Privacy Policy

Effective: March 28, 2025

Our Commitment to You

Mindoro Capital Partners LLC (“Mindoro” or the “Advisor”) is committed to safeguarding the use of personal information of our Clients (also referred to as “you” and “your”) that we obtain as your Investment Advisor, as described here in our Privacy Policy (“Policy”).

Our relationship with you is our most important asset. We understand that you have entrusted us with your private information, and we do everything that we can to maintain that trust. Mindoro (also referred to as "we", "our" and "us”) protects the security and confidentiality of the personal information we have and implements controls to ensure that such information is used for proper business purposes in connection with the management or servicing of our relationship with you.

Mindoro does not sell your non-public personal information to anyone. Nor do we provide such information to others except for discrete and reasonable business purposes in connection with the servicing and management of our relationship with you, as discussed below.

Details of our approach to privacy and how your personal non-public information is collected and used are set forth in this Policy.

Why you need to know?

Registered Investment Advisors (“RIAs”) must share some of your personal information in the course of servicing your account. Federal and State laws give you the right to limit some of this sharing and require RIAs to disclose how we collect, share, and protect your personal information.

What information do we collect from you?

Driver's License

Social security or taxpayer identification number

Name, address and phone number[s]

E-mail address[es]

Account information (including other institutions)

Date of birth
Assets and liabilities

Income and expenses

Investment activity

Investment experience and goals

Custody, brokerage and advisory agreements

Other advisory agreements and legal documents

Transactional information with us or others

Account applications and forms

Investment questionnaires and suitability

documents

Other information needed to service account

Basis For Sharing

Servicing our Clients

We may share non-public personal information with non-affiliated third parties (such as administrators, brokers, custodians, regulators, credit agencies, other financial institutions) as necessary for us to provide agreed upon services to you, consistent with applicable law, including but not limited to: processing transactions; general account maintenance; responding to regulators or legal investigations; and credit reporting.

Do we share?

Yes

Can you limit?

Marketing Purposes

Mindoro does not disclose, and does not intend to disclose, personal information with non-affiliated third parties to offer you services. Certain laws may give us the right to share your personal information with financial institutions where you are a customer and where Mindoro or the client has a formal agreement with the financial institution. We will only share information for purposes of servicing your accounts, not for marketing purposes.

Not Shared

Authorized Users

Your non-public personal information may be disclosed to you and persons that we believe to be your authorized agent[s] or representative[s].

Yes

Information About Former Clients

Mindoro does not disclose and does not intend to disclose, non-public personal information to non-affiliated third parties with respect to persons who are no longer our Clients.

Not Shared

What Information do we collect from other sources?

How do we protect your information?

To safeguard your personal information from unauthorized access and use we maintain physical, procedural and electronic security measures. These include such safeguards as secure passwords, encrypted file storage and a secure office environment. Our technology vendors provide security and access control over personal information and have policies over the transmission of data. Our associates are trained on their responsibilities to protect Client’s personal information.

We require third parties that assist in providing our services to you to protect the personal information they receive from us

How do we share your information?

An RIA shares Client personal information to effectively implement its services. In the section below, we list some reasons we may share your personal information.

State-specific Regulations

California

In response to a California law, to be conservative, we assume accounts with California addresses do not want us to disclose personal information about you to non-affiliated third parties, except as permitted by California law. We also limit the sharing of personal information about you with our affiliates to ensure compliance with California privacy laws.

Massachusetts

In response to Massachusetts law, the Client must “opt-in” to share non-public personal information with non-affiliated third parties before any personal information is disclosed. Client opt-in is obtained through the Client’s execution of authorization forms provided by the third parties, by executing an Information Sharing Authorization Form, or by other written consent by the Client, as appropriate and consistent with applicable laws and regulations.

Vermont

In response to a Vermont regulation, if we disclose personal information about you to non-affiliated third parties, we will only disclose your name, address, other contract information, and general information about our experience with you.

Changes to our Privacy Policy

We will send you a copy of this Policy annually for as long as you maintain an ongoing relationship with us.

Periodically we may revise this Policy and will provide you with a revised Policy if the changes materially alter the previous Privacy Policy. We will not, however, revise our Privacy Policy to permit the sharing of non-public personal information other than as described in this notice unless we first notify you and provide you with an opportunity to prevent the information sharing.

Any Questions?

You may ask questions or voice any concerns, as well as obtain a copy of our current Privacy Policy by contacting us at (617) 214-2313.

Mobile Application Privacy Addendum

Effective: January 1, 2026

This Mobile Application Privacy Addendum (“Addendum”) supplements the Privacy Policy above and applies solely to information collected through the Mindoro Capital Partners mobile application (the “App”).

Applicability
This Addendum applies only to information collected through the App and does not replace or modify Mindoro’s Privacy Policy governing its investment advisory services.

Information Collected Through the App

The App may collect limited information necessary to operate and maintain functionality, including:
Contact or authentication information voluntarily provided by the user
Technical information such as IP address, device type, operating system, or app version
App usage or diagnostic data (such as logs or crash reports)

The App does not collect sensitive personal information unless required to provide requested functionality.

Use of Information
Information collected through the App is used only to:

Operate, secure, and maintain the App
Authenticate users
Monitor performance and resolve technical issues
Comply with applicable legal and regulatory requirements

Third-Party Service Providers
The App may use third-party service providers for hosting, security, and application performance support. These providers may process limited information solely to perform services on Mindoro’s behalf and are required to protect such information.

Data Retention and Deletion
Information collected through the App is retained only as long as necessary for the purposes described above or as required by law. Users may request access to, correction of, or deletion of App-related information by contacting Mindoro.

Children’s Privacy
The App is not directed to children under the age of 13, and Mindoro does not knowingly collect personal information from children.

Security
Mindoro maintains reasonable administrative, technical, and physical safeguards designed to protect information collected through the App.

Availability
This Privacy Policy and Mobile Application Privacy Addendum are available on Mindoro’s public website, within the App, and through the Google Play Store listing.

Contact
Mindoro Capital Partners LLC
Email: contact@mindoro.com