Privacy Policy

Last Updated: February 2025

This Privacy Policy applies to the website of Willowbrook Capital, which is operated by Willowbrook SPV I LLC and its Affiliates ("Willowbrook Capital," "we," "our," or "us"), including www.willowbrookcp.com (the “Site”).

We are committed to protecting your privacy and ensuring the security of your Personal Information. This Privacy Policy outlines how we collect, use, and protect the information you provide when using our Site. By accessing or using this Site, you agree to the terms of this Privacy Policy. If you do not agree, please discontinue use of the Site.

This Privacy Policy is incorporated into and part of our Terms of Use, which govern your use of the Site.

Willowbrook Capital may update this Privacy Policy from time to time, and any changes will be posted on this page. Your continued use of the Site constitutes acceptance of any modifications.

1. Information We Collect
1. Information You Provide to Us
  You may provide information when interacting with us, including when submitting inquiries through the Site or contacting us via email, phone, or other means, which could be used to identify you (“Personal Information”). This may include:
  - Name, email address, phone number, and job title (“EPJ Information”)
  - Business information, including company name and industry (“BI Information”)
  - Any other information you voluntarily submit“Other Information”)
2. Information Collected Automatically
  When you visit our Site, we automatically collect certain information about your interaction with the Site, including:
  - Your IP address, browser type, and operating system
  - Pages visited and time spent on the Site
  - Referral sources (e.g., how you arrived at our Site)
  - Cookies and similar tracking technologies (see Cookies section below)
2. How We Use Information
We use the information collected for the following purposes:
- To respond to inquiries and provide requested services;
- To analyze how you interact with our Site and improve our Site, operations, and marketing efforts;
- To communicate with you about our investment activities, opportunities, or related matters;
- To comply with legal obligations or enforce our Terms of Use;
- To maintain and improve the content and functionality of the Services;
- To send administrative information to you, for example, information regarding the Services and changes to our terms, conditions, and policies;
- To develop new programs and services;
- To prevent fraud, criminal activity, or misuses of our Site, and to ensure the security of our IT systems, architecture, and networks; and
- To comply with legal obligations and legal process and to protect our rights, privacy, safety, or property, and/or that of our Affiliates, you, or other third parties.
Aggregated Information.We may aggregate Personal Information and use the aggregated information to analyze the effectiveness of our Site, to improve and add features to our Site, and for other similar purposes. In addition, from time to time, we may analyze the general behavior and characteristics of users of our Site and share aggregated information like general user statistics with prospective business partners. We may collect aggregated information through the Site, through Cookies, and through other means described in this Privacy Policy.

3. Information Sharing & Disclosure

We do not sell or rent your Personal Information. However, we may share Personal Information with third parties without further notice to you, unless required by law, in the following cases:

Vendors and Service Providers: To assist us in meeting business operations needs and to perform certain services and functions, we may share Personal Information with vendors and service providers, including providers of hosting services, cloud services, and other information technology services providers, event management services, email communication software and email newsletter services, financial service providers, other independent contractors, and web analytics services. Pursuant to our instructions, these parties will access, process, or store Personal Information in the course of performing their duties to us.
Legal Compliance: If required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, including to meet national security or law enforcement requirements, (ii) protect and defend our rights or property, (iii) prevent fraud, (iv) act in urgent circumstances to protect the personal safety of users of the Site, or the public, or (v) protect against legal liability.
Business Transfers: If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of all or a portion of our assets, or transition of service to another provider (collectively a “Transaction”), your Personal Information and other information may be shared in the diligence process with counterparties and others assisting with the Transaction and transferred to a successor or Affiliate as part of that Transaction along with other assets.
Affiliates: We may share Personal Information with our Affiliates, meaning an entity that controls, is controlled by, or is under common control with Willowbrook Capital. Our Affiliates will use the Personal Information we share in a manner consistent with this Privacy Policy.
With Your Consent: We may disclose your Personal Information to third parties upon your request, at your direction, or with your consent.
Other Users: certain actions you take may be visible to other users of the Site.

