Privacy Policy

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Your Privacy Matters to Us

At BlueRock Capital LLC, protecting your data and privacy is our top priority. We encourage you

to review this Privacy Policy so you can understand what information we collect, how we use it,

and with whom it might be shared. This policy also explains how you can control the use and

disclosure of your information.

Overview

This Privacy Policy describes how BlueRock Capital LLC (referred to as “the Company,” “we,” or

“us”), along with its affiliates and any investment vehicles we manage—or for which we act as

investment advisor, LLC manager, general partner, officer, or broker-dealer (collectively, the

“BlueRock Capital Vehicles”)—collect, use, and safeguard your personal information. If you

have any questions that aren’t addressed in this document, please email us at

info@bluerockcapital.co.

When you interact with our website (the “Website”) or our investor portal, we collect information

in various ways. By using the Web Portal, you consent to our information practices as described

in this Privacy Policy and agree to the Terms of Use provided there. Please note that if you

decide to invest in any offer through the Web Portal, you may be asked to agree to additional

agreements, including updated privacy notices or terms.

Information We Collect

Non-Personally Identifiable Information

We gather data that does not specifically identify you—referred to as “Non-Personally

Identifiable Information”—when you use our Website and Web Portal. This may include:

 The pages you visit and the articles, presentations, or videos you view

 The amount of time you spend using various features

 Demographic details like server locations

 Information stored in cookies on your device

 Search queries and results

 Date, time, connection speed, and similar usage details

We collect this data using several technologies, including cookies and server logs.

 Cookies: Small pieces of data placed on your computer by a website to enhance your

experience.

 Server Logs: Files automatically generated by our servers that record details about your

transactions and activities.

Analytics programs and service providers—using first-party cookies—help us understand your

interactions with the Website and Web Portal (such as visit times, referral sources, and pages

viewed). Please note, however, that this policy does not cover data collected by third parties (for

example, other entities with which BlueRock Capital conducts business), nor do we control their

information practices.

Personally Identifiable Information and Other Data

We also collect data that identifies you (or can be reasonably linked to you), which we refer to

as “Personally Identifiable Information.” Combined with Non-Personally Identifiable Information

(collectively “Data”), this information is used to enhance your experience on our Website and

Web Portal. For example, if you submit content (such as images or text), we may modify or copy

it to provide you with a seamless experience. By submitting Data via our Website or Web Portal,

you consent to its collection, use, and disclosure as described below.

How We Use Your Information

The BlueRock Capital Vehicles use the information we collect for various purposes, including to:

1. Provide services you have requested

2. Assist our IT vendors and contractors with troubleshooting

3. Comply with legal, regulatory, or internal requirements associated with the offer or sale

of securities

4. Protect against legal liability

For example, if you contact us via email, we’ll use your information to respond to your query or

address any issues. We may also use your data to improve the functionality and content of our

Website and Web Portal, and to inform you about services and products we believe may be of

interest. If you prefer not to receive marketing communications, you may request removal from

our mailing lists (details provided below). Please note that we will still send you the necessary

administrative messages (such as statements, investor updates, and confirmations).

Additionally, we may use your Data with our affiliates or third-party service providers when

needed to:

 Investigate or prevent fraudulent or unlawful activity

 Protect our or others’ rights and property

 Comply with legal obligations

 Facilitate a corporate transaction (such as a merger, sale, or reorganization)

In such events, you will be notified via email or a prominent notice on the Website regarding any

changes in ownership or the use of your Data, along with any options available to you.

Exclusions

This Privacy Policy applies only to information collected through the Website and Web Portal. It

does not cover any unsolicited information you may provide by other means (for example, if you

post on public areas of our Website, submit suggestions for new products, or propose

modifications). All such unsolicited information is considered non-confidential, and we are free

to use, reproduce, or distribute it without any obligation or attribution to you.

Opt-Out Policy

From time to time, we may send you marketing or promotional emails. If you prefer not to

receive these communications, please unsubscribe by emailing us at info@bluerockcapital.co.

Please allow up to one (1) week for your opt-out request to be processed. Note, however, that

we may still need to send you transactional emails (such as service notifications, payment

confirmations, investor updates, or legal and tax notices) that are essential to our business

relationship. You can update your account information (such as your email address, password, or contact details) via your profile or account settings on the Website and Web Portal. For further modifications, please contact us at info@bluerockcapital.co. Account settings also let you set preferences regarding the visibility of your information. You can disable or restrict cookies through your browser’s settings or “Do Not Track” feature, though this might affect the functionality of the Website or Web Portal. Additionally, if you wish to have your Personally Identifiable Information removed from our database, please send your request to info@bluerockcapital.co. We are not responsible for removing your data from third-party lists that received it in compliance with this Privacy Policy.

