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Last updated: December 02, 2025

This Privacy Policy describes GULFWAY CAPITAL, LLC (“Company”, “we”, “us” or “our”) policies and procedures on the collection, use and disclosure of your information when you use our service and tells you about your privacy rights and how the law protects you.

We use your personal data to provide and improve our service. By using the service, you agree to the collection and use of information in accordance with this Privacy Policy.

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

• Account means a unique account created for you to access our service or parts of our service.

• Affiliate means an entity that controls, is controlled by or is under common control with a party, where “control” means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.

• Company (referred to as either “the Company”, “we”, “us” or “our” in this Agreement) refers to GULFWAY CAPITAL, LLC, 336 Market Ave Unit D, Valparaiso, FL 32580.

• Cookies are small files that are placed on your computer, mobile device or any other device by a website, containing the details of your browsing history on that website among its many uses.

• Country refers to: Florida, United States

• Device means any device that can access the service such as a computer, a cellphone or a digital tablet.

• Personal Data is any information that relates to an identified or identifiable individual.

• Service refers to the Website and our capital management and investment services.

• Service Provider means any natural or legal person who processes the data on behalf of the Company.

• Usage Data refers to data collected automatically, either generated by the use of the service or from the service infrastructure itself.

• Website refers to Gulfway Capital, accessible from https://gulfwaycapital.com/

• You means the individual accessing or using the service, or the company, or other legal entity on behalf of which such individual is accessing or using the service, as applicable.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

While using our service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you. Personally identifiable information may include, but is not limited to:

• Email address

• First name and last name

• Phone number

• Investment criteria or accreditation status (if applicable)

• Usage Data

Usage Data

Usage Data is collected automatically when using the service. Usage Data may include information such as your device’s Internet Protocol address (IP address), browser type, browser version, the pages of our service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data. When you access the service by or through a mobile device, we may collect certain information automatically, including the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.

SMS/Text Message Communications

Consent for Text Messages: By providing your phone number to GULFWAY CAPITAL, LLC, you expressly consent to receive informational and marketing text messages from us at the number provided.

Data Collection and Usage We collect information such as your name and phone number to send you text messages related to:

• Account updates and alerts

• Appointment confirmations and reminders

• Investment opportunities and market news

• Requests for feedback or documentation

• Promotional offers and marketing messages about our services

Opt-Out Instructions You can opt out of receiving text messages from us at any time. To stop receiving messages, reply with any of the following keywords to any message you receive from us: STOP, CANCEL, or UNSUBSCRIBE. After you send the opt-out message, we will send you one final confirmation message to confirm that you have been unsubscribed. You will not receive any more messages from that number. If you wish to join again, just sign up as you did the first time, and we will start sending messages to you again.

Help and Support If you are experiencing issues with the messaging program you can reply with the keyword HELP for more assistance, or you can get help directly at our phone number (850) 262-7901 or email info@gulfwaycapital.com.

Tracking Technologies and Cookies

We use cookies and similar tracking technologies to track the activity on our service and store certain information. The technologies we use may include:

• Cookies or Browser Cookies: A cookie is a small file placed on your device. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent.

• Web Beacons: Certain sections of our service and our emails may contain small electronic files known as web beacons that permit us to count users who have visited those pages or opened an email.

We use both Session and Persistent Cookies for the purposes of providing and improving our service.

We may share hashed or masked customer data (such as email addresses) with third-party advertising partners, including Google, to match you with your accounts on their platforms for the purpose of measuring ad performance and improving our services. This data is hashed to protect your privacy and is not used by them for their own independent marketing purposes.

Use of Your Personal Data

We may use personal data for the following purposes:

• To provide and maintain our service, including to monitor the usage of our service

• To manage your account: to manage your registration as a user of the service

• For the performance of a contract: the development, compliance and undertaking of the purchase contract for services

• To contact you: by email, telephone calls, SMS, or other forms of electronic communication regarding updates or informative communications

• To provide you with news, special offers and general information about services similar to those you have purchased or enquired about

• To manage your requests: To attend and manage your requests to us

• For business transfers: We may use your information to evaluate or conduct a merger, divestiture, restructuring, or other sale

• For other purposes: such as data analysis, identifying usage trends, determining the effectiveness of promotional campaigns

Sharing Your Personal Information

Your Data is Not For Sale. We want to be clear: We do not sell your personal information. We only share data with service providers and advertising partners (as described above) to perform services for us, not for their own independent marketing use.

Note: Text messaging originator opt-in data and consent will not be shared with any third parties or advertising partners.

We may share your personal information in the following situations for the purpose of providing our services to you:

• With Service Providers: We may share your personal information with service providers to monitor and analyze the use of our service, for payment processing, and to contact you. This includes our CRM and secure financial communication platforms, which help us manage our business and communications.

• For business transfers: We may share or transfer your personal information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

• With affiliates: We may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy.

• With your consent: We may disclose your personal information for any other purpose with your consent.

Retention of Your Personal Data

We will retain your personal data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your personal data to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies. If you opt out of text messages, we will retain your phone number on a suppression list to ensure we do not send you future marketing messages.

Transfer of Your Personal Data

Your information, including personal data, is processed at the company’s operating offices and in any other places where the parties involved in the processing are located. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

Your Privacy Rights

Delete Your Personal Data You have the right to delete or request that we assist in deleting the personal data that we have collected about you. You may update, amend, or delete your information at any time by contacting us.

Disclosure of Your Personal Data

Business Transactions If the company is involved in a merger, acquisition or asset sale, your personal data may be transferred. We will provide notice before your personal data is transferred and becomes subject to a different Privacy Policy.

Law Enforcement Under certain circumstances, we may be required to disclose your personal data if required to do so by law or in response to valid requests by public authorities.

Other Legal Requirements We may disclose your personal data in the good faith belief that such action is necessary to:

• Comply with a legal obligation

• Protect and defend the rights or property of the company

• Prevent or investigate possible wrongdoing in connection with the service

• Protect the personal safety of users of the service or the public

• Protect against legal liability

Security of Your Personal Data

The security of your personal data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal data, we cannot guarantee its absolute security.

Children’s Privacy

Our service does not address anyone under the age of 18. We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your child has provided us with personal data, please contact us.

Links to Other Websites

Our service may contain links to other websites that are not operated by us. If you click on a third party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.

Changes to this Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and will let you know via email and/or a prominent notice on our service, prior to the change becoming effective. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, you can contact us:

Phone: (850) 262-7901
Email: info@gulfwaycapital.com
Website: https://gulfwaycapital.com/
Address: 336 Market Ave Unit D, Valparaiso, FL 32580.