Privacy Policy

This Privacy Policy (“Policy”) applies to personal information collected by Donum LLC, Donum Capital, and the Donum Charitable Lending Fund (DCLF1) (collectively, “Donum,” “we,” “us,” or “our”) through our public-facing websites, including donumplan.com and any related subdomains or applications that link to this Policy (collectively, the “Services”).

By accessing or using the Services, you acknowledge that you have read and understood this Policy. If you do not agree with our practices, please do not use the Services.

We collect information you provide directly to us, information collected automatically when you use the Services, and information we receive from third parties.

a. Information You Provide.

• Contact details such as your name, email address, telephone number, and mailing address when you complete a contact form or request information.
• Professional and financial context you choose to share with us, such as your advisor relationship, investment objectives, or a general description of the tax-planning scenario you would like to discuss.
• Communications you send to us, including the content of emails, voicemails, and messages submitted through our forms.

b. Information Collected Automatically.

• Device and usage data such as IP address, browser type, operating system, referring URLs, pages viewed, and timestamps.
• Cookies, pixels, and similar technologies described in Section 5.

c. Information From Third Parties.

We may receive information from service providers, analytics vendors, financial and legal professionals who refer you to us, and publicly available sources, to the extent permitted by applicable law.

We do not knowingly collect sensitive personal information (such as Social Security numbers, account numbers, or health information) through our public website. Any such information required to evaluate or administer a specific plan is collected through separate, secure onboarding channels and is subject to the engagement documentation you receive at that time.

We use the information we collect to:

• Respond to your inquiries and provide the information, materials, or introductions you request;
• Evaluate whether a Donum program may be appropriate for your situation and coordinate with your advisors;
• Operate, maintain, secure, and improve the Services and our programs;
• Send administrative communications, such as confirmations, updates to legal documents, and notices of changes to the Services;
• Personalize content and, where permitted, provide you with relevant information about Donum programs and events;
• Comply with applicable laws, regulations, U.S. Treasury guidance, court orders, and lawful requests from government authorities; and
• Detect, prevent, and respond to fraud, abuse, security incidents, and other harmful activity.

Donum does not sell your personal information. We share information only as described below:

• Within the Donum family of companies for the purposes described in this Policy and consistent with the regulatory role of each entity.
• Service providers that perform services on our behalf, including hosting, analytics, email delivery, customer support, document execution, and professional services. These providers are contractually required to protect your information and use it only for the purposes we authorize.
• Your advisors (such as your attorney, CPA, or financial advisor) when you direct us to do so or when doing so is reasonably necessary to evaluate or administer a plan.
• Legal and safety disclosures when we believe disclosure is necessary to comply with a subpoena, court order, or other legal process; to enforce our agreements; or to protect the rights, property, or safety of Donum, our clients, or others.
• Business transactions such as a merger, acquisition, reorganization, or sale of assets, in which case personal information may be transferred as part of the transaction and remain subject to protections at least as protective as this Policy.

We and our service providers use cookies, pixels, local storage, and similar technologies to operate the Services, remember your preferences, measure performance, and understand how visitors engage with our content.

Most browsers let you control cookies through their settings. If you disable or refuse cookies, some parts of the Services may not function properly. Where required by law, we obtain consent before placing non-essential cookies.

We retain personal information for as long as is reasonably necessary to fulfill the purposes described in this Policy, to comply with our legal, tax, accounting, and regulatory obligations, to resolve disputes, and to enforce our agreements. When information is no longer needed, we delete, anonymize, or securely archive it in accordance with our retention standards.

Depending on where you live, you may have certain rights with respect to your personal information, which may include the right to:

• Access or receive a copy of the information we hold about you;
• Request correction of inaccurate or incomplete information;
• Request deletion of personal information, subject to legal and regulatory retention obligations;
• Opt out of certain uses or disclosures of your information;
• Withdraw consent where we rely on consent as the legal basis for processing; and
• Lodge a complaint with a supervisory authority in your jurisdiction.

To exercise these rights, please contact us using the details in Section 13. We will verify your request and respond within the time required by applicable law. We do not discriminate against you for exercising your rights.

We maintain administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, loss, misuse, and alteration. No system is perfectly secure, and we cannot guarantee the security of information transmitted to or from the Services. You are responsible for keeping your credentials confidential and for notifying us promptly of any suspected unauthorized access.

The Services are directed to adults and are not intended for children under the age of 18. We do not knowingly collect personal information from children. If you believe a child has provided us with personal information, please contact us and we will take reasonable steps to delete it.

The Services are operated in the United States and are intended for users located in the United States. If you access the Services from outside the United States, you acknowledge that your information will be transferred to, processed, and stored in the United States, where data protection laws may differ from those in your jurisdiction.

The Services may contain links to third-party websites, tools, or services that are not owned or controlled by Donum. This Policy does not apply to those third parties. We encourage you to review the privacy practices of each third party before providing them with your information.

We may update this Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes, we will update the “Last updated” date above and, where appropriate, provide additional notice (such as by email or a prominent notice on the Services). Your continued use of the Services after the updated Policy takes effect constitutes your acceptance of the changes.

If you have questions about this Privacy Policy or our privacy practices, or if you would like to exercise your rights, please contact us at:

Donum — Privacy Office
Email: privacy@donumplan.com
Website: www.donumplan.com

This document is provided for informational purposes and is being reviewed by counsel. Final terms will be posted following legal review.