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Privacy Policy

Praetorian Capital 12/08/2025

We respect your privacy and are committed to protecting it and we always have been. The purpose of this Privacy Policy is to inform you what information we may collect and how it may be used.

This statement applies to www.pracap.com.

This Privacy Policy describes how we collect, use, process and distribute your information, including Personal Data (as defined below) used to access this Website. We will not use or share your information with anyone except as described in this Privacy Policy. The use of information collected through our Website shall be limited to the purposes under this Privacy Policy and our Terms of Use for customers.

Please read this Privacy Policy carefully. We reserve the right to change this Privacy Policy on the Website at any time without notice. In the event of a material change, we will let you know via email and / or a prominent notice on our Website. Use of any personal information or contribution that you provide to us, or which is collected by us on or through our Website or its content is governed by this Privacy Policy. By using our Website or its content, you consent to this Privacy Policy, whether or not you have read it.

WHAT INFORMATION DO WE COLLECT AND HOW IS IT USED?

Children’s Privacy: We do not knowingly collect Personal Data from children under 13. If such data is identified, it will be deleted promptly.

We collect personal information from you so that we can provide you with a positive experience when utilizing our Website or content. We will only collect the minimum amount of information necessary for us to fulfill our obligation to you.

We may collect:

  • A name and an email address so we can deliver our digital newsletter to you – you would be affirmatively consenting to this by providing this to us in our contact forms.
  • A name and an email address if you complete our contact form with a question.
  • We may send you marketing emails with either your consent or if we believe we have a legitimate interest to contact you based on your contact or question.
  • Information from you from a co-branded offer. In this case, we will make clear as to who is collecting the information and whose privacy policy applies. If both / all parties are retaining the information you provide, this will also be made clear as will links to all privacy policies.

Please note that the information above (“Personal Data”) that you are giving to us is voluntary, and by you providing this information to us you are giving consent for us to use, collect and process this Personal Data. You are welcome to opt-out or request for us to delete your Personal Data at any point by contacting us at info@pracap.com. If you choose not to provide us with certain Personal Data, you may not be able to participate in certain aspects of our Website or content.

Other Information We May Collect:

Anonymous Data Collection and Use

Google Analytics and HubSpot Analytics: We use Google Analytics for anonymized traffic analysis; Google may process IP and device identifiers. We use HubSpot for marketing automation and behavioral metrics collection. To maintain our Website’s high quality, we may use your IP address to help diagnose problems with our server and to administer the Website by identifying which areas of the Website are most heavily used, and to display content according to your preferences. Your IP address is the number assigned to computers connected to the Internet. This is essentially “traffic data” which cannot personally identify you, but is helpful to us for marketing purposes and for improving our services. Traffic data collection does not follow a user’s activities on any other websites in any way. Anonymous traffic data may also be shared with business partners and advertisers on an aggregate basis.

Use of “Cookies”

Cookie Consent and Options: We may use the standard “cookies” feature of major web browsers. We do not currently deploy a standalone cookie banner. By using the Website, you consent to essential and analytics cookies. We do not set any personally identifiable information in cookies, nor do we employ any data-capture mechanisms on our Website other than cookies. You may choose to disable cookies through your own web browser’s settings. However, disabling this function may diminish your experience on our Website and some features may not work as intended.

We are currently working on deploying a granular cookie preference center to allow users to more easily manage and withdraw consent for specific categories of cookies (e.g., analytics).

What We Do With Information We Collect

Contact You

We may contact you with information that you provide to us based on these lawful grounds for processing:

  • Consent: If you give us your clear, unambiguous, affirmative consent to contact you.
  • Contractual Obligation: We will contact you under our contractual obligation to deliver goods or services you purchase from us.
  • Legitimate Interest: We may contact you if we feel you have a legitimate interest in hearing from us. For example, if you sign up for a webinar, we may send you marketing emails based on the content of that webinar.

You will always have the option to opt out of any of our emails.

Submission, Storage, Sharing and Transferring of Personal Data

Personal Data that you provide to us is stored internally or through a data management system. Your Personal Data will only be accessed by those who help to obtain, manage or store that information, or who have a legitimate need to know such Personal Data (i.e., our hosting provider, newsletter provider, payment processors or team members).

