Omaha Beach Capital, LLC, headquartered in Aventura, Florida (together with its affiliates, “Omaha Beach Capital”, “we,” “us,” or “our,”) is committed to protecting your privacy. This Privacy Policy will provide you with information about how Omaha Beach Capital treats your personal data. It also describes the choices available to you regarding our use of your personal data and how you can access and update this information.

When you use this website, you consent to the use of your personal data by Omaha Beach Capital as outlined in this Privacy Policy. This Privacy Policy is subject to change. Use of this website after the policy is updated indicates your consent to any changed terms.

This Privacy Policy will explain:

• What personal data we collect
• Why we collect your personal data and the legal basis for processing
• Legal bases for processing your personal data
• How we disclose your personal data
• How we protect your personal data
• How long we keep your personal data
• Your rights with regard to your personal data
• Additional information for California residents
• Exclusions
• Questions or complaints about the privacy policy

1. What personal data we collect

Categories of personal data collected: Omaha Beach Capital collects the following categories of personal data:

• Identifiers: name, residential or business address, telephone number, nationality, tax identification number or passport number, date of birth, place of birth, photographs, and copies of identification documents.
• Customer records: bank account details, information about assets or net worth, credit history, signature.
• Commercial information: information on investment activities, information when you contact us with inquiries.
• Internet or other electronic network activity: browsing history, search history, and information regarding a consumer’s interaction with our website.
• Unique personal identifier: customer number, cookies, IP address, device identifier.
• Special categories of personal data (Sensitive Personal Data), where relevant: information on criminal convictions.

Sources of personal data: Omaha Beach Capital may collect these categories of personal data about you from the following sources:

• Information that you provide: When you sign up for services or otherwise engage with us, you voluntarily provide personal data, either directly or indirectly through a representative. By voluntarily providing us with this data, you are consenting to our use of it in accordance with this Privacy Policy. If you provide such data, you acknowledge and agree that it may be transferred from your current location to the offices and servers of Omaha Beach Capital and authorized third parties located in the United States.
• Information from other sources: We may also collect personal data about you from another source, for example from an acquaintance of yours, your representative, an expert, or a publicly available source. If you provide personal data to us about someone else (such as one of your employees or business associates), you acknowledge that you are authorized to disclose that information to us as if it were disclosed to us directly by such other person.
• Automated collection: In operating this website, we use “cookies” and other technologies to automatically collect certain information. A cookie is a small text file that is stored by your web browser when you access our website. Cookies help provide additional functionality to the website and help us analyze website usage more accurately. Most browsers accept cookies automatically, but can be configured not to accept them or to indicate when a cookie is being sent. You can manage or disable cookies at any time by adjusting your browser settings, though we recommend that you leave cookies turned on because they allow you to take advantage of some of the website’s features. Please view our Cookie Policy for more information on the types of cookies or other automated technologies we use on this website and how you may manage or disable them.

Information about children: We do not direct our services or our website to children or individuals under eighteen (18) years of age. Individuals under eighteen (18) should consult with their parent or guardian about the use of this website for their benefit.

2. Why we collect your personal data and the legal basis for processing

We collect your personal data for the following purposes:

Services: We collect your personal data so that we may provide our services to you. This includes providing you with information about our services, communicating with you about those services, performing a contract with you, enhancing the services we offer, performing administrative functions related to the services, or other activities related to the provision of services.

Marketing: We may collect your personal data for direct marketing based on your consent. You have the option to withdraw your consent at any time. We also may process information collected through cookies, such as your location data, IP address, and content viewed on our website, for marketing purposes. You can manage or disable cookies at any time by adjusting your browser settings.

Research: Your personal data may be used for research on usage patterns, product development, online site customization, targeted marketing, customer satisfaction surveys, customer habits, or other analyses.

Recruiting: If you are a candidate for a position with Omaha Beach Capital, we will use personal data about you for purposes of recruiting, evaluating, hiring, and promoting personnel. Where the information about you is sensitive, you expressly consent to our use of the information to assess your application and to allow us to carry out equal opportunity monitoring.

Legal obligations: We will use or process personal data as is necessary for compliance with legal obligations to which we are subject. This includes using or processing personal data for defense of claims against us and satisfying any government reporting obligations and requests.