Please note that for purposes of this section, “sharing” does not include “sharing” as defined under the CCPA. For additional disclosures and information on our CCPA practices, please review California Privacy Rights below.

The following disclosures are intended to provide additional information about (1) the categories of Personal Information we collect, (2) the source of the Personal Information, (3) how we use each category of Personal Information, and (4) how we disclose Personal Information. These disclosures do not limit our ability to use or disclose information as described in Sections 2 and 3.

Category of Personal Information	Sources Of Personal Information	Business or Commercial Purpose for Collecting Personal Information	Disclosure of Personal Information
EPJ Information	We collect this information directly from you.	We use this information for purposes described in Section 2, including without limitation to communicate with you about our investment activities, opportunities, or related matters.	We disclose this information to our Affiliates, and in some cases, to service providers, Willowbrook Capital-funded companies, and/or other users of the Site.
BI Information	We collect this information directly from you.	We use this information for the purposes described in Section 2, including without limitation to communicate with you about our investment activities, opportunities, or related matters.	We disclose this information to our Affiliates, and in some cases, to service providers, Willowbrook Capital-funded companies, and/or other users of the Site.
Other Information	We collect this information directly from you, and it includes any other information that you voluntarily submit to us which is not expressly covered herein.	We use this information for the purposes described in Section 2, including without limitation to communicate with you about our investment activities, opportunities, or related matters.	We disclose this information to our Affiliates, and in some cases, to service providers, Willowbrook Capital-funded companies, and/or other users of the Site.

4. Security
You use the Site at your own risk. We use reasonable best efforts within our limited means of a new business to implement technical, administrative, and organizational measures designed to protect Personal Information both online and offline from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or email transmission is ever fully secure or error free. In particular, email sent to or from us may not be secure. Therefore, you should take special care in deciding what information you send to us via the Site or email. Please keep this in mind when disclosing any Personal Information to Willowbrook Capital via the Internet. In addition, we are not responsible for circumvention of any privacy settings or security measures contained on the Site, or third party websites.
5. Cookies & Tracking Technologies
We use cookies and similar tracking technologies to enhance your experience and analyze Site usage. You may disable cookies through your browser settings, but doing so may affect Site functionality.
6. Your Rights
Depending on your jurisdiction, you may have rights regarding your personal data, including access, correction, deletion, or opting out of marketing communications. To exercise your rights, contact us at www.willowbrookcp.com. If you are a California resident, please review the below section, California Privacy Rights, for additional information on your rights under the California Consumer Privacy Act (with any implementing regulations, as amended by the California Privacy Rights Act (“CPRA”), and as may be amended from time to time, “CCPA”).

7. California Privacy Rights

The CCPA imposes certain obligations on us and grants certain rights to California residents (“California Resident,” “you” or “your”) with regard to Personal Information. If you are a California Resident, please review the following information about your potential rights with regard to your Personal Information under the CCPA. The rights described herein are subject to exemptions and other limitations under applicable law. Terms used herein have the meaning ascribed to them in the CCPA. We are a “business.”

Notice at Collection and Use of Personal Information

Information We Collect. Depending on how you interact with us, we may collect the categories of personal information from or about you as identified in Personal Information We Collect and including:

Identifiers and similar information, such as your name, address, date of birth, email address, online identifiers or other similar identifiers;
Characteristics of Protected Classifications under certain federal or state laws, including gender, national origin, or marital status;
Commercial information, including records of products or services purchased, obtained, or considered, or other purchasing histories or tendencies;
Audio, electronic, visual, or similar information;
Geolocation information, such as information about your location or the location of your device;
Professional or employment-related information, including occupation, compensation, employer, and title;
Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, 34 C.F.R. Part 99);
Internet or other electronic network activity information, including interactions with our website or use of certain online tools, and IP addresses; and
Inferences drawn from any of the information identified above to create a profile reflecting your preferences or similar information.

