Old North Capital Fund (“ONCF”, “we,” or “us”) is committed to protecting and respecting your privacy.

Scope of Policy

This policy, together with our General Terms of Service, applies to your use of our website at
https://oncfund.com/ (the “Site”), including, without limitation, all services accessible through the Site.

This policy sets out the basis on which any personal or business data we collect from you, or that you provide to us, will be processed and disclosed by ONCF. Please read the following carefully to understand our collection, use, and disclosure of your information.

Important Disclaimer — Business Purpose Loans Only

ONCF provides financing strictly for business or investment purposes. We do not make consumer-purpose loans for personal, family, or household use. All borrowers must confirm that loan proceeds are intended solely for commercial, investment, or business purposes.

Our Services

ONCF provides private lending and related services for business-purpose loans, including commercial real estate loans, construction financing, and other credit products designed for investment or business use.

We reserve the right, in our sole discretion, to change how we operate and provide our services, including adding new services, modifying existing services, or suspending, discontinuing, or terminating access to any or all portions of our services.

Information We Collect From You

We collect and process the following types of information:

Technologies We Use for Automatic Data Collection

Most browsers allow you to control cookie settings; some Site features may not function properly if cookies are disabled.

Uses of Information

We use the collected information to:

Third-Party Tracking and Online Advertising

ONCF may use interest-based advertising and third-party providers to deliver targeted ads and measure effectiveness. We may share browsing behavior with these partners via cookies and tracking technologies. Social media integrations (e.g., LinkedIn or Facebook widgets) may collect information subject to their own policies.

Your Choices

Disclosure of Your Information

We may disclose your information to:

Data Security

We take appropriate safeguards to protect your information. While no online transmission is completely secure, once we receive your data we apply security measures to protect it and dispose of records securely when no longer required.

Control Over Your Information

You may opt out of marketing communications; however, essential notices (e.g., compliance, transaction, or security-related messages) cannot be opted out of.

Your California Privacy Rights

California users may request details on data sharing by emailing compliance@oncfund.com.

Links to Third-Party Websites and Services

Our Site may link to third-party sites not governed by this policy. We are not responsible for their privacy practices.

Transfer of Information

ONCF is based in the U.S., and your information may be processed and stored in the U.S. or other jurisdictions. No mobile information will be sold or shared with third parties for promotional or marketing purposes.

Changes to Privacy Policy

We may update this policy from time to time. Changes will be posted on this page and, where appropriate, notified via email or other communication methods.

Contact

Questions or requests should be sent to our compliance department at
compliance@oncfund.com.