Last Revision Date:  November 16, 2023

1. Introduction. TRI-AD Capital Management I, LLC (‘We,’ ‘Us,’ ‘Our,’ or ‘TCMI’) is committed to protecting your privacy and providing you a safe online experience. Your privacy is important to Us and We are committed to safeguarding it. This Privacy Policy describes Our data handling practices with respect to Personal Information We gather in connection with your use of the Site.
2. Personal Information We Process. By accessing and using Our Site, you provide Us with certain Personal Information. Personal Information is any combination of information in the possession of TCMI that can be used to identify, contact, or locate a discrete individual, and any expression of opinion about an individual is covered.
3. Purposes for Processing Your Personal Information. We use the Personal Information you provide and the personalized data you create and save through the Site to:
   • Respond to information requests made by you after you submit a request for information on Our Site;
   • to protect against fraud, suspicious or other illegal activities; and to improve the Service we provide and deliver a more personalized experience by enabling us to:
     • Store information about your preferences, allowing Us to customize Our Service according to your individual interests.
     • Speed up your searches.
     • Recognize you when you use the Site.
4. How We Collect Your Personal Information. TCMI acquires information (1) you voluntarily provide Us through Our Site or (2) automatically collected through the navigation of Services through Our Site.
   1. Information You Provide to Us. If you elect to request information using the Contact Us form on Our Site, certain personal information is requested so we can contact you back. This information includes name, employer, email address and telephone number.
   2. Information Automatically Collected.
      1. When you access and navigate Our Service, We may use technology to automatically collect information such as:
         • Usage Details. When you access and use Our Service, We may automatically collect certain details of your access to and use of the Service, including traffic data, location data, logs, and other communication data and the resources that you access and use on or through the Service.
         • Device Information. We may collect information about your internet connection, including your IP address, operating system, and browser type.
         • Stored Information and Files. The Service also may access metadata and other information associated with other files stored on your computer.
      2. Technologies used to Automatically Collect and Track Information. TCMI may use the following technologies in Our platform.
         • Cookies. Cookies are pieces of information shared between your web browser and Our platform.  Use of cookies enables a faster and easier user experience. There are different kinds of cookies with different functions:
           • Session cookies: these are only stored on your computer during your web session. They are automatically deleted when the browser is closed.  They usually store an anonymous session ID allowing you to browse Services without having to log in to each page. They do not collect any information from your computer.
           • Persistent cookies: a persistent cookie is one stored as a file on your computer, and it remains there when you close your web browser. The cookie can be read by a website that created it when you visit that website again.
           • First-party cookies: this type of cookie is used to retain your preferences for a particular website for the entity that owns that website. They are stored and sent between Our servers and your computer’s hard drive. They are not used for anything other than for personalization as set by you. These cookies may be either Session or Persistent cookies.
           • Third-party cookies: This type of cookie is used to retain your interaction with a particular website for an entity that does not own that website. They are stored and sent between the third party’s server and your computer’s hard drive. These cookies are usually Persistent cookies.
         • Web Beacons. Pages of the Service, and emails from Us, may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit Us, for example, to count users who have visited those pages or opened an email and for other related app statistics (for example, recording the popularity of certain app content and verifying system and server integrity).
5. Accuracy, Accountability, Openness and Access. You may contact Us to request access to, correct, or delete any personal Information that you have provided to Us. We will delete your personal Information provided by you on Our Site when requested. 
6. Sale and Disclosure of Personal Information. We do not sell or market your personal Information or personalized data to unaffiliated organizations. We may disclose:
   • Information which has been de-identified or aggregated so as not be able to identify a discernible individual may be disclosed without restriction
   • Personal information We collect or that you provide us with may be disclosed:
     • To our subsidiaries and affiliates.
     • To contractors, service providers, and other third parties We use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which We disclose it to them.
     • In a bankruptcy or similar proceeding in which personal information held by TCMI about our Service users is among the assets transferred.
