PRIVACY POLICY
Finissimo Capital LLC
Version 3.0
Effective Date: July 27, 2026
Last Updated: July 26, 2026
1. PURPOSE AND SCOPE
Finissimo Capital LLC, a Delaware limited liability company, respects the privacy of individuals who visit or interact with our website.
This Privacy Policy describes how Finissimo Capital LLC, referred to as Finissimo Capital, the Company, we, us, or our, collects, uses, discloses, retains, and protects Personal Information in connection with the website located at www.finissi.com, including its pages, content, features, forms, and related digital services.
This Privacy Policy applies when you:
Visit or browse the Website.
Submit an inquiry or contact form.
Communicate with us through the Website.
Subscribe to communications.
Download or interact with documents, media, or other Website content.
Otherwise engage with a digital service that links to this Privacy Policy.
This Privacy Policy does not apply to information processed under a separate privacy notice, contractual arrangement, transaction document, employment notice, or other disclosure provided in connection with a specific relationship. Where another applicable notice or agreement conflicts with this Privacy Policy, the more specific notice or agreement will govern with respect to the relevant processing activity.
For purposes of this Privacy Policy, Personal Information means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked to an identified or identifiable individual or household. Personal Information does not include information that is lawfully excluded from applicable privacy laws, such as certain publicly available, aggregated, or deidentified information.
2. INFORMATION WE COLLECT
The information we collect depends on how you interact with the Website.
2.1 Information You Provide
We may collect information that you provide directly to us, including:
Your name.
Your business or personal email address.
Your telephone number.
Your company, institution, or organizational affiliation.
Your professional title or role.
Your country, state, or general location.
The subject and content of your inquiry.
Information contained in correspondence with us.
Documents, attachments, or other materials that you choose to submit.
Your communication and marketing preferences.
Any other information that you voluntarily provide.
Please do not submit Social Security numbers, government identification numbers, financial account credentials, payment card information, medical information, biometric information, passwords, or other highly sensitive information through a general Website form or unsecured communication channel unless we expressly request the information and provide an appropriate method for its transmission.
2.2 Information Collected Automatically
When you access or interact with the Website, we and our service providers may automatically collect certain technical and usage information, including:
Your Internet Protocol address.
Browser type and version.
Device type and device identifiers.
Operating system and platform.
Language and regional settings.
Approximate geographic location derived from your Internet Protocol address.
The date and time of access.
Pages viewed and content accessed.
Referring and exit pages.
Links selected and navigation paths.
Session duration and interaction information.
Download activity.
Form interaction and submission status.
Website performance, diagnostic, and error information.
Security events and access logs.
Cookie identifiers and information collected through similar technologies.
We use this information to operate, secure, administer, measure, and improve the Website.
2.3 Information Obtained From Other Sources
We may receive Personal Information from sources other than the individual to whom the information relates, including:
Professional referrals and business contacts.
Affiliates and business partners.
Website, hosting, security, analytics, and communications providers.
Publicly available sources.
Professional networking services.
Corporate websites and directories.
Government, regulatory, and public records, where lawfully available.
Fraud prevention, identity verification, compliance, or due diligence providers, where relevant to a prospective or existing business relationship.
Information obtained from another source may be combined with information collected directly from you or generated through your use of the Website.
3. HOW WE USE PERSONAL INFORMATION
We may use Personal Information for the following business and operational purposes.
3.1 Website Operation
We use Personal Information to provide, maintain, administer, display, and improve the Website and its content.
This may include managing Website infrastructure, supporting navigation, processing forms, delivering requested documents, maintaining user preferences, diagnosing technical problems, and measuring Website performance.
3.2 Communications and Relationship Management
We use Personal Information to:
Respond to inquiries.
Provide requested information.
Manage correspondence.
Evaluate potential professional or commercial relationships.
Maintain business contact records.
Arrange meetings or follow-up communications.
Provide administrative support.
Communicate regarding our activities, services, or areas of interest.
3.3 Security and Integrity
We may process Personal Information to protect the Website, our systems, our personnel, and other users.
This includes detecting, investigating, preventing, and responding to unauthorized activity, fraud, misuse, security threats, malicious code, technical failures, and violations of our legal terms.
3.4 Analytics and Improvement
We may use Website and interaction information to understand how the Website is accessed and used, evaluate content performance, identify navigation patterns, improve functionality, and support internal planning.
Where appropriate, we may aggregate or deidentify information so that it is no longer reasonably capable of being associated with a particular individual.
3.5 Legal and Compliance Purposes
We may use Personal Information to:
Comply with applicable laws and lawful legal process.
Respond to governmental, judicial, regulatory, or law enforcement requests.
Establish, exercise, or defend legal rights and claims.
Maintain records required for legal, accounting, audit, tax, or compliance purposes.
Investigate suspected violations of law or our agreements.
Protect the rights, property, security, and legitimate interests of Finissimo Capital and others.
3.6 Corporate Transactions
We may process and disclose Personal Information in connection with an actual or contemplated financing, investment, acquisition, disposition, merger, consolidation, restructuring, reorganization, sale of assets, transfer of control, insolvency proceeding, or similar corporate event.
Any recipient of Personal Information in such a transaction will be expected to process it in a manner consistent with applicable law and any binding confidentiality obligations.
3.7 Communications and Marketing
Subject to applicable law, we may use contact information to send institutional updates, publications, invitations, announcements, or other communications that may be relevant to a professional relationship.
You may unsubscribe from promotional email communications by using the unsubscribe mechanism included in the communication or by contacting us at privacy@finissi.com.
We may continue to send nonpromotional communications concerning an existing inquiry, transaction, relationship, legal notice, security matter, or administrative issue.
4. COOKIES AND SIMILAR TECHNOLOGIES
4.1 General Use
The Website may use cookies and similar technologies to operate, protect, analyze, and improve its functionality.
These technologies may include:
Browser cookies.
Local storage.
Tracking pixels.
Web beacons.
Tags.
Scripts.
Software development kits.
Session identifiers.
Embedded content technologies.
Other technologies that store information on, or access information from, a browser or device.
Cookies may be placed by us or by third parties that provide Website infrastructure, functionality, content, analytics, security, or related services.
4.2 Categories of Technologies
Strictly Necessary Technologies
These technologies support functions required for the Website to operate securely and effectively. They may be used for session management, security, fraud prevention, network routing, load management, consent management, and other essential functions.
Disabling strictly necessary technologies may prevent portions of the Website from functioning properly.
Analytics and Performance Technologies
These technologies help us understand Website traffic, navigation, content engagement, errors, and performance.
Analytics providers may collect technical information about your browser, device, network connection, general location, and interactions with the Website.
Where required by applicable law, nonessential analytics technologies will be used only after appropriate consent has been obtained.
Functional Technologies
These technologies may remember selections, preferences, form entries, language settings, or other choices intended to improve Website functionality.
Third Party Content Technologies
Certain Website content may rely on third-party technologies to display, deliver, secure, or measure the relevant content. These technologies may collect information when the content is requested, displayed, downloaded, played, or otherwise accessed.
4.3 Managing Cookie Preferences
Where available, you may manage nonessential cookies through the Cookie Settings control displayed on the Website.
You may also configure your browser to block, restrict, or delete cookies. Browser-level restrictions may affect Website appearance, availability, performance, or functionality.
Your preferences may be specific to the browser and device you use. You may therefore need to repeat your selections when using another browser, device, or browsing environment.
4.4 Global Privacy Control
Where required by applicable law, we recognize legally valid browser-based opt-out preference signals, including Global Privacy Control signals.
The effect of such a signal may depend on your jurisdiction, browser configuration, and the nature of the processing activity.
4.5 Do Not Track Signals
Some browsers provide a Do Not Track setting. Because no uniform industry standard currently governs how all websites must interpret those signals, the Website may not respond to a Do Not Track setting unless required by applicable law.
This does not affect our obligation to recognize legally binding opt-out preference signals where applicable.
5. THIRD PARTY HOSTED CONTENT, MEDIA, AND ASSETS
The Website may incorporate, display, transmit, cache, or otherwise make available content and technical assets that are supplied, hosted, processed, or delivered by third-party providers.
Such content and assets may include:
Images and photographs.
Video and audiovisual material.
Audio recordings.
Documents and downloadable files.
Reports and presentations.
Fonts and typography resources.
Forms and interactive components.
Scripts and software elements.
Security and fraud prevention features.
Content delivery services.
Website hosting infrastructure.
Analytics and performance tools.
Embedded media players.
Other digital content or functionality.
When your browser or device requests, loads, displays, downloads, plays, or interacts with third-party content or assets, the relevant provider may automatically receive certain technical and usage information.
Depending on the provider and configuration, this information may include your Internet Protocol address, browser type, device information, referring page, requested asset, access time, approximate location, interaction information, and cookie or similar identifiers.
A third-party provider may also place or access cookies, local storage, pixels, tags, or similar technologies through the Website. Such technologies may be necessary to deliver content, maintain security, measure performance, analyze usage, remember preferences, or support other functions.
We do not control every technical process used by an independent third party. A third party's collection, use, and disclosure of information may also be governed by its own privacy notice, contractual terms, and legal obligations.
Where required by applicable law, we take reasonable steps to obtain consent before permitting nonessential third-party technologies to operate. Restricting such technologies may prevent certain media, documents, fonts, forms, or other Website elements from loading or functioning as intended.
6. HOW WE DISCLOSE PERSONAL INFORMATION
We may disclose Personal Information to the categories of recipients described below.
6.1 Service Providers and Contractors
We may disclose Personal Information to vendors and contractors that perform services on our behalf, including providers of:
Website hosting and infrastructure.
Cloud storage.
Content delivery.
Information security.
Fraud prevention.
Website development and maintenance.
Analytics and performance measurement.
Communications and email delivery.
Document management.
Data storage and backup.
Professional contact management.
Technical support.
Compliance and verification services.
Service providers and contractors are authorized to process Personal Information only for permitted purposes and subject to applicable contractual and legal restrictions.
6.2 Professional Advisers
We may disclose Personal Information to attorneys, accountants, auditors, consultants, insurers, financial advisers, and other professional advisers where reasonably necessary to obtain advice, protect our interests, manage risk, or comply with legal obligations.
6.3 Governmental and Legal Recipients
We may disclose Personal Information to courts, regulators, law enforcement agencies, governmental bodies, tax authorities, or other authorized parties where we believe disclosure is required or permitted by applicable law.
We may also disclose information where reasonably necessary to comply with legal process, enforce an agreement, investigate misconduct, prevent harm, or protect legal rights.
6.4 Corporate Transaction Recipients
Personal Information may be disclosed to prospective or actual purchasers, investors, lenders, counterparties, successors, or advisers in connection with a corporate transaction or strategic review.
6.5 Affiliates and Business Partners
We may disclose Personal Information to affiliates or business partners where reasonably necessary to respond to an inquiry, administer a relationship, evaluate an opportunity, perform an agreed activity, or pursue a legitimate business purpose consistent with this Privacy Policy.
6.6 At Your Direction
We may disclose Personal Information to another person or organization when you request, authorize, or direct us to do so.
7. SALE, SHARING, AND TARGETED ADVERTISING
We do not sell Personal Information in exchange for monetary consideration.
We do not use Personal Information collected through the Website for targeted advertising as an independent business purpose.
Certain analytics, embedded content, or third-party digital technologies may, depending on their configuration and the definitions established by applicable law, constitute a sale, sharing, or processing for targeted advertising even where no money is exchanged.
Where such processing occurs and applicable law provides an opt-out right, you may exercise that right through the Cookie Settings control, a legally recognized browser-based preference signal, or a request submitted to privacy@finissi.com.
We do not knowingly sell or share the Personal Information of individuals under sixteen years of age for cross-context behavioral advertising.
8. DATA RETENTION
We retain Personal Information only for as long as reasonably necessary and proportionate to fulfill the purposes described in this Privacy Policy, unless a longer period is required or permitted by law.
The appropriate retention period may depend on:
The nature and sensitivity of the information.
The purpose for which the information was collected.
The duration of a business or professional relationship.
Applicable legal, tax, accounting, regulatory, and contractual requirements.
Security and fraud prevention needs.
The existence of a dispute, investigation, proceeding, or legal claim.
Applicable limitation periods.
Technical backup and disaster recovery cycles.
When Personal Information is no longer reasonably required, we may delete, destroy, aggregate, anonymize, or deidentify it in accordance with applicable law and our records management practices.
