Concierge Management, LLC (“Concierge Management,” “we,” “us”) operates the website cmngt.com, the investor portal, and the Concierge Management mobile app (together, the “Services”). This policy explains what information we collect through the Services, how we use it, and the choices you have.

Account information. Your name, email address, and login credentials. Investor accounts are created by invitation only; passwords are handled by Amazon Cognito and are never visible to our staff.

Investor profile information. For each investor profile: name, profile type, mailing address, phone number, date of birth, and Social Security number or Employer Identification Number, plus an optional profile picture.

Investment records. The projects you are invested in, contributions, distributions, and the private documents we share with you, such as statements and tax forms.

Requests you send us. Profile change requests, including any new picture you upload, and messages you send to us.

Security and technical information. Sign-in times, a device identifier used to recognize your phone for secure sign-in, a notification token if you allow push notifications, and basic server logs used to protect the Services.

Visitors to our public pages can browse without an account. We do not use advertising or analytics trackers.

• To provide the investor portal and app: showing your investments, transactions, and documents.
• To review and apply profile changes you request.
• To send the account emails and push notifications you have not turned off, such as notice that a new document or distribution is available.
• To keep accounts secure, prevent fraud, and meet our legal, tax, and record-keeping obligations.

• We do not sell or rent your personal information.
• We do not use your information for advertising or track you across other apps or websites.
• Emails and push notifications may show the project name, a transaction’s amount and quarter, or a new document’s type and name. They never contain Social Security numbers, Employer Identification Numbers, or document contents; you sign in to see details.

The Services run on Amazon Web Services in the United States. Data is encrypted in transit (HTTPS) and at rest. Social Security numbers and Employer Identification Numbers are separately encrypted with a dedicated key and are only ever shown masked to the last four digits. Documents are stored privately and opened through short-lived secure links. Access by our staff is limited to authorized administrators.

In the mobile app, your sign-in is kept in your phone’s secure storage (the iPhone Keychain or the Android Keystore) and is unlocked with Face ID, Touch ID, your fingerprint, or your passcode. If you choose “Remember me,” your password is also kept in that secure storage, protected the same way, and it never leaves your phone. Signing out removes it.

No method of transmission or storage is completely secure, but we work to protect your information using industry-standard safeguards.

We share information only with service providers that help us run the Services, and only as needed: Amazon Web Services (hosting, storage, sign-in, and email delivery), Apple and Expo (delivering push notifications, which contain no financial details), and professional advisers such as accountants or attorneys where required for our business.

We may also disclose information when required by law, to protect the rights and safety of our investors or others, or as part of a business transfer, subject to this policy.

• Profile updates: request changes in the portal or app under your profile.
• Notifications: turn email notices off in the portal, and push notifications off in the app’s Account tab or your phone’s settings.
• Camera and photos: the app only accesses them when you choose to add a profile picture, and you can revoke access in your phone’s settings.
• Access or copies: email us to request a copy of the personal information we hold about you.

You can request deletion of your account at any time from the app (Account → Request account deletion) or by emailing admin@cmngt.com. We will confirm the request, close your login, and delete personal information we are not required to keep.

Because we manage investments, certain records, such as transactions, tax documents, and related identity information, must be kept for the periods required by law and for legitimate business purposes. Those records remain protected under this policy until they can be deleted.

The Services are intended for investors and are not directed to children under 13. We do not knowingly collect information from children.

We may update this policy from time to time. We will post the updated version here with a new effective date and, for significant changes, notify investors by email or in the portal.

Questions or requests about your privacy: admin@cmngt.com.