It is important to note that we may transfer data internationally. For users in the European Union, please be aware that we transfer Personal Data outside of the European Union. By using our Website and providing us with your Personal Data, you consent to these transfers in accordance with this Privacy Policy.

Third-Party Data Processors and Categories of Data Shared: We use trusted third parties as our data processors for technical and organizational purposes, including for payments and email marketing. We may share your Name, Email Address, and Website Behavior Metrics (e.g., pages viewed) with the following categories of third-party vendors for the purpose of essential website functionality, analytics, and marketing:

  • Cloud Hosting Provider: For website operation and data storage.
  • Email Marketing/CRM Provider (HubSpot): For managing and sending newsletters and marketing communications.
  • Analytics Providers (Google Analytics, HubSpot): For analyzing website traffic and user behavior.
  • Payment Processors: For processing transactions when you purchase goods or services. We only share your Personal Data with trusted third parties who use the same level of care in processing your Personal Data.

Data Retention

CPRA Retention Disclosure: Identifiers such as emails are retained until you unsubscribe or request deletion; analytics data is retained per provider schedules. We retain your Personal Data for the minimum amount of time necessary to provide you with the information and/or services that you requested from us. We may include certain Personal Data for longer periods of time if necessary for legal, contractual and accounting obligations.

Confidentiality

We aim to keep the Personal Data that you share with us confidential. Please note that we may disclose such information if required to do so by law or in the good-faith belief that: (1) such action is necessary to protect and defend our rights or property or those of our users or licensees, (2) to act as immediately necessary in order to protect the personal safety or rights of our users or the public, or (3) to investigate or respond to any real or perceived violation of this Privacy Policy or of our Disclaimer, Terms and Conditions, or any other terms of use or agreement with us.

How You Can Access, Update or Delete Your Personal Data

You have the right to:

  • Request information about how your Personal Data is being used and request a copy of what Personal Data we use.
  • Restrict processing if you think the Personal Data is not accurate, unlawful, or no longer needed.
  • Rectify or erase Personal Data and receive confirmation of the rectification or erasure. (You have the “right to be forgotten”).
  • Withdraw your consent at any time to the processing of your Personal Data.
  • Lodge a complaint with a supervisory authority if you feel we are using your Personal Data unlawfully.
  • Receive Personal Data portability and transference to another controller without our hinderance.
  • Object to our use of your Personal Data.
  • Not be subject to an automated decision based solely on automatic processing, including profiling, which legally or significantly affects you.

Responding to Requests: We will respond to all legitimate user rights requests, including those for access, deletion, and correction, within 45 calendar days of receiving the request, in compliance with applicable laws (such as CPRA). If we require more time (up to 90 days total), we will notify you of the reason and the extension period in writing.

Unsubscribe

You may unsubscribe from our e-newsletters or updates at any time through the unsubscribe link at the footer of all email communications. If you have questions or are experiencing problems unsubscribing, please contact us at info@pracap.com.

Security

We take commercially reasonable steps to protect the Personal Data you provide to us from misuse, disclosure or unauthorized access. We only share your Personal Data with trusted third parties who use the same level of care in processing your Personal Data. That being said, we cannot guarantee that your Personal Data will always be secure due to technology or security breaches. Should there be a data breach of which we are aware, we will inform you immediately.

Anti-Spam Policy

We have a no spam policy and provide you with the ability to opt-out of our communications by selecting the unsubscribe link at the footer of all e-mails. We have taken the necessary steps to ensure that we are compliant with the CAN-SPAM Act of 2003 by never sending out misleading information. We will not sell, rent or share your email address.

Third Party Websites

We may link to other websites on our Website. We have no responsibility or liability for the content and activities of any other individual, company or entity whose website or materials may be linked to our Website or its content, and thus we cannot be held liable for the privacy of the information on their website or that you voluntarily share with their website. Please review their privacy policies for guidelines as to how they respectively store, use and protect the privacy of your Personal Data.

California Privacy Rights (CCPA/CPRA)

California residents may request access, deletion, correction, and opt‑out of sale or sharing of Personal Data.

Sale and Sharing Disclosure: We do not sell Personal Data. Limited analytics-based ‘sharing’ may occur; opt‑out requests are honored via our contact email. Except when required by law, we will not sell, distribute, or reveal your email addresses or other personal information without your consent; however, we may disclose or transfer personal information collected through the Website to third parties who acquire all or a portion of our business, which may be the result of a merger, consolidation, or purchase of all or a portion of our assets, or in connection with any bankruptcy or reorganization proceeding brought by or against us.

