INTRODUCTION
Urgent Management LLC ("Manager," "we," "us," or "our"), a Washington limited liability company operating on behalf of Urgent Capital Company LLC (the "Fund"), is committed to protecting the privacy of individuals who visit our website, inquire about our offerings, or invest through the Fund.This Privacy Policy explains what information we collect, how we use and protect it, with whom we share it, and what rights you have with respect to your personal information. It applies to information collected through our website at urgentcap.com (the "Site") and through any related communications, forms, or investor onboarding processes.Please read this policy carefully. By using the Site or engaging with us in connection with any offering, you agree to the practices described here.
1. INFORMATION WE COLLECT
We collect information in two ways: information you provide to us directly, and information collected automatically when you use the Site.A. Information You ProvideContact and Inquiry Information. When you contact us, complete a form on the Site, or express interest in an offering, we may collect your name, email address, phone number, mailing address, and the nature of your inquiry.Investor Onboarding Information. If you apply to invest in the Fund, we collect information necessary to evaluate your eligibility and complete the subscription process. This includes:— Full legal name, date of birth, and government-issued identification— Social Security Number or Tax Identification Number— Residential and mailing address— Employment, income, and net worth information— Entity documentation (for non-individual investors), including formation documents, ownership charts, and beneficial ownership certifications— Bank account information for funding and distribution purposes— Executed subscription agreements and related certificationsAccredited Investor Verification Documents. Because the Fund conducts its offerings under Rule 506(c) of Regulation D, we are required by law to verify that each investor qualifies as an Accredited Investor. Depending on the verification method you choose, this may include tax returns, W-2 or 1099 forms, brokerage or bank statements, or a third-party verification letter from a licensed CPA, attorney, registered investment adviser, or broker-dealer.These documents contain sensitive financial information. We treat them with heightened care and use them only for the purposes described in this policy.Communications. We retain records of correspondence between you and us, including emails, call notes, and responses to investor surveys or questionnaires.B. Information Collected AutomaticallyWhen you visit the Site, we and our service providers may automatically collect certain technical information, including:— IP address and approximate geographic location— Browser type and version— Device type and operating system— Pages visited, time spent, and referring URLs— Cookie identifiers and similar tracking dataThis information is collected through cookies, web beacons, and similar technologies, as described further in Section 7 below.C. Information We Collect From Third PartiesWe may obtain information about you from third parties in connection with investor onboarding, identity and accredited-investor verification, and regulatory compliance. These sources may include identity-verification and accredited-investor verification providers, anti-money-laundering and sanctions-screening vendors, consumer reporting agencies, custodians, and publicly available databases. We may use this information to verify your identity and accredited-investor status, conduct sanctions screenings, and detect and prevent fraud.────────────────────────────────────────────────────────────2. HOW WE USE YOUR INFORMATIONWe use the information we collect for the following purposes:To evaluate investor eligibility. We use personal and financial information to determine whether a prospective investor qualifies as an Accredited Investor and meets any other eligibility criteria for participation in the Fund.To process subscriptions and manage investor relationships. We use investor information to execute subscription agreements, process capital contributions and distributions, maintain investor records, and communicate regarding the status of investments.To comply with legal and regulatory obligations. We are subject to federal and state requirements that mandate collection, verification, and retention of certain investor information. This includes anti-money laundering (AML) and know-your-customer (KYC) obligations under the Bank Secrecy Act and applicable state law, as well as Regulation D requirements for accredited investor verification.To communicate with you. We use contact information to respond to inquiries, send updates about the Fund, share investor reports, and provide other information you have requested or that is relevant to your investment.To operate and improve the Site. We use automatically collected data to monitor Site performance, understand how visitors use the Site, identify technical issues, and improve the user experience.To protect our rights and the rights of investors. We may use information to detect and prevent fraud, unauthorized activity, or violations of our terms of use.We do not sell your personal information. We do not use investor information for marketing purposes unrelated to the Fund or its offerings.────────────────────────────────────────────────────────────3. HOW WE SHARE YOUR INFORMATIONWe do not sell, rent, or trade your personal information to third parties. We share information only in the following circumstances:Service Providers. We engage third-party service providers to assist with investor onboarding, document management, accredited investor verification, fund administration, tax reporting, and other operational functions. These providers access your information only as necessary to perform their services and are contractually required to protect it.Fund Administration and Legal. We share investor information with the Fund's administrators, legal counsel, accountants, and auditors as necessary to manage the Fund, prepare financial statements, file tax returns, and fulfill regulatory obligations.Affiliates. We may share your information with Urgent Management LLC’s affiliates and entities under common control, and with other pooled investment vehicles they sponsor or manage, for purposes consistent with this Policy, including fund administration, investor servicing, and regulatory compliance. Any use of your information by an affiliate to inform you of other investment opportunities will be subject to the limitations described in this Policy.Accredited Investor Verification Platforms. If you use a third-party verification service to confirm your accredited investor status, that service will collect and process your financial documents pursuant to its own privacy policy. We receive only a confirmation of your verified status, not the underlying documents, unless you submit documents directly to us.Regulatory and Legal Requirements. We may disclose information to government agencies, regulators, or law enforcement when required by law, legal process, or regulation, including in response to a subpoena, court order, or regulatory inquiry. We may also disclose information to protect the rights, property, or safety of Urgent Capital, its investors, or others.Business Transfers. In the event of a merger, acquisition, restructuring, or sale of all or a portion of the Manager's business or assets, investor information may be transferred as part of that transaction, subject to the same protections described in this policy.With Your Consent. We may share your information for any other purpose with your prior written consent.