     • To fulfill the purpose for which you provide it. For example, if you give Us an email address to use the “contact” feature of our Website or Service, We will transmit the contents of that email and your email address to the recipients.
     • For any other purpose disclosed by Us when you provide the information.
     • To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
     • To enforce our rights arising from the terms of service entered into between you and Us.
     • If We believe disclosure is necessary or appropriate to protect the rights, property, or safety of TCMI, Our customers or others. This includes exchanging information with other companies and organizations for the purposes of identity theft prevention, fraud protection, and financial risk reduction.
7. Third Party Information Collection. Our Services offered through Site may contain links or other content related to websites, advertisers, products and/or services offered by third Persons. We have no control over and make no representations with respect to third person property or any information transmitted via such third person property, or otherwise provided by any such third persons. Use of links to such third person property is at your own risk, as such links and third person property are governed by terms of use and privacy policies outside Our Services. As such, TCMI is not responsible for any use outside the scope of Our Services.
8. California Privacy Rights
   1. California Civil Code § 1798.83 permits California residents using Our website to request and obtain a list of personal information We disclosed to third parties for their direct marketing purposes during the preceding calendar year as well as the names and addresses of those third parties. To make such a request, please contact Us at info@tcmiadvisors.com.
   2. California Civil Code § 1798.100 et seq. grants California residents various privacy rights to their personal information including:
      • Right of access. You have the right to request access to personal information that We collected for the previous 12 months. Please note that if your access request requires the disclosure of personal information of another individual, We won’t be able to comply with all of your access request. Similarly, if responding to your access request would cause Us to violate any law, rule, regulation, or law enforcement request, We would not be able to fulfill your request.
      • Right of deletion. You have the right to request that We delete personal information that We collected from you. However, We are not required to comply with your request if it is necessary for us or our service provider to maintain your personal information in order to complete the transaction with you, detect security incidences, identify and repair errors, exercise free speech, comply with the California Electronic Communications Privacy Act, engage in certain public interest research, use internally so long as reasonably aligned with your expectations, comply with a legal obligation or otherwise use your personal information internally so long as it is compatible with the context in which you provided it.
      • Right to opt-out. You have the right to opt-out of the sale of your personal information to third parties. However, TCMI does not sell your personal information to third parties as contemplated by California law.
      • Right not to be discriminated against for exercising these rights. You have the right to be free of discrimination for exercising your consumer privacy rights. As we do not engage in activities which require you to exercise rights under California law, we will not deny you goods or services, charge different amounts or provide a different quality level of goods or services for exercising your rights.
      • How to Exercise Your Rights. In order to exercise your rights, you may submit a request by contacting Us through this website. 
9. Modifications; Additional Terms. We reserve the right to update our Privacy Policy from time to time. If there is any material change to your rights or how We treat your personal information under this Privacy Policy, We will post the new Privacy Policy on this website with a notice that the privacy policy has been updated. Identification of when the Privacy Policy has last been updated is located at the top left corner of the page. (“Last Revision Date: _____). You are responsible for periodically visiting this Privacy Policy to check for changes and your continued use of the Site is deemed your acceptance of the modified Privacy Policy.
10. Security. We have implemented commercially reasonable administrative, procedural, and technical measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. Measures will vary depending on the sensitivity, format, location, amount, distribution and storage of the personal information. However, due to the nature of the Internet and related technology, We cannot absolutely guarantee the security of personal information, and TCMI expressly disclaims any such obligation. You hereby acknowledge and understand that such risk is inherent in interacting with any website, including this Site, and take full responsibility for any harm, danger or damage that ensues. If you have any questions about the security of your information, you may contact us at the e-mail or physical address listed below.
11. Contact Information. TCMI or its agents may provide notice to you by means of a general posting at the Site or to your Company email address. To ask questions or comment about this Privacy Policy and our privacy practices, contact us via our mailing address or email at:

TRI-AD Capital Management I, LLC
221 West Crest Street, Suite 300 
Escondido, CA 92025
info@tcmiadvisors.com