Residual copies may remain temporarily within backup, archival, security, or disaster recovery systems until they are deleted or overwritten through established processes.
9. INFORMATION SECURITY
We maintain administrative, technical, and physical safeguards designed to protect Personal Information against unauthorized access, acquisition, use, alteration, disclosure, loss, or destruction.
Our safeguards are selected in light of the nature of the information, the purposes for which it is processed, the systems involved, and the reasonably foreseeable risks.
These measures may include:
Access restrictions.
Authentication controls.
Encryption where appropriate.
Network and system monitoring.
Security logging.
Vulnerability and patch management.
Vendor oversight.
Confidentiality obligations.
Personnel training.
Incident response procedures.
Business continuity and recovery planning.
No system, network, transmission method, storage environment, or security measure is completely secure. We therefore cannot guarantee the absolute security of Personal Information.
If we become aware of a security incident involving Personal Information, we will investigate and respond in accordance with applicable law. Where legally required, we will provide notice to affected individuals, regulators, or other appropriate parties.
10. YOUR PRIVACY RIGHTS
Depending on your state or country of residence and subject to applicable exemptions, you may have the right to:
Confirm whether we process your Personal Information.
Request access to Personal Information maintained about you.
Request a copy of certain Personal Information.
Request correction of inaccurate Personal Information.
Request deletion of Personal Information.
Request portability of Personal Information in a usable format.
Object to or restrict certain processing.
Opt out of the sale of Personal Information.
Opt out of the sharing of Personal Information for cross-context behavioral advertising.
Opt out of processing for targeted advertising.
Opt out of certain profiling activities that produce legal or similarly significant effects.
Withdraw consent where processing is based on consent.
Appeal the denial of a privacy request where applicable law provides an appeal right.
Receive equal service and treatment without unlawful discrimination for exercising a privacy right.
These rights are not absolute. A request may be denied or limited where an exception applies, including where processing is necessary to comply with law, complete a transaction, preserve security, protect legal rights, maintain records, prevent fraud, or exercise another legally recognized purpose.
11. SUBMITTING A PRIVACY REQUEST
You may submit a privacy request by contacting:
Please include Privacy Request in the subject line and clearly describe the right you wish to exercise.
We may request information reasonably necessary to verify your identity, residency, authority, or relationship to the information at issue. Information collected for verification will be used only for verification, security, fraud prevention, and compliance purposes.
We will respond within the period required by applicable law. Where permitted, we may extend the response period and will provide notice of the extension.
An authorized agent may submit a request on your behalf where permitted by law. We may require evidence of the agent's authority and may also request that you verify your identity directly with us.
If your request is denied and applicable law grants an appeal right, you may submit an appeal by emailing privacy@finissi.com with Privacy Appeal in the subject line.
We do not unlawfully discriminate against individuals for exercising privacy rights.
12. CALIFORNIA PRIVACY DISCLOSURES
This section applies to California residents to the extent the California Consumer Privacy Act, as amended, applies to our processing activities.
12.1 Categories Collected
During the preceding twelve months, we may have collected the following categories of Personal Information, as defined under California law:
Identifiers, including names, email addresses, telephone numbers, Internet Protocol addresses, and online identifiers.
Customer records information, including contact information, professional affiliation, and correspondence details.
Commercial information, including records of inquiries, potential business interests, and interactions with us.
Internet or other electronic network activity information, including Website browsing, navigation, interaction, device, and diagnostic information.
Approximate geolocation information derived from an Internet Protocol address.
Professional or employment-related information, including company affiliation, professional role, biography, or other business information voluntarily provided.
Audio, electronic, visual, or similar information where you submit, access, or interact with media through the Website.
Inferences that may be derived from Website interactions for security, analytics, relationship management, or Website improvement purposes.
Other Personal Information that you voluntarily submit through Website forms, correspondence, or attachments.
12.2 Sources
We may collect these categories directly from you, automatically from your browser or device, from service providers, from referrals and business contacts, and from public or professional sources.
12.3 Business and Commercial Purposes
We use these categories for the purposes described in this Privacy Policy, including Website operation, security, communications, relationship management, analytics, legal compliance, records administration, and corporate transactions.