────────────────────────────────────────────────────────────4. ANTI-MONEY LAUNDERING AND KNOW-YOUR-CUSTOMER COMPLIANCEAs part of our legal obligations, we are required to collect and verify certain identity and source-of-funds information from all investors. This process, commonly referred to as AML/KYC compliance, may include identity verification, screening against government watchlists and sanctions databases (including OFAC), and review of the source of invested funds.You are required to provide accurate and complete information in connection with AML/KYC review. Failure to do so may result in the rejection of your subscription or, in the case of identified violations, mandatory reporting to the appropriate authorities.Information collected for AML/KYC purposes is retained in accordance with applicable law, which may require retention for a minimum of five years following the end of the investor relationship.────────────────────────────────────────────────────────────5. DATA SECURITYWe maintain reasonable administrative, technical, and physical safeguards designed to protect your personal information against unauthorized access, disclosure, alteration, or destruction. Sensitive documents submitted for investor verification are encrypted in transit and at rest.No method of electronic transmission or storage is completely secure. While we work to protect your information, we cannot guarantee absolute security. If you have reason to believe that your interaction with us has been compromised, please contact us immediately at team@urgentcap.com.────────────────────────────────────────────────────────────6. DATA RETENTIONWe retain personal information for as long as necessary to fulfill the purposes described in this policy and to comply with our legal obligations.Investor records, including subscription documents, accredited investor verification files, and transaction history, are generally retained for a minimum of seven years following the end of the investor relationship, or longer if required by applicable law or regulation.Site usage data and inquiry records that do not result in a subscription are generally retained for no more than three years, after which they are deleted or anonymized.────────────────────────────────────────────────────────────7. COOKIES AND TRACKING TECHNOLOGIESThe Site uses cookies and similar tracking technologies to operate certain features, analyze Site traffic, and improve the user experience.Essential Cookies. These are required for the Site to function and cannot be disabled. They include session management and security functions.Analytics Cookies. We use analytics tools (such as Google Analytics) to understand how visitors use the Site. This data is aggregated and does not identify individual users. You may opt out of Google Analytics tracking by installing the Google Analytics Opt-out Browser Add-on available at tools.google.com/dlpage/gaoptout.You can control cookie settings through your browser preferences. Disabling certain cookies may affect the functionality of the Site.We do not use cookies to serve advertising or to track your activity across third-party websites.────────────────────────────────────────────────────────────8. THIRD-PARTY LINKSThe Site may contain links to third-party websites, platforms, or resources. We are not responsible for the privacy practices or content of those third parties. We encourage you to review the privacy policies of any third-party sites you visit.────────────────────────────────────────────────────────────9. UNSOLICITED INFORMATIONThis Policy applies only to information collected by us as described above. It does not apply to any unsolicited information you provide to us through the Site or by any other means, including information posted to any public area of the Site and any ideas, suggestions, or materials you submit without our request (collectively, “Unsolicited Information”). All Unsolicited Information will be deemed non-confidential, and we may use, reproduce, disclose, and distribute such Unsolicited Information without restriction or attribution.────────────────────────────────────────────────────────────10. YOUR PRIVACY RIGHTSDepending on where you reside, you may have certain rights regarding your personal information.Washington State Residents. Washington's My Health MY Data Act and related state privacy regulations may afford you rights, including the right to know what personal information we hold about you, the right to request correction of inaccurate information, and the right to request deletion of personal information, subject to legal retention requirements.California Residents. Under the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), California residents may have the right to know what personal information we collect, disclose, and sell (we do not sell personal information); the right to delete personal information, subject to exceptions; the right to correct inaccurate personal information; and the right to non-discrimination for exercising privacy rights.To submit a privacy rights request, please contact us at team@urgentcap.com. We will respond within the timeframe required by applicable law. We may need to verify your identity before processing a request. Please note that certain information may be exempt from deletion or access requests where retention is required by law, including investor and AML/KYC records.All Individuals. Regardless of location, you may contact us at any time to update your contact information, correct inaccuracies, or ask questions about how your data is handled.────────────────────────────────────────────────────────────11. CHILDREN'S PRIVACYThe Site is not directed to individuals under the age of 18. We do not knowingly collect personal information from minors. If you believe we have inadvertently collected information from a minor, please contact us at team@urgentcap.com, and we will promptly delete it.────────────────────────────────────────────────────────────12. CHANGES TO THIS POLICYWe may update this Privacy Policy from time to time to reflect changes in our practices, applicable law, or regulatory requirements. When we make material changes, we will update the "Last Updated" date at the top of this page. We encourage you to review this policy periodically. Your continued use of the Site following any update constitutes your acceptance of the revised policy.────────────────────────────────────────────────────────────13. CONTACTQuestions, requests, or concerns regarding this Privacy Policy may be directed to:Urgent Management LLCAttn: Jacob Wilson33530 1st Way S, Suite 102Federal Way, WA 98003team@urgentcap.com253.313.8384────────────────────────────────────────────────────────────