Privacy Policy

1. Introduction

Northbarn Capital Management LLC ("Northbarn Capital," "we," "our," or "us") operates the website northbarncap.com (the "Service"). This Privacy Policy explains what information we collect, how we use it, and the choices you have. It applies to information we collect through the Service and through direct communications with you.

We are based at 100 Federal Street, Suite 2800, Boston, MA 02110 and can be reached at [email protected].

Northbarn Capital is an exempt reporting adviser registered with the Securities and Exchange Commission. This Privacy Policy applies solely to the Service and does not govern the collection or use of information from fund investors, portfolio companies, or other business relationships, which are governed by separate agreements.

2. Information We Collect

2.1 Information You Provide

We collect information you submit directly, including:

• Contact details (name, email, phone) when you fill out a form, request a meeting, or contact us directly;
• Company information you choose to share (employer, role, project context);
• The content of any messages you send us.

2.2 Information Collected Automatically

When you visit northbarncap.com, we automatically collect limited technical information:

• IP address and approximate location (city/region level);
• Browser type, operating system, device class;
• Pages visited, referring URLs, time on page;
• Cookie and similar identifiers (see Section 5).

2.3 We Do Not Knowingly Collect Children's Data

northbarncap.com is not directed to children under 13. We do not knowingly collect personal information from children. If you believe a child has provided us information, contact [email protected] and we will delete it.

3. How We Use Information

We use the information we collect to:

• Respond to inquiries and provide requested information;
• Operate, maintain, and improve the Service;
• Send service updates and (with your consent where required) communications;
• Detect, investigate, and prevent fraud or abuse;
• Comply with legal obligations.

We do not sell personal information for monetary value. Where applicable state law treats certain advertising arrangements as a "sale" or "share," see your state's section below.

4. Sharing of Information

We share personal information only with:

• Service providers acting on our behalf (e.g., hosting, email delivery, analytics) under contractual confidentiality terms;
• Authorities, when required by law or to protect rights, safety, or property;
• A successor entity in the event of a merger, acquisition, or asset sale, subject to this Policy.

We do not sell personal information to third parties.

5. Cookies and Tracking

We use cookies and similar technologies to operate the site, remember preferences, and measure usage. For details and choices, see our Cookie Policy.

6. Data Retention

We retain personal information only as long as needed for the purposes described, to comply with legal or accounting obligations, and to resolve disputes. Inactive contact records are purged after 24 months. Server access logs are retained 90 days, then aggregated.

7. Security

We use administrative, technical, and physical safeguards designed to protect personal information, including TLS encryption in transit, restricted-access databases, and least-privilege access controls. No system is perfectly secure; we cannot guarantee absolute security.

8. Your General Rights

Depending on your jurisdiction, you may have rights including access, correction, deletion, and the ability to limit certain processing. To make a request, email [email protected]. We will respond within the timeframe required by applicable law.

9. Massachusetts Residents

Massachusetts does not currently have a comprehensive consumer privacy statute. As a matter of policy, we extend the following baseline rights to all U.S. residents regardless of state of residence.

9.1 Baseline Rights

• Right to Know: request the categories of personal information we have collected about you.
• Right to Delete: request deletion of personal information you have provided.
• Right to Correct: request correction of inaccurate personal information.
• Right to Opt Out of Marketing: unsubscribe from marketing emails or opt out via the link in each marketing message.

9.2 How to Exercise

Email [email protected] with a description of your request and enough detail for us to verify your identity. We respond within 45 days.

9.3 Sector-Specific Rights

If you are protected by federal sector laws (e.g., HIPAA, GLBA, FERPA), those laws may give you additional rights with respect to data covered by them.

9.X California Visitors

If you are a California resident visiting from another state, you may also exercise the rights granted under the California Consumer Privacy Act ("CCPA") and California Privacy Rights Act ("CPRA"), including the right to know, the right to delete, the right to correct, and the right to opt out of sale or sharing. We do not sell personal information and do not "share" personal information for cross-context behavioral advertising.

To submit a CCPA / CPRA request, email [email protected] with the subject line "California Privacy Request."

10. Changes to This Policy

We may update this Policy from time to time. Material changes will be reflected by a new "Last updated" date and, where appropriate, a notice on the Service.

11. Contact

Questions, requests, or complaints can be sent to: