Privacy Policy

Effective Date: March 1, 2025

QCI Capital Management LLC ("QCI," "we," "us," or "our") is committed to protecting your privacy. This Privacy Policy describes how we collect, use, disclose, and safeguard your information when you visit our website at qcicm.com (the "Site"). Please read this policy carefully. By accessing or using the Site, you agree to the terms of this Privacy Policy.

1. Information We Collect

We may collect information about you in a variety of ways, including:

Information You Provide Voluntarily. We may collect personal information that you voluntarily provide when you contact us, subscribe to our publications, or request information about our services. This may include your name, email address, phone number, mailing address, and professional affiliation.

Information Collected Automatically. When you access the Site, we may automatically collect certain information about your device and usage, including your IP address, browser type, operating system, referring URLs, pages viewed, and the dates and times of your visits. This information is collected through cookies, web beacons, and similar technologies.

2. Use of Your Information

We may use the information we collect for purposes including:

• Responding to your inquiries and fulfilling your requests
• Sending you communications about our services, market commentary, and publications
• Operating, maintaining, and improving the Site
• Monitoring and analyzing usage trends to enhance user experience
• Complying with applicable laws, regulations, and legal processes
• Protecting the rights, property, or safety of QCI, our users, or others

3. Cookies and Tracking Technologies

The Site may use cookies and similar tracking technologies to collect information about your browsing activity. Cookies are small data files stored on your device that help us improve the Site and your experience. You may configure your browser to refuse cookies or alert you when cookies are being sent. If you disable cookies, some features of the Site may not function properly.

We may use third-party analytics services, such as Google Analytics, to help us understand how visitors use the Site. These services may use cookies and similar technologies to collect and analyze information about use of the Site.

4. Disclosure of Your Information

We do not sell, trade, or rent your personal information to third parties. We may share your information in the following circumstances:

• Service Providers. We may share your information with third-party vendors and service providers that perform services on our behalf, such as website hosting, analytics, and email delivery.
• Legal Requirements. We may disclose your information if required to do so by law or in response to valid requests by public authorities, including to meet national security or law enforcement requirements.
• Business Transfers. In the event of a merger, acquisition, reorganization, or sale of assets, your information may be transferred as part of that transaction.
• Protection of Rights. We may disclose information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, or situations involving potential threats to the safety of any person.

5. Security of Your Information

We use reasonable administrative, technical, and physical safeguards to protect your personal information. However, no method of transmission over the Internet or method of electronic storage is completely secure. While we strive to protect your information, we cannot guarantee its absolute security.

6. Third-Party Websites

The Site may contain links to third-party websites, including our Substack publication and investor portal. We are not responsible for the privacy practices or content of those third-party sites. We encourage you to review the privacy policies of any third-party sites you visit.

7. Children's Privacy

The Site is not directed to individuals under the age of 18. We do not knowingly collect personal information from children under 18. If we become aware that we have collected personal information from a child under 18, we will take steps to delete such information promptly.

8. Your Rights and Choices

Depending on your jurisdiction, you may have certain rights regarding your personal information, including the right to access, correct, delete, or restrict processing of your data. You may also opt out of receiving promotional communications from us by following the unsubscribe instructions in those messages.

9. California Residents

If you are a California resident, you may have additional rights under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA), including the right to know what personal information we collect, the right to request deletion of your personal information, the right to correct inaccurate information, and the right to opt out of the sale or sharing of your personal information. We do not sell personal information. To exercise your rights, please contact us using the information below.

10. European Economic Area and United Kingdom Residents

If you are located in the European Economic Area ("EEA") or the United Kingdom ("UK"), you may have additional rights under the General Data Protection Regulation ("GDPR") and applicable UK data protection laws.

We process your personal information on the following lawful bases, as applicable: our legitimate interests in operating and improving our business and the Site; your consent, where you have provided it; performance of a contract with you or to take steps at your request prior to entering into a contract; and compliance with our legal obligations.

Subject to applicable law, you may have the right to:

• Access the personal information we hold about you
• Rectify inaccurate or incomplete personal information
• Request erasure of your personal information
• Restrict the processing of your personal information
• Data portability — receive your personal information in a structured, commonly used, and machine-readable format
• Object to the processing of your personal information

Where processing is based on your consent, you have the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.

You also have the right to lodge a complaint with your local data protection supervisory authority if you believe that our processing of your personal information violates applicable law.

Your personal information may be transferred to and processed in countries outside the EEA or UK, including the United States. Where such transfers occur, we take appropriate safeguards to ensure that your personal information receives an adequate level of protection.

To exercise your GDPR rights or for any related inquiries, please contact us at info@qcicm.com.

11. Investor Portal

Personal information submitted through the NAV Consulting investor portal (navconsulting.net) is processed and stored by NAV Consulting in accordance with their own privacy practices. QCI does not control the data handling procedures of the NAV Consulting portal.

QCI may receive and use investor information from the portal for fund administration, reporting, and investor communications.

We encourage investors to review NAV Consulting's privacy policy for details on how their data is handled within the portal.

12. Do Not Track Signals

Some web browsers transmit "Do Not Track" ("DNT") signals to the websites and other online services with which the browser communicates. There is currently no industry standard for recognizing or honoring DNT signals. We do not currently respond to DNT signals. However, we will reassess our practices as uniform standards for responding to DNT signals develop.

13. Data Retention

We retain personal information for as long as necessary to fulfill the purposes for which it was collected, comply with our legal obligations, resolve disputes, and enforce our agreements. When personal information is no longer needed, we will securely delete or anonymize it.

14. Changes to This Policy

We may update this Privacy Policy from time to time. The updated version will be indicated by an updated effective date at the top of this page. We encourage you to review this Privacy Policy periodically. Your continued use of the Site following the posting of changes constitutes your acceptance of such changes.

15. Contact Us

If you have questions or concerns about this Privacy Policy or our data practices, please contact us at:

QCI Capital Management LLC
Email: info@qcicm.com