Global Privacy Control: We recognize GPC signals as valid opt‑out requests.

Notification of Changes

We may use your Personal Data, such as your contact information, to inform you of changes to the Website or its content, or, if requested, to send you additional information about us. We reserve the right, at our sole discretion, to change, modify or otherwise alter our Website, its content and this Privacy Policy at any time. Such changes and/or modifications shall become effective immediately upon posting our updated Privacy Policy. Please review this Privacy Policy periodically. Continued use of any information obtained through or on the Website or its content following the posting of changes and/or modifications constituted acceptance of the revised Privacy Policy. Should there be a material change to our Privacy Policy, we will contact you via email or by a prominent note on our Website.

Changelog: Updated December 8, 2025:

  • Added specific categories of third-party data processors and the types of Personal Data shared.
  • Added Hubspot and Google analytics disclosure
  • Added Children’s Privacy
  • Added CPRA Retention
  • Added Sale and Sharing Disclosures
  • Added Contact address
  • Added expected response time (45 days) for user rights requests.
  • Added a notice regarding the future deployment of a granular cookie preference center.
  • Added a section on Dispute Resolution.

Dispute Resolution

In the event of any controversy or claim arising out of or relating to this Privacy Policy, the parties shall first attempt to settle the dispute through good-faith negotiation. If a dispute arising under this Privacy Policy cannot be resolved through negotiation, the parties agree to resolve the dispute in accordance with the provisions outlined in our Terms of Use.

Data Controller and Processors

We are the data controllers as we are collecting and using your Personal Data. We use trusted third parties as our data processors for technical and organizational purposes, including for payments and email marketing. We use reasonable efforts to make sure our data processors are GDPR- compliant.

GDPR Compliance: For EEA/UK users, Personal Data is processed under lawful bases including consent, contractual necessity, and legitimate interests.

Cross ‑ Border Transfers: International transfers rely on Standard Contractual Clauses or equivalent safeguards.

EU/UK Representative: We do not target or market to EEA/UK users; therefore an Article 27 representative is not designated.

SENSITIVE PERSONAL INFORMATION

CPRA SPI Notice: We do not collect Sensitive Personal Information as defined under CPRA, including precise geolocation, government ID numbers, or biometric identifiers. At no time should you submit sensitive personal information to the Website. This includes your social security number, information regarding race or ethnic origin, political opinions, religious beliefs, health information, criminal background, or trade union memberships. We would never ask for such information. If you elect to submit such information to us, it will be subject to this Privacy Policy.

CONTACT INFORMATION

At any time, please contact us at info@pracap.com for questions related to this Privacy Policy.

Contact Address: Praetorian PR, 2420 Ave. Albizu Campos #427, Rincon, PR, 00677. Contact Phone: (786) Six Eight Eight – 3375.

 

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Disclaimer

Nothing in this article, podcast or communication (collectively, referred to as the “Communication”) should be construed as investment advice of any kind. This Communication is not a recommendation, or an offer to sell, or a solicitation of any offer to buy, an interest in any security or derivative instrument, including an interest in any investment vehicle managed or advised by Praetorian PR LLC and affiliates (together “Praetorian”). Consult your financial adviser before making any investment decisions.

Unless noted otherwise, the information presented by Praetorian within the contents of Communication, represent opinions of Harris Kupperman or Praetorian and no representation is made with respect to the accuracy, completeness or timeliness of information, and Praetorian assumes no obligation to update or revise such information. As such, the opinions may not be complete, are subject to change, and are provided for informational purposes only. Additionally, certain information may be based on third party sources and, although believed to be reliable, has not been independently verified and Praetorian is not responsible for third-party errors.

The views expressed in the Communication may include forward-looking statements as of the original date of the publication which may be identified by, among other things, the use of words such as “expects,” “anticipates,” “believes,” or “estimates,” or these terms’ negatives, and similar expressions. Forward-looking statements reflect Praetorian’s opinions as of such date with respect to possible future events. Actual results could differ materially from those in the forward-looking statements. No party has an obligation to update any of the forward-looking statements in this document. Investors are cautioned not to place undue reliance on such statements.

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