Privacy Policy and Terms of Use

Part One: Privacy Policy

1. About This Policy

This Privacy Policy describes how JBB Equity Management, LLC, a Puerto Rico limited liability company ("JBBEM," "we," "us," or "our"), collects, uses, and discloses information when you visit jbbem.com (the "Site") or otherwise interact with us through the channels described below.

By using the Site, you agree to the practices described in this Policy. If you do not agree, please do not use the Site.

2. Who We Are

JBB Equity Management, LLC PMB 402, 425 CARR 693, STE 1 Dorado, PR 00646 Email: [email protected]

For purposes of the European Union General Data Protection Regulation ("GDPR"), JBBEM is the data controller for personal information collected through the Site.

3. Information We Collect

We collect the following categories of information:

Information you provide directly. When you fill out a contact form, subscribe to our newsletter, request portfolio materials, schedule a call, or otherwise communicate with us, you may provide your first and last name, email address, phone number, mailing address, employer or affiliation, accreditation status, and any message content you choose to send. No mobile information will be shared with third parties/affiliates for marketing or promotional purposes. All categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

Information collected automatically. When you visit the Site, we (or our service providers) may collect information about your device and browsing activity, including your IP address, browser type, operating system, referring URL, pages viewed, time and date of visits, and general location inferred from your IP address. We may collect this information through cookies, pixels, server logs, and similar technologies, including (currently or in the future) Google Analytics, Meta, LinkedIn Insight Tag, HubSpot, Go High Level (HighLevel), and similar analytics, CRM, and marketing automation platforms.

Information from third parties. We may receive information about you from publicly available sources, business partners, co-investors, accreditation verification services, payment processors, and our affiliates, including Acumen Development Partners and other operating entities under common ownership or control.

4. How We Use Your Information

We use the information we collect to:

•       respond to your inquiries and provide requested materials;

•       communicate with you about investment opportunities, projects, events, and updates;

•       send newsletters and marketing communications you have opted to receive;

•       verify accredited investor status when required by applicable securities laws;

•       operate, maintain, secure, and improve the Site;

•       analyze Site traffic and user behavior to refine our content and offerings;

•       comply with legal obligations, including tax, anti-money laundering, sanctions, and securities laws;

•       detect, prevent, and investigate fraud, abuse, or unauthorized activity; and

•       exercise or defend legal claims.

5. Legal Bases for Processing (GDPR)

If you are located in the European Economic Area or the United Kingdom, we process your personal information under one or more of the following legal bases:

Consent, where you have given clear consent (for example, opting into our newsletter);

Contract, where processing is necessary to take steps at your request before entering into a contract or to perform a contract with you;

Legitimate interests, including operating our business, communicating with prospective and existing investors, securing the Site, and informing potential investors about opportunities, provided those interests are not overridden by your rights; and

Legal obligation, where we are required to process information to comply with applicable law.

6. How We Share Information

We do not sell your personal information. We have not sold personal information in the past twelve months and have no intention of doing so.

We share personal information only as follows:

Service providers. With vendors who perform services for us under written agreements that restrict their use of the information, including email and CRM platforms (currently HubSpot and Go High Level), hosting providers, analytics providers, professional advisors, accreditation verification services, and payment processors.

Affiliates and operating entities. With our parent, subsidiary, and affiliated entities (including Acumen Development Partners and project-specific sponsor entities) for the purposes described in this Policy.

Co-investors and partners. In connection with a specific investment opportunity, with co-sponsors, lenders, joint venture partners, brokers, and counsel, on a need-to-know basis.

Legal and safety reasons. When we believe disclosure is necessary to comply with law or legal process, respond to lawful requests from public authorities, enforce our terms, protect our rights or property, or protect the safety of our investors, employees, or the public.

Corporate transactions. In connection with a merger, acquisition, financing, reorganization, sale of assets, or similar transaction involving JBBEM or any of its affiliates.