Our Use and Collection of Information. We may collect and use Personal Information from you for the purposes described above in How We Use Information and described below in Our Collection, Use, and Disclosure of Personal Information.

Sale or Sharing of Personal Information. We do not sell or share your Personal Information (as those terms are defined under the CCPA).

How Long We Keep Information. How long we keep your Personal Information will vary depending on the type of personal data and our reasons for collecting it. The retention period will be determined by various criteria, including the purposes for which we are using it (as it will need to be kept for as long as is necessary for any of those purposes) and our legal obligations (as laws or regulations may set a minimum period for which we have to keep your personal data). In general, we will retain your Personal Information unless your account is deleted, or for as long as we require it to fulfill the business purposes for which it was collected, perform our contractual rights and obligations, or for periods required by our legal and regulatory obligations.

For more information about our privacy practices, please review our entire Privacy Policy.

Our Collection, Use, and Disclosure of Personal Information

The following disclosures are intended to provide additional information about (1) the categories of Personal Information we have collected in the preceding 12 months (as listed in Information We Collect), (2) the source of the Personal Information, (3) the business or commercial purposes for our collection of the Personal Information and (4) how we may disclose Personal Information for a business purpose. These disclosures do not limit our ability to use or disclose information as described in Sections 2 and 3. We do not sell or share your personal information (as those terms are defined under the CCPA). We do not knowingly sell or share the personal information of California Residents under 16 years old.

Category of Personal Information	Sources Of Personal Information	Business or Commercial Purpose for Collecting Personal Information	Disclosure of Personal Information
Identifiers and similar information	We collect this information directly from you.	We use this information for purposes including logging you into your account, granting you access to the Site, enforcing community norms and policies, monitoring security, and password recovery.	We disclose this information to our Affiliates, and in some cases, to service providers, Willowbrook Capital-funded companies, and/or other users of the Site.
Characteristics of Protected Classifications	We collect this information directly from you.	We use this information as directed by you and in some cases, to compile and publish aggregated statistics.	We disclose this information to our Affiliates, and in some cases, to Willowbrook Capital-funded companies, and/or other users of the Site.
Commercial Information	We collect this information from you directly when you sign up for the Site, and from your interactions with the Site.	We use this information to provide you with the Site and to improve the Site.	We disclose this information to our Affiliates and analytics providers.
Geolocation Information	We collect this information directly from you through your interactions with the Site.	We use this information for analytics purposes, regulatory compliance, and in some cases, for moderation and fraud prevention.	We disclose this information to our Affiliates and analytics providers.
Professional or employment-related information	We collect this information directly from you.	We use this information to provide you with the Site.	We disclose this information to our Affiliates, and in some cases, to Y Combinator-funded companies, and/or other users of the Site.
Internet or other electronic network activity information	We collect this information directly from you through your interactions with the Site.	We use this information to improve the Site, for analytics, and for moderation and fraud prevention.	We disclose this information to our Affiliates and analytics providers.
Inferences drawn from any of the information identified above	We collect this information directly from you through your interactions with the Site.	We use this information to improve and personalize the Site.	We disclose this information to our Affiliates.

In addition, in the preceding 12 months, we may have disclosed all of the categories of Personal Information identified in Information We Collect above to the following categories of third parties: (i) judicial courts, regulators, or other government agents purporting to have jurisdiction over us, our subsidiaries or our Affiliates, or opposing counsel and parties to litigation; and (ii) other third parties as may otherwise be permitted by law. We may disclose the categories of Personal Information identified in Information We Collect for the business or commercial purposes identified above in How We Use Information. Additionally, we may disclose your Personal Information to third parties upon your request, at your direction, or with your consent.

We may also disclose your Personal Information or otherwise make it available to our service providers, other entities that have agreed to limitations on the use of your Personal Information, or entities that fit within other exemptions or exceptions in, or as otherwise permitted by, the CCPA.

