Terms of Use

Crom Capital Management

Effective date: January 1, 2026

1. Acceptance of These Terms

These Terms of Use (these “Terms”) govern your access to and use of the website located at https://crom-capital.com (the “Site”), which is operated by Crom Capital Management, LLC and its affiliated entities (collectively, “Crom,” “we,” “us,” or “our”). By accessing or using the Site, you accept and agree to be bound by these Terms and by our Privacy Policy, which is incorporated into these Terms by reference. If you do not agree to these Terms, do not access or use the Site. If you are dissatisfied with the Site or these Terms, your sole and exclusive remedy is to discontinue using the Site.

2. Informational Purposes Only; No Offer or Solicitation

The information and materials on the Site are provided for general informational purposes only. Nothing on the Site constitutes, and nothing on the Site should be construed as, an offer to sell, or a solicitation of an offer to buy, any security, financial instrument, investment product, or service, in any jurisdiction. Any offer or solicitation with respect to any securities of, or interests in, any fund, account, or other vehicle managed by Crom may be made only by means of definitive offering documents delivered to qualified recipients in transactions that comply with applicable securities laws, and any such offering documents will supersede in their entirety the information contained on the Site.

3. No Investment, Legal, or Tax Advice; No Advisory Relationship

Crom is a private investment firm. Nothing on the Site constitutes investment, legal, accounting, or tax advice, or a recommendation to buy, sell, or hold any security or to pursue any investment strategy. The content of the Site is not tailored to the circumstances of any particular person, and your use of the Site does not create any advisory, fiduciary, client, or similar relationship between you and Crom. You should consult your own legal, tax, accounting, and financial advisors before making any investment decision, and any decision based on information contained on the Site is your sole responsibility.

4. Past Performance; Forward-Looking Statements

Any description on the Site of investments, strategies, or results is for illustrative purposes only, does not purport to be complete, and should not be relied upon in making any investment decision. Past performance is not indicative, and is no guarantee, of future results. The Site may contain statements that are forward-looking in nature; such statements reflect judgments and assumptions as of the date they were made, are subject to risks and uncertainties, may prove to be incorrect, and are subject to change without notice. Crom undertakes no obligation to update any information on the Site.

5. Client Login Portal

The client login link on the Site provides access to a portal operated by a third-party service provider. Access to the portal is limited to authorized users and is governed by separate agreements between you and Crom and by the portal provider’s own terms and policies. These Terms do not grant any right of access to the portal, and Crom is not responsible for the availability or operation of the portal or the acts or omissions of its provider.

6. Intellectual Property

All text, images, graphics, logos, designs, and other content on the Site (collectively, “Content”) are the property of Crom or its licensors and are protected by copyright, trademark, and other intellectual property laws. The Crom name and logo may not be used or displayed without our prior written consent. You may view the Content for your personal, non-commercial use only. You may not reproduce, redistribute, publish, transmit, modify, or otherwise use the Content, in whole or in part, by any means, without our prior written consent.

7. Third-Party Websites

The Site may contain links to websites owned or operated by third parties. These links are provided solely as a convenience. Crom does not control, monitor, or endorse such websites and is not responsible for their content, accuracy, security, or privacy practices, or for any products or services offered through them. If you access a third-party website through the Site, you do so at your own risk, and links to or from the Site do not indicate any affiliation between Crom and the linked party.

8. Restrictions on Use

You may not use the Site for any unlawful purpose. You agree not to violate, or attempt to violate, the security of the Site, including by accessing data not intended for you, probing or testing the vulnerability of any system or network, or transmitting any virus, worm, malicious code, or other computer routine intended to damage, disrupt, or impair the Site or any system or data. You may not use automated means to access or copy the Site or its Content except as permitted by standard search-engine indexing.