Monitoring, enforcement and legal requests: Omaha Beach Capital reserves the right at all times to monitor, review, retain, and/or disclose any information as necessary to satisfy any applicable law, regulation, legal process, or governmental request, or to cooperate with law enforcement and other authorities in investigating a claim of illegal activity. We may use IP addresses to identify a user when we feel it is necessary to protect our service, website, visitors, or others.

Legitimate interests: We may process your personal data for any other legitimate interests not described above. These interests may include analyzing the use of our website or services, improving our website and its content, fulfilling our obligations to our customers and others, and managing our customer and vendor relationships.

3. Legal bases for processing your personal data

We may process your personal data according to the following legal bases:

Contractual Obligations: We collect your personal information so that we may provide our services to you and communicate with you about our services. This includes entering into or performing a contract with you, providing you with information about our services, or responding to inquiries.

Consent: We may collect your personal information for direct marketing or other reasons based on your consent. You have the option to withdraw your consent at any time. We also may process information collected through cookies, such as your location data, IP address, and content viewed on our website, for marketing purposes. You can manage or disable cookies at any time by adjusting your browser settings.

Legal Obligations: We will use or process personal information as necessary for compliance with a legal obligation to which we are subject.

Legitimate Interests: Where our use of your personal information is necessary for our legitimate interests or the legitimate interests of a third party (unless there is a good reason to protect your personal information, which overrides our legitimate interests).

4. How we disclose your personal data

We do not sell, trade, or rent your personal data to third parties. We may disclose personal data that we collect about you to the following categories of third parties:

• Business affiliates: We may provide personal data within our company and across offices for the legal and legitimate purposes described above. The categories of personal data we may disclose to business affiliates may include identifiers, customer records, and commercial information.
• Service providers: We may disclose your personal data to third party service providers and business partners that perform services for us and who are obligated to secure the information, such as information technology service providers, trading platform providers, suppliers, contractors, consultants, and analytics or marketing providers. These companies are bound by contractual obligations to keep personal data confidential and use the data only for the purposes for which it has been disclosed to them. The categories of personal data we may disclose to service providers may include identifiers, customer records, commercial information, and geolocation.
• Government and law enforcement: We may disclose any and all categories of personal data as required by a court order or any other legal or regulatory requirement, including in response to requests from public and government authorities, or to protect our rights, privacy, safety, or property.
• Successors: In the event of a sale, merger, consolidation, change in control, transfer of substantial assets, reorganization, or liquidation, we may transfer, sell, or assign to third parties information concerning your relationship with us, including, without limitation, any and all categories of personal data that we have collected about you in accordance with applicable law. We also may disclose this information in connection with the due diligence for any such transaction. Any acquirer or successor may continue to use your data as set forth in this Notice.

The recipients of your personal data may be located outside of the jurisdiction where you reside.

Omaha Beach Capital and other processing agents will perform the processing of your personal data in good faith and in compliance with the principles of purpose, suitability, necessity, free access, quality of data, transparency, security, prevention, non-discrimination and accountability, as well as pursuant to other provisions set forth in this privacy policy.

5. How we protect your personal data

We take reasonable security, technical and administrative measures to protect personal data from misuse, interference, and unauthorized loss, access, modification, or disclosure. We follow industry standard data protection practices to protect the personal data submitted to us, both during transmission and once we receive it. This includes deploying a variety of commercially available software and hardware security tools. We will take such measures with respect to your personal data using security measures that we use for the personal data of others, and we will do so in compliance with all applicable data protection laws and our professional secrecy and ethical obligations.

Unfortunately, no method of transmission over the Internet, or method of electronic storage, is 100% secure. As a result, while we will strive to protect your personal data, we cannot and do not guarantee or warrant the absolute security of any of your personal data. We will not be and are not liable for disclosures of your personal data due to errors in transmission, networks that we do not control, nor unauthorized acts of third parties.

6. How long we keep your personal data

We will keep your personal data in accordance with all applicable laws and until such time as we no longer expect to need to use it for any legal and legitimate purpose. At the appropriate time, we will take reasonable steps to destroy your personal data in a safe manner.

