Privacy Policy

Old Tom Capital (“Old Tom,” “we,” “our,” or “us”) is committed to respecting the privacy of individuals who visit our website or otherwise interact with us online. This Privacy Policy describes how we collect, use, store, and safeguard information obtained through oldtomcapital.com and related digital properties (collectively, the “Site”).

This Privacy Policy applies solely to information collected through the Site. It does not apply to information collected offline, through portfolio companies, or in connection with any separate contractual, advisory, or investment relationship.

Information We Collect

We collect limited information that is necessary to operate the Site, respond to inquiries, and evaluate potential business or investment-related interest.

Information may be collected in two ways:

Information you provide voluntarily.

You may choose to provide personal or professional information when you contact us, request information, submit materials, or otherwise communicate through the Site. This may include your name, email address, company or affiliation, title, and any information you elect to share in correspondence or document submissions.

Information collected automatically.

When you access the Site, certain technical information may be collected automatically, including IP address, browser type, device information, operating system, referring URLs, pages viewed, and interaction timestamps. This information is used to support Site functionality, security, and performance analysis.

We do not knowingly collect sensitive personal data, nor do we knowingly collect information from individuals under the age of 18.

How We Use Information

Information collected through the Site is used solely for legitimate business purposes consistent with the operation of an institutional investment platform.

These purposes include responding to inquiries, providing requested information, evaluating potential business, investment, or partnership interest, operating and improving the Site, monitoring usage and performance, maintaining security, and complying with applicable legal or regulatory obligations.

Old Tom Capital does not sell personal information, does not engage in consumer marketing, and does not use Site-collected information for advertising or behavioral profiling.

Cookies and Similar Technologies

The Site may use cookies or similar technologies to enable core functionality, maintain security, and understand how the Site is accessed and used. These technologies help us improve performance and user experience but are not used for third-party advertising or tracking across unrelated websites.

You may control or disable cookies through your browser settings. Doing so may affect certain Site functionality.

Information Sharing and Disclosure

Old Tom Capital does not share personal information with unaffiliated third parties for marketing purposes.

Information may be shared on a limited basis with trusted service providers who perform services on our behalf, such as website hosting, analytics, or IT support, and only to the extent necessary for those services to be provided. Such service providers are subject to confidentiality and data protection obligations.

We may also disclose information if required to do so by law, regulation, or legal process, or where we believe disclosure is necessary to protect the rights, property, or security of Old Tom Capital or others.

Data Security

We maintain reasonable administrative, technical, and physical safeguards designed to protect information collected through the Site against unauthorized access, loss, misuse, or alteration. While we take data protection seriously, no system or transmission method can be guaranteed to be completely secure, and we cannot ensure absolute security.

Third-Party Websites

The Site may contain links to third-party websites for convenience or informational purposes. Old Tom Capital is not responsible for the privacy practices, policies, or content of third-party sites. We encourage visitors to review the privacy policies of any external sites they access.

International Visitors

The Site is operated from the United States. If you access the Site from outside the United States, please be aware that information may be transferred to, stored, and processed in jurisdictions where data protection laws may differ from those in your country of residence.

Updates to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or Site operations. Any updates will be effective upon posting to the Site. The “Last Updated” date above indicates the most recent revision.

Contact Information

Questions regarding this Privacy Policy or our data practices may be directed to: Old Tom Capital

Email: info@oldtomcapital.com