Privacy Policy

Effective Date: January 1, 2025

Overlay Capital ("Overlay," "we," "our," or "us") respects your right to privacy and is committed to protecting your personal data in accordance with applicable data privacy regulations, including the California Consumer Privacy Act (CCPA). This Privacy Policy describes the information we collect from visitors to our website at overlaycapital.com (the "Website"), how it is used, and how we protect it. This policy does not address our privacy practices for investors, which are covered in separate notices as required by law.

What Information is Collected?

We collect information about visitors to our Website in the following ways:

• Automatically Collected Information: When you access the Website, certain information is automatically collected through cookies, web server logs, and similar technologies. This includes your Internet Protocol (IP) address, browser type, information about the time, duration, and frequency of your visits, and details about specific pages visited.
• Voluntarily Submitted Information: We collect information you voluntarily provide, such as your name, email address, and phone number when signing up for our mailing list or submitting inquiries.

We do not collect Social Security Numbers, financial account numbers, or other sensitive personal data through the Website. Sensitive data related to investments is managed through secure, third-party platforms and stored on our internal systems using trusted service providers.

How Do We Use Your Personal Data?

We use the personal data we collect for:

• Communication: To respond to inquiries, send updates, and provide information about Overlay and our services. By providing your telephone number, you consent to receive SMS text messages from us. We will not share your phone number or messaging data with third parties for marketing purposes. You can opt out at any time by replying STOP. Message and data rates may apply.
• Business Operations: To manage and improve our Website and maintain customer relationship systems.
• Compliance: To fulfill legal, regulatory, and contractual obligations as a state-registered investment advisor.

Information Sharing

We do not sell or transfer personal data to unaffiliated third parties for value. We may share your information as follows:

• Service Providers: With vendors or service providers who assist us in operating our business, such as email distribution or customer relationship platforms.
• Affiliates: Within the Overlay group of companies for internal business purposes.
• Regulatory Authorities: As required to comply with applicable laws or regulatory obligations.

Information Security

Overlay Capital implements commercially reasonable security measures to protect your personal data, including:

• Restricting access to sensitive data to authorized personnel.
• Employing technical, physical, and administrative safeguards to prevent unauthorized access, disclosure, or alteration of information.

Despite these measures, no data transmission or storage system is guaranteed to be completely secure. Any transmission of data is at your own risk.

Third-Party Websites and Content

Our Website may include links to or embedded content from third-party websites. These websites may collect data about you, use cookies, or embed additional third-party tracking. We are not responsible for the privacy policies or content of these external websites and encourage you to review their policies before interacting with them.

California Privacy Rights

If you are a California resident, you have rights under the CCPA, including:

• Right to Know: Request details about the personal data we collect and how we use it.
• Right to Delete: Request deletion of your personal data, subject to legal or regulatory exceptions.
• Right to Opt-Out: Opt-out of any sale of your personal data.
• Non-Discrimination: You will not be discriminated against for exercising these rights.

To exercise your rights, please contact us at general@overlaycapital.com.

Updates to This Privacy Policy

This Privacy Policy may change periodically to reflect updates in our practices or applicable laws. Changes will be posted on this page with an updated "Effective Date."

Contact Information

If you have any questions about this Privacy Policy or how we handle your personal data, please contact us at:

Overlay Capital
11720 Amber Park Drive Suite 425
Alpharetta, GA 30009

general@overlaycapital.com
[US +1] 770 – 415 – 0595

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