Privacy Policy

Effective Date: June 8, 2026

Last Updated: June 6,2026

Northwind Investment Group (“Northwind,” “we,” “us,” or “our”) respects your privacy and is committed to protecting the personal information you share with us. This Privacy Policy explains what information we collect, how we use it, how we share it, and the choices you have, including in connection with our text messaging (SMS) communications.

This Policy applies to visitors of northwindig.com and any related subdomains (including our Investor Portal), and to individuals who communicate with us by phone, email, text message, or through our online forms (collectively, the “Services”).

By using our Services, you agree to the terms of this Privacy Policy. If you do not agree, please do not use our Services.

1. Information We Collect

We may collect the following categories of information:

a) Information you provide directly

• Contact details (name, email address, phone number, mailing address, company/firm name)
• Information submitted through our forms (e.g., “Invest With Us,” “Request Materials,” “Contact Us”)
• Information you provide when communicating with us by phone, email, or SMS text message
• Information related to your accreditation status or investment interests, where voluntarily provided
• Information submitted through our Investor Portal

b) Information collected automatically

• Device and browser information, IP address, and general location data
• Website usage data (pages visited, time on site, referring URLs) via cookies and analytics tools (e.g., Google Analytics, Google Tag Manager)

c) Text messaging (SMS) data

If you communicate with us by text message (for example, as a broker or business partner corresponding with Northwind regarding a transaction, deal, or negotiation), we collect:

• Your mobile phone number
• The content of text messages exchanged with our team
• The date, time, and status of messages
• Your consent/opt-in status and any opt-out (STOP) requests

No mobile information will be shared with third parties or affiliates for marketing or promotional purposes. All other categories of information may be shared as described in Section 3 below, but this exclusion applies specifically and at all times to text messaging originator opt-in data and consent — this information is never shared with any third party for any purpose, including marketing.

2. How We Use Your Information

We use the information we collect to:

• Communicate with you, including responding to inquiries and conducting business correspondence (by phone, email, or SMS)
• Provide, maintain, and improve our Services and website
• Process and manage relationships with brokers, partners, and prospective investors
• Send you requested materials, updates, or account-related information
• Maintain records of communications for business, compliance, and recordkeeping purposes, including logging communications in our internal customer relationship management (CRM) system
• Comply with applicable laws, regulations, and legal processes
• Detect and prevent fraud or unauthorized activity

We do not use text messaging opt-in data to make automated decisions that produce legal or similarly significant effects, and we do not sell text messaging data.

3. How We Share Your Information

We may share information with:

• Service providers who perform services on our behalf (e.g., our communications platform provider Aircall, our CRM provider HubSpot, IT hosting, and analytics providers), solely to help us provide and operate our Services
• Professional advisors (legal, accounting, compliance) as needed
• Regulators or governmental authorities, where required by law, regulation, or legal process
• A successor entity, in the event of a merger, acquisition, or sale of assets, subject to standard confidentiality protections

We do not sell your personal information, and — as stated above — we do not share SMS opt-in or consent data with any third party for marketing or promotional purposes under any circumstance.

4. Data Retention

We retain personal information, including SMS communications, for as long as reasonably necessary to fulfill the purposes described in this Policy, to maintain accurate business records, and to comply with our legal, accounting, and regulatory obligations. Retention periods vary depending on the type of information and the nature of our relationship with you.

5. Your Rights and Choices

Text messages: You may opt out of receiving text messages from Northwind at any time by replying STOP to any message. You may request help at any time by replying HELP. See our Terms and Conditions for full details on our SMS program.

Marketing communications: You may unsubscribe from marketing emails at any time using the unsubscribe link included in those emails.

Access, correction, and deletion: Depending on your location, you may have the right to request access to, correction of, or deletion of your personal information. To make such a request, contact us using the details in Section 10 below.

California residents: If you are a California resident, you may have additional rights under the California Consumer Privacy Act (CCPA), including the right to know what personal information we collect, the right to request deletion, and the right to opt out of the “sale” or “sharing” of personal information (Northwind does not sell personal information). To exercise these rights, contact us using the details below.

6. Cookies and Tracking Technologies

Our website uses cookies and similar tracking technologies (including Google Analytics and Google Tag Manager) to understand how visitors use our site and to improve our Services. You can control cookies through your browser settings. Disabling cookies may affect certain website functionality.

7. Data Security

We implement reasonable administrative, technical, and physical safeguards designed to protect personal information from unauthorized access, use, or disclosure. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.

8. Children’s Privacy

Our Services are intended for individuals who are at least 18 years old and are not directed to children. We do not knowingly collect personal information from children under 18.

9. Important Notice for Investors

This Privacy Policy governs general website and communications data (including SMS). If you become an investor in a Northwind fund, additional privacy and data-handling terms will apply as set out in that fund’s subscription agreement and related offering documents, which govern investor information collected for regulatory compliance, fund administration, and investor reporting purposes. For questions about investor-specific data handling, please contact your Northwind fund administrator directly.

10. Contact Us

If you have questions about this Privacy Policy or wish to exercise any of the rights described above, please contact us:

Northwind Investment Group

2125 Biscayne Blvd, Suite 345

Miami, FL 33137, USA

Phone: (888) 842-0476

Email: [email protected]

11. Changes to This Policy

We may update this Privacy Policy from time to time. The “Last Updated” date at the top of this page reflects the most recent revision. Material changes will be posted on this page.