PRIVACY POLICY

MARIEMONT CAPITAL LLC

Effective Date: June 4, 2025

1. INTRODUCTION

Mariemont Capital LLC (“Mariemont Capital,” “we,” “us,” or “our”), an Ohio limited liability company, is committed to protecting the privacy and confidentiality of personal information. This Privacy Policy describes how we collect, use, disclose, and protect information when you access our website or engage with our services.

This Privacy Policy applies only to qualified investors who have met our eligibility requirements and have been granted access to our website. By accessing our website, you consent to the practices described in this Privacy Policy.

2. INFORMATION WE COLLECT

2.1 Information You Provide

We collect information you provide directly to us, including:

• Full legal name and any aliases
• Contact information (address, email, phone numbers)
• Date of birth and Social Security Number or Tax ID
• Financial information (net worth, income, investment experience)
• Accreditation status and supporting documentation
• Bank account and wire transfer information
• Copies of government-issued identification
• Tax residency and citizenship information
• Source of funds information
• Any other information required for regulatory compliance

2.2 Information Collected Automatically

When you access our website, we automatically collect:

• IP address and approximate geographic location
• Browser type and version
• Operating system
• Access times and dates
• Pages viewed and links clicked
• Referring website addresses
• Device identifiers and hardware information
• Cookie data and similar tracking technologies

2.3 Information from Third Parties

We may collect information about you from:

• Background check providers
• Sanctions screening databases
• Credit reporting agencies (with your consent)
• Other parties as required for due diligence
• Public records and databases

3. HOW WE USE YOUR INFORMATION

We use collected information to:

• Verify your identity and accredited investor status
• Comply with anti-money laundering (AML) and know-your-customer (KYC) requirements
• Process investment transactions and maintain investor accounts
• Communicate about your investments and account
• Provide investor reports and tax documents
• Comply with legal and regulatory obligations
• Detect and prevent fraud or unauthorized access
• Maintain website security and functionality
• Fulfill any other purpose disclosed at the time of collection

4. HOW WE SHARE YOUR INFORMATION

We may share your information with:

4.1 Service Providers

• Fund administrators and custodians
• Accounting and audit firms
• Legal counsel
• Technology service providers
• Background check providers

4.2 Regulatory and Legal Compliance

• Securities and Exchange Commission (SEC)
• Financial Industry Regulatory Authority (FINRA)
• Department of Treasury / FinCEN
• State securities regulators
• Law enforcement agencies
• Courts and tribunals
• Other parties as required by law or legal process

4.3 Business Transfers

In connection with any merger, acquisition, or sale of assets, information may be transferred to the acquiring entity.

4.4 With Your Consent

We may share information for any other purpose with your specific consent.

We do not sell, rent, or trade your personal information to third parties for marketing purposes.

5. DATA RETENTION

We retain your information for as long as necessary to:

• Maintain your investor account
• Comply with legal and regulatory requirements
• Resolve disputes and enforce agreements
• Meet applicable statutes of limitations

Generally, we retain records for up to ten (10) years after your last interaction with us or as required by applicable law, whichever is longer.

6. DATA SECURITY

We implement appropriate technical and organizational measures to protect your information, including:

• Encryption of data in transit and at rest
• Secure access controls and authentication
• Regular security assessments and monitoring
• Employee training on data protection
• Incident response procedures
• Physical security of data centers

However, no security measures are completely secure, and we cannot guarantee absolute security of your information.

7. YOUR RIGHTS AND CHOICES

7.1 Access and Correction

You may request access to or correction of your personal information by contacting us at the information below.

7.2 Communications

You may opt out of non-essential communications, though we must still send legally required investor communications.

7.3 Cookies

You can manage cookie preferences through your browser settings, though some website features may not function properly without cookies.

8. COOKIES AND TRACKING TECHNOLOGIES

We use cookies and similar technologies to:

• Maintain your session and authentication
• Analyze website usage and performance
• Detect and prevent fraud
• Comply with regulatory requirements

For detailed information about our use of cookies, please see our Cookie Policy.

9. INTERNATIONAL TRANSFERS

Our servers and service providers are located in the United States. If you access our website from outside the United States, your information will be transferred to and processed in the United States, which may have different privacy laws than your jurisdiction.

10. CHILDREN’S PRIVACY

Our website and services are not directed to individuals under 18. We do not knowingly collect information from children. If we learn we have collected information from a child, we will delete it.

11. CALIFORNIA PRIVACY RIGHTS

California residents may have additional rights under the California Consumer Privacy Act (CCPA). However, investment advisers are generally exempt from CCPA when handling investor information pursuant to federal securities laws.

12. OHIO PRIVACY RIGHTS

Ohio residents have certain rights under Ohio Revised Code Chapter 1347 regarding access to personal information maintained by businesses. To exercise these rights, please contact us using the information below. We will respond to valid requests within the timeframes required by Ohio law.

13. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time. We will notify you of material changes by posting the updated policy on our website and updating the effective date. Your continued use of our website after changes constitutes acceptance of the updated policy.

14. CONTACT INFORMATION

For questions about this Privacy Policy or our privacy practices, please contact:

Mariemont Capital LLC
Attention: Chief Compliance Officer
6965 Miami Avenue
Cincinnati, Ohio 45243
Email: kt@mariemontcapital.com
Phone: (513) 535-0576

15. REGULATORY DISCLOSURES

Mariemont Capital LLC is an Ohio limited liability company and investment adviser registered with the Securities and Exchange Commission. Registration does not imply any level of skill or training. This Privacy Policy is provided in accordance with SEC Regulation S-P and Ohio Division of Securities requirements.

For a copy of our Form ADV Part 2A brochure, which contains important information about our advisory services, fees, and business practices, please contact us at the above information.

16. GOVERNING LAW

This Privacy Policy shall be governed by and construed in accordance with the laws of the State of Ohio, without regard to conflict of law principles. Any disputes arising under or relating to this Privacy Policy shall be subject to the dispute resolution provisions set forth in our Terms and Conditions, including mandatory arbitration in Cincinnati, Ohio, or if arbitration is not available, exclusive jurisdiction in the courts of Hamilton County, Ohio.

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IMPORTANT NOTICE: This Privacy Policy applies only to persons who have been properly qualified and granted access to our website. Unauthorized access is prohibited and may be subject to criminal and civil penalties.