9. Disclaimer of Warranties

THE SITE AND ALL CONTENT ARE PROVIDED ON AN “AS IS” AND “AS AVAILABLE” BASIS, WITHOUT WARRANTY OF ANY KIND. TO THE FULLEST EXTENT PERMITTED BY APPLICABLE LAW, CROM EXPRESSLY DISCLAIMS ALL WARRANTIES, EXPRESS OR IMPLIED, INCLUDING WITHOUT LIMITATION THE IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, TITLE, AND NON-INFRINGEMENT. CROM DOES NOT WARRANT THAT THE SITE WILL BE UNINTERRUPTED, TIMELY, SECURE, OR ERROR-FREE; THAT THE CONTENT IS ACCURATE, COMPLETE, OR CURRENT; OR THAT THE SITE OR THE SERVERS THAT MAKE IT AVAILABLE ARE FREE OF VIRUSES OR OTHER HARMFUL COMPONENTS. ANY MATERIAL OBTAINED THROUGH THE SITE IS OBTAINED AT YOUR OWN DISCRETION AND RISK.

10. Limitation of Liability

TO THE FULLEST EXTENT PERMITTED BY APPLICABLE LAW, CROM AND ITS AFFILIATES, AND THEIR RESPECTIVE MEMBERS, MANAGERS, PARTNERS, OFFICERS, DIRECTORS, EMPLOYEES, AND AGENTS, SHALL NOT BE LIABLE FOR ANY DIRECT, INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, PUNITIVE, OR EXEMPLARY DAMAGES — INCLUDING WITHOUT LIMITATION DAMAGES FOR LOSS OF PROFITS, USE, DATA, OR OTHER INTANGIBLES — ARISING OUT OF OR RELATING TO YOUR USE OF, OR INABILITY TO USE, THE SITE OR ANY CONTENT, EVEN IF ADVISED OF THE POSSIBILITY OF SUCH DAMAGES, AND REGARDLESS OF THE FORM OF ACTION, WHETHER IN CONTRACT, WARRANTY, TORT (INCLUDING NEGLIGENCE), STRICT LIABILITY, OR OTHERWISE. BECAUSE SOME JURISDICTIONS DO NOT ALLOW THE EXCLUSION OR LIMITATION OF CERTAIN DAMAGES, IN SUCH JURISDICTIONS LIABILITY IS LIMITED TO THE FULLEST EXTENT PERMITTED BY LAW.

11. Indemnification

You agree to indemnify, defend, and hold harmless Crom and its affiliates, and their respective members, managers, partners, officers, directors, employees, and agents, from and against any claims, liabilities, damages, losses, and expenses (including reasonable attorneys’ fees) arising out of or relating to your use of the Site or your violation of these Terms.

12. Users Outside the United States

Crom makes no representation that the Site is appropriate or available for use in locations outside the United States. If you access the Site from outside the United States, you do so at your own initiative and are responsible for compliance with applicable local laws and regulations.

13. Changes to the Site and These Terms

Crom reserves the right, in its sole discretion and without notice, to change, modify, suspend, or discontinue any aspect of the Site, and to amend these Terms at any time by posting revised Terms to this page. Revisions are effective when posted, and your continued use of the Site after revisions are posted constitutes your acceptance of the revised Terms. Please review this page periodically.

14. Governing Law and Venue

These Terms, and any dispute arising out of or relating to these Terms or the Site, are governed by and construed in accordance with the laws of the State of Delaware, without regard to its conflict-of-laws principles. You agree that any action arising out of or relating to these Terms or the Site shall be brought exclusively in the state or federal courts located in the State of Delaware, and you consent and submit to the personal jurisdiction of such courts.

15. Miscellaneous

These Terms, together with the Privacy Policy, constitute the entire agreement between you and Crom regarding your use of the Site and supersede any prior understandings on that subject. If any provision of these Terms is held invalid or unenforceable, the remaining provisions will continue in full force and effect. Crom’s failure to enforce any provision of these Terms is not a waiver of that provision or of the right to enforce it later. You may not assign these Terms; Crom may assign them without restriction.

16. Contact

Questions about these Terms may be directed to:

Crom Capital Management, LLC

228 Park Ave S, PMB 57033, New York, NY 10003-1502

Email: notices@crom-llc.com