PRIVACY AND COOKIE POLICY
1. DATA CONTROLLER
Your personal data will be processed by EdgeCraft Capital Management LLC, a Delaware limited liability company (Tax ID: 41-2545168, Registration No. 527641), with its principal office at 8 The Green, Suite B, Dover, Delaware 19901, United States (hereinafter "EdgeCraft"), which is the entity responsible for the website www.edgecraftgroup.com (the "Website") and acts as data controller under Regulation (EU) 2016/679 of the European Parliament and of the Council (the "GDPR").
This Privacy and Cookie Policy (the "Policy") provides information about the processing of personal data for which EdgeCraft acts as data controller, without prejudice to more detailed information that may be contained in other documents, which shall prevail over this Policy.
Website users should also consult the Terms of Service for information regarding the terms governing use of the Website.
For any questions, please contact EdgeCraft at info@edgecraft.com.
2. DEFINITIONS AND LEGAL BASES
"Personal Data" means any information relating to an identified or identifiable natural person. "Processing" means any operation performed on personal data, whether or not by automated means, including collection, recording, organization, storage, use, disclosure, erasure, or destruction.
EdgeCraft processes personal data based on the following legal bases under GDPR:
• Consent for processing for one or more specific purposes (Article 6(1)(a))
• Performance of a contract or pre-contractual measures at the data subject's request (Article 6(1)(b))
• Compliance with a legal obligation (Article 6(1)(c))
• Legitimate interests pursued by EdgeCraft, except where overridden by the interests or fundamental rights and freedoms of the data subject (Article 6(1)(f))
3. DATA PROCESSING DETAILS
Purpose: Inquiries and requests submitted via Website contact forms
Legal Basis: Pre-contractual measures (Article 6(1)(b)) / Legitimate interest (Article 6(1)(f))
Retention Period: 2-3 years after last contact
Purpose: Investor and prospective investor relations
Legal Basis: Performance of contract (Article 6(1)(b)) / Legitimate interest (Article 6(1)(f))
Retention Period: 7 years after relationship ends
Purpose: Billing, collection, legal actions, and compliance with fiscal obligations
Legal Basis: Legal obligation (Article 6(1)(c)) / Legitimate interest (Article 6(1)(f))
Retention Period: Applicable legal period; if none exists, 10 years
Purpose: Compliance with legal obligations and response to regulatory authorities
Legal Basis: Legal obligation (Article 6(1)(c))
Retention Period: Applicable legal period
Purpose: Unsolicited marketing communications
Legal Basis: Consent (Article 6(1)(a))
Retention Period: Until consent withdrawal or 3 years of inactivity
Purpose: Website analytics and cookies
Legal Basis: Consent (Article 6(1)(a)) / Legitimate interest (Article 6(1)(f))
Retention Period: Session to 2 years depending on cookie type
The Website is intended for users aged 18 and over. We do not knowingly collect data from individuals under 18.
4. COOKIES AND TRACKING TECHNOLOGIES
Cookies are small text files stored on your device when you visit a website. We use the following types of cookies:
Essential Cookies
Necessary for the Website to function properly. Set by Squarespace (our hosting platform) for basic website functionality, security, and user sessions. These cannot be disabled.
Analytical Cookies
Help us understand how visitors interact with our Website through Squarespace's built-in analytics. These are optional and require your consent.
Marketing Cookies
Used by third-party services to deliver relevant advertisements. These are optional and require your consent. May include:
• HubSpot (CRM and marketing automation)
• Google Ads (advertising campaigns)
• Meta Pixel/Facebook (conversion tracking)
• Substack (newsletter distribution, if implemented)
You can manage your cookie preferences through the cookie banner on our Website or through your browser settings. Note that disabling essential cookies may affect Website functionality. For more information about cookies, visit www.allaboutcookies.org.
5. RECIPIENTS OF PERSONAL DATA
EdgeCraft may share your personal data with the following categories of recipients:
• IT service providers (Squarespace, HubSpot, Google, Meta, Substack)
• Marketing and communications service providers
• Legal, accounting, and audit service providers
• Regulatory authorities and government agencies when required by law (SEC, tax authorities, courts)
6. INTERNATIONAL DATA TRANSFERS
EdgeCraft is based in the United States. Personal data from EU/EEA users will be transferred to and processed in the United States. We ensure appropriate safeguards are in place:
• EU-US Data Privacy Framework (when applicable)
• Standard Contractual Clauses approved by the European Commission
7. YOUR RIGHTS UNDER GDPR
If you are located in the EU/EEA, you have the following rights:
• Access: Request access to your personal data and information about how it is processed
• Rectification: Request correction of inaccurate or incomplete personal data
• Erasure: Request deletion of your personal data in certain circumstances
• Restriction: Request restriction of processing in certain circumstances
• Data Portability: Receive your personal data in a structured, machine-readable format
• Object: Object to processing based on legitimate interests or for direct marketing
• Withdraw Consent: Withdraw consent at any time where processing is based on consent
• Lodge a Complaint: File a complaint with your local data protection authority (in the EU/EEA, see https://edpb.europa.eu/about-edpb/board/members_en)
To exercise your rights, contact us at info@edgecraft.com. We will respond within one month, though this may be extended by two months in complex cases. Exercise of these rights is free of charge, unless requests are manifestly unfounded or excessive.
8. DATA SECURITY
We implement appropriate technical and organizational security measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. We will notify you promptly of any data breaches as required by law.
9. CHANGES TO THIS POLICY
We may update this Policy from time to time. Any changes will be posted on the Website with a revised date. We encourage you to review this Policy periodically. Your continued use of the Website after changes indicates acceptance of the updated Policy.
10. CONTACT INFORMATION
For questions regarding this Policy or to exercise your rights, please contact:
EdgeCraft Capital Management LLC
8 The Green, Suite B
Dover, Delaware 19901
United States
Email: info@edgecraft.com
*
Last Updated: February 11, 2026