7. Your rights with regard to your personal data

Subject to local law, including the EU General Data Protection Regulation (“GDPR”) and Brazil Data Protection Law (“LGPD”), you may have certain rights regarding personal data we have collected about you. Such rights might include the right to (a) know what personal data we have collected about you, (b) know what personal data about you was disclosed to third parties, (c) update or correct such data if you believe there is an inaccuracy, or is not complete, (d) restrict the processing of your personal data, (e) request deletion of your personal data, (f) object to our use of your personal data, (g) request transmission of your personal data to another data controller, (h) confirm the existence of the processing of your personal data, (i) request the anonymization, blocking or deletion of unnecessary or excessive personal data or personal data processed in noncompliance with the LGPD, (i) revoke your consent, (j) request information about the personal data we have shared, (k) receive information about the possibility of denying consent and the consequences of said denial, (l) oppose to the processing of your personal data when is noncompliant with the LGPD, or (m) request review by a natural person, of decisions taken solely based on automated processing of personal data that affects your interests . We will not discriminate against you for exercising any of these privacy rights, except that the deletion of your personal data may prevent us from providing you content or other benefits that depend on the processing of your personal data.

If you would like to exercise any of these rights provided under local law, you may contact us at: (305) 560-5200 or by email at info@Omaha Beach Capital.com.

If you would like to make a complaint about how we handled your personal data, or make a complaint about a breach of data protection laws, please contact us using the information provided below in Section 10. Complaints will be investigated and the outcome of the investigation will be communicated to you after the complaint is made in accordance with applicable law. You may have a right in some locations to file a complaint with your local data protection authority.

8. Additional information for California residents

During the past twelve (12) months, we collected the categories of personal data outlined above in Section 1 from California residents for the purposes outlined in Section 2. We also disclosed personal data about California residents to third parties for the purposes noted above in Section 4 during the past twelve (12) months. We do not sell, trade, or rent the personal data of California residents to third parties.

If you are a resident of California, the California Consumer Privacy Act (“CCPA”) provides you with the following rights regarding your personal data:

• Right to Know: You have the right to request information about our collection and use of your personal data over the past twelve (12) months concerning (i) the categories of personal data we collected about you, (ii) the categories of sources from which your personal data is collected, and (iii) categories of third parties with whom we share your personal data
• Right to Deletion: You have the right to request that we delete any of your personal data that we collected from you and retained, subject to certain exceptions provided under the CCPA
• Right to Non-Discrimination: We will not discriminate against you for exercising any of your privacy rights under CCPA or applicable law.
• Confirmation that we do not sell your personal data to third parties.

If you would like to exercise any of these rights provided under local law, you can contact us by telephone, collect, at (305) 560-5200, or by email at info@Omaha Beach Capital.com.

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal data. To exercise the rights described above, it may be necessary for us to verify your identity or authority to make the request and confirm the personal data relates to you. During the verification process, we may verify your identity against known information in our databases, such as your name, e-mail address, physical address, and telephone number.

When we receive your request, we also may contact you via e-mail, telephone, and/or other secured communication channels to verify your identity. Where you request access to the specific pieces of personal data we hold about you or deletion of your personal data, we may ask you to sign a declaration under penalty of perjury that you are the consumer whose personal data is the subject of the request.

In certain instances (e.g., where there is a mismatch against known information in our databases or where you are seeking information on behalf of another person without authorization), we may seek additional verification from you, which may be in the form of a notarized attestation or by asking you additional questions to ensure you are the consumer whose personal data is the subject of the request.

9. Exclusions

This Privacy Policy does not apply to any unsolicited information you provide to Omaha Beach Capital through this website or through any other means. This includes, but is not limited to, information posted to any public areas of the website, such as bulletin boards, any ideas for new products or modifications to existing products, and other unsolicited submissions (collectively, “Unsolicited Information”). All Unsolicited Information shall be deemed to be non-confidential and Omaha Beach Capital shall be free to reproduce, use, disclose, distribute, and exploit such Unsolicited Information without limitation or attribution.

This website may contain links to other websites not operated or controlled by Omaha Beach Capital (the “Third Party Sites”). The policies and procedures we described here do not apply to the Third Party Sites. The links from this website do not imply that Omaha Beach Capital endorses or has reviewed the Third Party Sites. We suggest contacting those sites directly for information on their privacy policies.

10. Questions or complaints about the Privacy Policy

Your privacy and security is important to us. We continually monitor customer feedback and seek to improve our services to meet your needs. If you have any questions, comments, or complaints about Omaha Beach Capital’s Privacy Policy, the information practices of this website, or your interaction with Omaha Beach Capital’s website you can send us an email at: info@omahabeachcap.com.