With your consent. For any other purpose disclosed to you at the time we collect the information or with your separate consent.

7. Cookies and Tracking Technologies

The Site may use cookies, web beacons, pixels, and similar technologies to operate the Site, remember your preferences, measure traffic, and (in the future) deliver targeted advertising. You can control cookies through your browser settings, but disabling cookies may affect Site functionality.

We do not currently respond to "Do Not Track" browser signals because no common industry standard has been adopted.

8. Data Retention

We retain personal information for as long as necessary to fulfill the purposes described in this Policy, comply with our legal obligations, resolve disputes, and enforce our agreements. Retention periods vary based on the nature of the information and the reason it was collected. When we no longer need the information, we will delete, anonymize, or securely destroy it.

9. Security

We use reasonable administrative, technical, and physical safeguards designed to protect personal information against loss, theft, misuse, and unauthorized access. No method of transmission over the internet or electronic storage is fully secure, however, and we cannot guarantee absolute security.

10. Your Choices

You can:

•       unsubscribe from our marketing emails using the link in any message we send;

•       ask us to update or correct information you have provided;

•       ask us to delete information we hold about you, subject to legal exceptions;

•       restrict your browser's use of cookies; and

•       decline to provide information, understanding that some Site features may not be available without it.

11. GDPR Rights (Residents of the EEA, UK, and Switzerland)

If you are in the European Economic Area, the United Kingdom, or Switzerland, you have the right to:

•       access the personal information we hold about you;

•       request correction of inaccurate or incomplete information;

•       request erasure of your information;

•       object to or restrict our processing of your information;

•       request portability of information you have provided to us;

•       withdraw consent at any time, without affecting the lawfulness of prior processing; and

•       lodge a complaint with your local data protection authority.

To exercise these rights, contact us at [email protected]. We may need to verify your identity before responding.

12. CCPA Rights (California Residents)

If you are a California resident, the California Consumer Privacy Act ("CCPA"), as amended by the CPRA, gives you the right to:

•       know what categories of personal information we collect, the sources of that information, the purposes for collection, and the categories of third parties with whom we share it;

•       request a copy of the specific pieces of personal information we have collected about you in the past twelve months;

•       request deletion of your personal information, subject to legal exceptions;

•       correct inaccurate personal information;

•       opt out of the "sale" or "sharing" of personal information for cross-context behavioral advertising (we do not sell personal information, and we do not currently share it in a way that would qualify as "sharing" under the CCPA); and

•       be free from discrimination for exercising your CCPA rights.

To exercise these rights, contact us at [email protected]. We will verify your request before responding, generally by asking you to confirm information we already hold. You may designate an authorized agent to act on your behalf with written authorization.

13. International Data Transfers

We are located in Puerto Rico and the United States. If you access the Site from outside the United States, you understand that your information will be transferred to, stored in, and processed in the United States and other jurisdictions where our service providers operate. Data protection laws in those jurisdictions may differ from those in your country.

14. Children

The Site is not directed to children, and we do not knowingly collect personal information from anyone under the age of 18. If you believe a child has provided us with personal information, please contact us at [email protected] and we will take steps to delete it.

15. Third-Party Sites

The Site contains links to third-party sites, including Homebase (the investor portal), our newsletter platform (subscribe.rogerking.com), Instagram, YouTube, and LinkedIn. We are not responsible for the privacy practices of those sites. Please review their policies before providing information.

16. Changes to This Policy

We may update this Policy from time to time. When we do, we will post the revised version on this page and update the "Last Updated" date. If changes are material, we will provide additional notice (for example, by email or a notice on the Site). Your continued use of the Site after the changes take effect means you accept the updated Policy.

17. Contact Us

Questions, requests, or complaints about this Policy or our handling of your information should be directed to:

JBB Equity Management, LLC PMB 402, 425 CARR 693, STE 1 Dorado, PR 00646 [email protected]