and include, without limitation:

• Access controls on customer information systems, including authentication and access controls limited to authorized personnel, and controls designed to prevent disclosure of NPI to unauthorized persons obtaining it through fraudulent means;
• Encryption in transit (TLS) and at rest where appropriate or feasible, including encryption on company-managed devices;
• Multi-factor authentication on cloud-software accounts that hold NPI;
• Segregation of duties for personnel whose responsibilities require access to NPI;
• Documented vendor due-diligence and contractual confidentiality and security obligations on third-party service providers, including the cloud providers used to operate the Site (see Section 1.6);
• Incident response procedures, including escalation, containment, notification, and post-incident review; and
• A disaster recovery plan to protect against loss or damage to NPI from hazards including fire, water damage, and technological interruption or failure.

We periodically review, revise, and update our information security procedures to reflect changes in technology, the regulatory environment, and operational risk.

2.8 Maintenance of records

NPI about you is retained during the time you are a client and for the required time thereafter under applicable federal and state securities laws and SEC books-and-records rules. After the required period of record retention, NPI is destroyed using methods designed to render it non-recoverable.

2.9 Notice to clients

We will provide notice of this Privacy Policy at least annually for as long as you maintain an ongoing client relationship with us. We may revise this Notice periodically and will provide a revised Notice if changes materially alter the prior version. We will not revise this Notice to permit sharing of NPI other than as described here without first notifying you and providing an opportunity to prevent the new sharing.

2.10 Opting out

Section 502(a) of the Gramm-Leach-Bliley Act generally prohibits a financial institution from sharing NPI with non-affiliated third parties unless the institution (i) provides a notice of its privacy policies, (ii) provides clear and conspicuous notice that NPI may be disclosed to non-affiliates, (iii) gives the consumer an opportunity to opt out, and (iv) informs the consumer how to opt out.

You may opt out of permitted sharing of your NPI with non-affiliated third parties by sending a written request to Fundviews at the address below. We will retain the opt-out on file for as long as your account is open. If you leave Fundviews and later return as a client, a new opt-out will be required.

Part 3 — Common provisions

3.1 Changes to this Policy

We may update this Privacy Policy from time to time. The "Last Updated" date at the top of the page indicates when this version was published. Material changes will be communicated by email (for advisory clients) or by a notice on the Site (for visitors). Your continued use of the Site after a change becomes effective constitutes acceptance of the updated Privacy Policy.

3.2 Contact

For questions, requests, or to exercise any of the rights described above, contact our Chief Compliance Officer:

• By email: compliance@fundviewscapital.com
• By phone: (305) 846-9175
• By mail: Fundviews Capital LLC, Attn: Chief Compliance Officer, 3785 NW 82nd Ave, Suite #304, Doral, FL 33166

We will respond to your request within the period required by applicable law. For requests under U.S. state privacy laws, we may need to verify your identity before responding.