Last updated: July 23, 2026
Version: 1.1 (Partner FI absorb)

1. Introduction

Network Capital LLC (“Network Capital,” “we,” “us,” or “our”) is an investment adviser registered with the U.S. Securities and Exchange Commission. This Privacy Policy describes how we collect, use, share, and protect personal information in connection with our investment advisory, investment account, cash management, and related platform services for U.S. customers.

This Privacy Policy is the privacy notice for Network Capital’s U.S. customer relationships. Non-U.S. customers of The Network Bank Ltd. Co. and The Network Labs Ltd. Co. use the Network Bank Group Privacy Policy instead.

When you accept the Agent of Payee Services Agreement, Network Pay LLC and Network Clearing LLC may process payment-related data as your agents and as affiliates under Section 4 of this Policy and under that Agreement. No separate Network Pay or Network Clearing privacy policy acceptance is required for onboarding.

Partner Financial Institutions. Banks, program banks, sponsor banks, custodians, broker-dealers, payment processors, and other licensed financial institution service providers (“Partner Financial Institutions”) that support standard platform rails receive and use information as described in this Policy and in Parts F and G of the Network Capital Terms, Conditions, and Disclosures. For those standard rails, you are not required to accept a separate Partner Financial Institution privacy pack at onboarding. Specialty products that legally require issuer-specific notices may still present a limited product notice for that product only.

2. Information We Collect

We may collect:

• Identity and contact information: name, date of birth, address, email, phone, nationality, citizenship, government ID data.
• Tax and regulatory information: SSN/ITIN or EIN, tax forms (e.g., W-9), FATCA/CRS certifications as applicable.
• Financial and suitability information: income, net worth, investment objectives, risk tolerance, employment, source of funds/wealth.
• Account and transaction information: holdings, orders, transfers, cash management activity, payment instructions, statements, and related records.
• Funding and banking information: linked bank account numbers, routing numbers, account balances (where you connect an account), and similar funding details needed for ACH, wire, or settlement.
• Technical information: device, IP address, browser, app usage, cookies or similar technologies on Network Capital sites or apps.
• Communications: support requests, recordings where permitted, and correspondence.

We may collect information directly from you, from affiliates and service providers assisting onboarding or account servicing, from identity-verification and sanctions vendors, from Partner Financial Institutions, and from publicly available or commercially available sources as permitted by law.

3. How We Use Information

We use personal information to:

• Provide advisory, investment account, cash management, and platform services;
• Verify identity, prevent fraud, and comply with AML/CFT, sanctions, books-and-records, and other legal obligations;
• Open and maintain accounts with custodians, broker-dealers, program banks, and other Partner Financial Institutions;
• Process transactions, settlements, ACH, wires, and reporting;
• Communicate with you about your account and services;
• Improve our products, security, and customer experience;
• Enforce agreements and protect rights and safety.

4. How We Share Information

We may share personal information with:

• Affiliates, including Network Pay LLC and Network Clearing LLC, when needed to provide or support services you use or accept (including Agent of Payee / merchant services);
• Partner Financial Institutions, including program banks, sponsor banks, custodians, broker-dealers, payment processors, card issuers, settlement banks, and other licensed financial institution service providers, as necessary to provide platform services, process Transactions, hold or settle funds, comply with law, and meet Payment Network Rules;
• Other service providers and vendors, including KYC/KYB vendors, cloud providers, fraud tools, and customer support providers;
• Regulators and law enforcement, when required or permitted by law;
• Professional advisers, such as auditors, counsel, and consultants under confidentiality obligations;
• Successors, in connection with a merger, acquisition, or similar corporate transaction.

Partner reliance. Information you provide to Network Capital (including through the platform) may be shared with Partner Financial Institutions and may be relied on by them to provide Bank Services, verify identity, comply with applicable law, or respond to valid legal process, as described in Part G of the Network Capital Terms, Conditions, and Disclosures.

We do not sell your personal information for money. We may disclose information for targeted advertising or analytics only as described at the time of collection or in a supplemental notice, where applicable.