California Resident’s Privacy Rights

To the extent provided for by law and subject to applicable exceptions, California residents may have the following privacy rights in relation to the Personal Information we collect, including the right to:

Be informed, at or before the point of collection, of the categories of Personal Information to be collected,and the purposes for which the categories of Personal Information shall be used;
Know what Personal Information we have collected and how we have used and disclosed that PersonalInformation (“Request to Know”);
Request deletion of your Personal Information, subject to certain exemptions (“Request to Delete”);
Opt-out of the “sale” (as that term is defined in the CCPA) of your personal information if a business sells your Personal Information (we do not);
Opt-out of the “sharing” (as that term is defined in the CCPA) of your Personal Information if a business shares your Personal Information with third parties (we do not);
Limit the use and disclosure of sensitive personal information where required by the CCPA (“Right toLimit”) (please note that we are not using your sensitive personal information for purposes that would require that we provide you with a Right to Limit);
Correct inaccurate Personal Information (“Request to Correct”); and
Be free from discrimination relating to the exercise of any of your privacy rights.

The CCPA does not restrict our ability to do certain things like comply with other laws or comply with regulatory investigations. We also reserve the right to retain, and not to delete, certain Personal Information after receipt of a Request to Delete from you where permitted by the CCPA or another law or regulation.

Exercising Your Rights. California residents can exercise their right to Request to Know, Request to Correct or Request to Delete (“Consumer Rights Request”) as described above, by contacting us at privacy@willowbrookcp.com.

Verification. In order to protect your Personal Information from unauthorized access or deletion, we may require you to verify your login credentials before you can submit a Consumer Rights Request. In verifying your request, we may ask you to provide additional Personal Information and proof of residency for verification. Such information may include, at a minimum, depending on the sensitivity of the information you are requesting and the type of request you are making, your name and email address. Any information gathered as part of the verification process will be used for verification purposes only. If we cannot verify your identity, we will not provide, delete or correct your Personal Information.

Authorized Agents. You may submit a Consumer Rights Request through an authorized agent. If you do so, the agent must present signed written permission to act on your behalf and you may also be required to independently verify your identity and submit proof of your residency with us.

Shine the Light Disclosures. California law requires us to inform California residents who have provided us with personal information that they may request information from us about our disclosures to third parties for their direct marketing purposes. To request this information, please contact us at privacy@willowbrookcp.com. In your request, please specify that this is a “California 'Shine the Light' Request.”

8. Children
Our Site is not directed to children who are under the age of 13. Willowbrook Capital does not knowingly collect Personal Information from children under the age of 13. If you have reason to believe that a child under the age of 13 has provided Personal Information to Willowbrook Capital through the Site, please contact us at privacy@willowbrookcp.com and we will endeavor to delete that information from our databases.
9. Links to Other Websites
The Site may contain links to other websites not operated or controlled by Willowbrook Capital, including social media services (“Third Party Sites”). The information that you disclose to Third Party Sites will be governed by the specific privacy policies and terms of service of the Third Party Sites and not by this Privacy Policy. By providing these links we do not imply that we endorse or have reviewed these sites. Please contact the ThirdParty Sites directly for information on their privacy practices and policies.
10. International Users
By using our Services, you understand and acknowledge that your Personal Information will be transferred from your location to our facilities and servers in the United States.
11. Changes to the Privacy Policy
The Site and our business may change from time to time. As a result we may change this Privacy Policy at any time. When we do, we will post an updated version on this page, unless another type of notice is required by the applicable law. By continuing to use our Site or providing us with Personal Information after we have posted an updated Privacy Policy, or notified you by other means if applicable, you consent to the revised Privacy Policy and practices described in it.
12. Contact Us
If you have any questions regarding this Privacy Policy, please contact us.
Willowbrook Capital
Malibu, CA
Website: www.willowbrookcp.com