Privacy Policy
Crom Capital Management
Effective date: January 1, 2026
1. Introduction
This Privacy Policy describes how Crom Capital Management, LLC and its affiliated entities (collectively, “Crom,” “we,” “us,” or “our”) collects, uses, and shares information in connection with your use of our website, https://crom-capital.com (the “Site”). By accessing or using the Site, you agree to the collection and use of information as described in this Privacy Policy. If you do not agree, please do not use the Site.
This Privacy Policy applies only to the Site. It does not apply to information that investors or prospective investors provide to us in connection with an investment in any fund or vehicle we manage; the handling of that information is governed by the applicable offering documents, subscription agreements, and related agreements.
2. Information We Collect
Information you provide. The Site is primarily informational, and we do not require you to submit personal information to browse it. If you choose to contact us — for example, by email using an address listed on the Site — we will receive the information you provide, such as your name, email address, and the contents of your message.
Information collected automatically. When you visit the Site, certain information may be collected automatically by us or by third-party service providers that support the Site’s operation. This may include your Internet Protocol (IP) address, browser type and version, device type, operating system, referring website, pages viewed, the dates and times of your visits, and similar technical or usage data. This information may be collected through server logs, cookies, pixels, and similar technologies.
Third-party tools. Our Site is built on and supported by third-party platforms and service providers — including our website host and content management system, security and anti-spam services, and any analytics tools we may use — that may collect or process technical and usage data of the kind described above on our behalf. The specific providers we use may change from time to time.
3. Cookies and Similar Technologies
Cookies are small text files placed on your device that help websites function and provide information about how the site is used. The Site may use strictly necessary cookies (required for the Site to function) and analytics or performance cookies (which help us understand how visitors use the Site). Third parties that support the Site may also set cookies or use similar technologies such as pixels.
Most browsers allow you to manage or disable cookies through your settings. If you disable cookies, some features of the Site may not function properly.
4. How We Use Information
We use the information described above to operate, maintain, secure, and improve the Site; to respond to inquiries you send us; to protect against spam, fraud, and unauthorized or unlawful activity; to comply with applicable legal and regulatory obligations; and for our other legitimate business purposes.
5. How We Share Information
We do not sell personal information. We may share information: (a) with service providers that perform services on our behalf, such as website hosting, security, anti-spam, information technology, and analytics providers; (b) as required by law, regulation, subpoena, court order, or other legal process, or in response to lawful requests by governmental or regulatory authorities; (c) to enforce our rights, protect our property, or protect the rights, property, or safety of others; and (d) in connection with a merger, reorganization, sale of assets, or similar transaction involving our business.
6. Third-Party Websites and Services
The Site may contain links to websites and services operated by third parties, including our social media pages and the client login portal made available through a third-party provider. Those websites and services are governed by their own privacy policies and terms, which we do not control and for which we are not responsible. Access to the client portal is limited to authorized users and is governed by separate agreements and the portal provider’s own policies. We encourage you to review the privacy policies of any third-party site you visit.
7. Data Security
We take reasonable measures designed to protect the information described in this Privacy Policy. However, no method of transmission over the Internet or method of electronic storage is completely secure, and we cannot guarantee the security of any information transmitted to or through the Site. Any transmission is at your own risk.
8. Data Retention
We retain information for as long as reasonably necessary for the purposes described in this Privacy Policy, to comply with our legal and regulatory obligations, to resolve disputes, and to enforce our agreements.
9. Children
The Site is not directed to children, and we do not knowingly collect personal information from anyone under the age of 18. If we learn that we have collected personal information from a child under 13, we will delete it.
10. Visitors from Outside the United States
The Site is operated from the United States and is intended for users located in the United States. If you access the Site from outside the United States, you understand that your information may be transferred to, stored, and processed in the United States, where privacy laws may differ from those of your jurisdiction.
11. Your Privacy Rights
Depending on where you live, you may have rights under applicable law with respect to your personal information, such as the right to request access to or deletion of personal information we hold about you. To make a request, please contact us using the information below. We will respond as required by applicable law.
12. Changes to This Privacy Policy
We may update this Privacy Policy from time to time in our sole discretion. Changes are effective when posted to this page, and the effective date above will be revised accordingly. Your continued use of the Site after changes are posted constitutes your acceptance of the revised Privacy Policy. We encourage you to review this page periodically.
13. Contact Us
If you have questions about this Privacy Policy or our privacy practices, please contact us at:
Crom Capital Management, LLC
228 Park Ave S, PMB 57033, New York, NY 10003-1502
Email: notices@crom-llc.com