5. Regulation S-P and Other U.S. Privacy Rules

As an SEC-registered investment adviser, Network Capital maintains policies and procedures designed to protect nonpublic personal information under Regulation S-P and other applicable U.S. privacy and data-security requirements. We limit access to personnel and providers who need the information to perform their duties.

6. Financial Privacy Notice (Gramm-Leach-Bliley Act)

Where Network Capital or its affiliates provide financial products or services that implicate the Gramm-Leach-Bliley Act (“GLBA”) and its implementing regulations, this section describes how we collect, use, and share nonpublic personal information (“NPI”).

Information We Collect

We collect NPI about you from:

• Information you provide in applications or account use (name, address, tax identification number, financial account information);
• Information about your transactions with us, our affiliates, or others (account balances, payment activity, transfer history); and
• Information we receive from third parties (identity verification services, fraud prevention organizations, Partner Financial Institutions).

Information We Disclose

We may disclose NPI to:

• Service providers that perform services on our behalf (payment processing, identity verification, AML/CTF monitoring, tax reporting, hosting, fraud prevention);
• Partner Financial Institutions (including banking partners) as necessary to provide products and process your transactions;
• Affiliates for everyday business purposes related to your transactions and experiences with us; and
• Government agencies and law enforcement as required or permitted by law.

We do not disclose your NPI to nonaffiliated third parties for them to market their products or services to you. We do not sell your NPI.

Sharing Practices Summary

Reasons we can share your NPI	Do we share?	Can you limit this sharing?
For our everyday business purposes — such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus	Yes	No
For our marketing purposes — to offer our products and services to you	Yes	No
For joint marketing with other financial companies	No	Not applicable
For our affiliates’ everyday business purposes — information about your transactions and experiences	Yes	No
For our affiliates’ everyday business purposes — information about your creditworthiness	No	Not applicable
For nonaffiliates to market to you	No	Not applicable

Because we do not share NPI in ways that would trigger an opt-out under the GLBA, no opt-out notice is required at this time. If our sharing practices change, we will update this notice and provide any required opt-out opportunity.

How We Protect NPI

We use administrative, technical, and physical safeguards designed to protect NPI, including access controls and encryption of data in transit and at rest where appropriate. If you close your account, we will continue to treat your NPI in accordance with this Privacy Policy.

7. Retention

We retain personal information for as long as needed to provide services and as required by SEC books-and-records rules, AML requirements, tax rules, and other legal obligations, and thereafter for a commercially reasonable period consistent with our retention schedule.

8. Security

We use administrative, technical, and physical safeguards designed to protect personal information. No method of transmission or storage is completely secure.

9. Your Choices and Rights

Depending on applicable law (including state privacy laws where they apply), you may have rights to access, correct, delete, or obtain a copy of certain personal information, or to opt out of certain processing. You may update account information through your dashboard or by contacting us. Marketing opt-out instructions, where applicable, appear in marketing messages.

Some requests may be limited by securities, AML, or recordkeeping obligations.

10. Cookies and Similar Technologies

Our websites and apps may use cookies and similar technologies for security, authentication, preferences, and analytics. See any cookies notice presented on the applicable site for additional detail.

11. Children’s Privacy

Our services are not directed to children under 18. We do not knowingly collect personal information from children under 18.

12. International Transfers

Network Capital serves U.S. customers. Information may be processed in the United States and in other jurisdictions where our affiliates, Partner Financial Institutions, or service providers operate, subject to appropriate safeguards and applicable law.

13. Changes

We may update this Privacy Policy from time to time. We will post the updated policy with a new “Last updated” date and, for material changes, provide additional notice as required by law. Continued use of the services after the effective date constitutes acceptance where permitted by law.

14. Contact

Privacy questions may be directed to support@networkcap.us, (415) 734-1666, the support channel in your account, or the contact information in Form ADV / Form CRS at https://adviserinfo.sec.gov/firm/summary/342019.