Data Security

We take extensive measures to safeguard your Data. The Company and each BlueRock Capital Series have implemented technical, organizational, and administrative safeguards—including bank-level encryption and secure account verification processes—to protect your information from loss, misuse, unauthorized access, alteration, or destruction. While we work with reputable security vendors and use industry-standard technologies (such as SSL encryption for data transmission), no method of data transmission or storage is entirely secure. Therefore, while we strive to protect your data, we cannot guarantee absolute security. It is also important that you safeguard your login details and log off from shared devices.

Please note that BlueRock Capital Affiliates acts as a data controller for any personal information you provide when using our Website, including membership details. By using our Website, joining BlueRock Capital Affiliates, or otherwise indicating your acceptance of this Privacy Policy, you authorize us to collect and use your Personal Information as described herein.

Legal Basis for Processing Your Data

We collect and process your Personally Identifiable Information only as allowed by applicable law. Our legal bases for processing include:

 The necessity to perform a contract to which you are a party or to take steps at your request in order to enter into such a contract

 Our legitimate interests (or those of a third party), provided these interests are not overridden by your rights and freedoms

 Your consent

 Compliance with a legal obligation

In some cases, applicable law requires us to implement and maintain certain security measures, report breaches, or retain data for a minimum period.

Data Retention

We retain your information only as long as necessary to comply with legal obligations, resolve disputes, enforce agreements, or provide you with our services. If your account is inactive, your Personally Identifiable Information may still be retained if required for compliance, regulatory purposes, fraud prevention, or enforcement of this Privacy Policy and our Terms of Service. In addition, we may keep your data for a limited period if requested by law enforcement.

Your Rights Under GDPR and Other Data Protection Laws

You have rights regarding your Personal Data. If you wish to access, correct, delete, restrict, transfer, or object to the processing of your information—or if you wish to deactivate your membership—please contact us at info@bluerockcapital.co. We will process your request in accordance with applicable laws, and we may need to verify your identity before taking action.

In every email sent by or on behalf of BlueRock Capital Affiliates, you will find instructions on how to unsubscribe from future communications.

Subject to applicable law, your rights include:

 Right of Access: You can request confirmation of whether we are processing your Personal Data and, if so, obtain a copy along with certain details. Additional copies may incur a fee.

 Right to Rectification: If your Personal Data is inaccurate or incomplete, you can ask us to correct or complete it. If we have shared your data, we will notify third parties of the correction when possible.

 Right to Erasure: You may request that we delete your Personal Data under certain circumstances (except where retention is required by law or other overriding interests). If your data has been shared, we will inform you as soon as practicable.

 Right to Restrict Processing: You may ask us to limit the processing of your Personal Data (for example, if you contest its accuracy or object to its use). We will notify you when any restrictions are lifted.

 Right to Data Portability: You have the right to receive your Personal Data in a

structured, commonly used, and machine-readable format so that you can reuse it elsewhere.

 Right to Object: You may request that we cease processing your Personal Data for direct marketing or other purposes. However, if we rely on legitimate interests that we can demonstrate as compelling, we may continue processing your data.

 Rights Concerning Automated Decision-Making and Profiling: You have the right not to be subject solely to automated processing, including profiling, which produces significant effects on you—unless such processing is necessary for a contract or you have provided explicit consent.

 Right to Withdraw Consent: If our processing of your Personal Data is based on your consent, you can withdraw it at any time. Withdrawal will not affect data processed

before the withdrawal.

 Right to Lodge a Complaint: If you have concerns about our privacy practices or our handling of your Personal Data, you have the right to lodge a complaint with the

appropriate data protection authority.

California Privacy Rights:

If you are a California resident, under California Civil Code Section 1798.83 you may request details about the disclosure of your personal information to third parties for their direct marketing purposes. For more information on your California privacy rights, please refer to our CCPA Privacy Notice. To request a list of third parties with whom we have shared your information in the past year—including the categories of data disclosed—please contact us at

info@bluerockcapital.co.

Modifications to This Privacy Policy

We reserve the right to modify, update, or remove parts of this Privacy Policy at our sole discretion. Any changes will be effective immediately upon posting on the Website or Web Portal, and significant updates will be communicated to all registered users via email. We encourage you to review this policy regularly. Your continued use of our Website or Web Portal after changes are posted signifies your acceptance of those changes.

Governing Law and Jurisdiction

The Website and Web Portal are operated from within the United States. By accessing or using our Website or Web Portal (including the mobile application), you consent to the export, storage, and use of your Personally Identifiable Information in the United States in accordance with this Privacy Policy. This policy is governed by and construed under the laws of the State of Wyoming, without regard to conflicts of law principles. Any disputes arising from this Privacy Policy shall be resolved exclusively in either the Florida State Courts located in Palm Beach County, Florida, or the federal district court for the Southern District of Florida. By using our services, you consent to the jurisdiction and venue of these courts and waive your right to a jury trial to the fullest extent permitted by law.

Effective Date

This Privacy Policy was last updated on February 6, 2025.

© BlueRock Capital LLC 2025