12.4 Categories Disclosed
During the preceding twelve months, we may have disclosed the categories identified above to service providers, contractors, professional advisers, affiliates, business partners, governmental authorities, legal recipients, and corporate transaction participants for business purposes.
12.5 Sale and Sharing
We have not sold Personal Information in exchange for monetary consideration.
Certain analytics or third-party digital technologies may be considered sharing for cross-context behavioral advertising under California law, depending on their operation and configuration.
California residents may opt out of qualifying sale or sharing through the Cookie Settings control, a legally recognized Global Privacy Control signal, or by contacting privacy@finissi.com.
12.6 Sensitive Personal Information
We do not use or disclose Sensitive Personal Information collected through the Website for purposes that require a right to limit under California law.
Please do not provide Sensitive Personal Information through general Website forms unless specifically requested through an appropriate channel.
12.7 Financial Incentives
We do not offer financial incentives or price or service differences in exchange for the collection, retention, sale, or sharing of Personal Information through the Website.
13. RIGHTS OF DELAWARE AND OTHER UNITED STATES RESIDENTS
Residents of Delaware and other states with applicable comprehensive privacy laws may have rights to access, correct, delete, or obtain a copy of Personal Information, and to opt out of certain sales, targeted advertising, or profiling activities.
Applicable rights vary by jurisdiction and may be subject to legal thresholds, exemptions, verification requirements, and exceptions.
Where applicable law provides a right to appeal a decision concerning a privacy request, you may submit an appeal using the process described in Section 11.
14. INTERNATIONAL VISITORS
Finissimo Capital is established in the United States. Personal Information collected through the Website may be processed and stored in the United States and in other jurisdictions where our service providers or other recipients operate.
The privacy and data protection laws of those jurisdictions may differ from the laws of your country of residence.
Where an applicable law requires a lawful basis for processing, we may rely on one or more of the following:
Your consent.
Performance of a contract or steps requested before entering into a contract.
Compliance with a legal obligation.
Our legitimate interests, provided those interests are not overridden by applicable individual rights.
The establishment, exercise, or defense of legal claims.
Another lawful basis recognized under applicable law.
Where required, we will use an appropriate legal mechanism for an international transfer of Personal Information.
Individuals located outside the United States may contact privacy@finissi.com to request information about applicable rights or transfer safeguards.
Nothing in this Privacy Policy limits a mandatory right available under applicable law.
15. CHILDREN'S PRIVACY
The Website is intended for business and professional audiences. It is not directed to children or designed for use by individuals under eighteen years of age.
We do not knowingly collect Personal Information online from children under thirteen years of age.
If we learn that Personal Information has been collected from a child in a manner prohibited by applicable law, we will take reasonable steps to delete the information.
A parent or legal guardian who believes that a child has submitted Personal Information through the Website may contact privacy@finissi.com.
16. THIRD PARTY WEBSITES AND SERVICES
The Website may contain links to websites, applications, platforms, documents, or services operated by third parties.
A link does not constitute an endorsement of the third party's privacy, security, content, or business practices.
This Privacy Policy does not govern an independent third party's collection, use, disclosure, retention, or protection of information. You should review the applicable privacy notice before providing information to or interacting with a third-party service.
17. CHANGES TO THIS PRIVACY POLICY
We may revise this Privacy Policy periodically to reflect changes in our practices, Website functionality, service providers, legal obligations, or regulatory requirements.
When we revise the Privacy Policy, we will update the Last Updated date displayed at the beginning of the document.
Where required by applicable law, we will provide additional notice of a material change and obtain consent when necessary.
Your use of the Website after an updated Privacy Policy becomes effective will be governed by the updated version, subject to any consent requirement or other mandatory protection established by applicable law.
18. CONTACT INFORMATION
Questions, requests, and concerns relating to this Privacy Policy or our privacy practices may be directed to:
Finissimo Capital LLC
Attention: Privacy Officer
8 The Green
Dover, Delaware 19901
United States of America
Email: privacy@finissi.com
Website: www.finissi.com
DOCUMENT CONTROL
Version: 3.0
Effective Date: July 27, 2026
Last Updated: July 26, 2026
Policy Owner: Privacy Officer
Review Cycle: Periodic and upon material legal, operational, or technological change
Copyright 2026 Finissimo Capital LLC. All rights reserved.