How we handle your information.

1. Who We Are

Novella Equity LLC ("Novella," "we," "us," or "our") is a private real estate investment firm operating within the Valoris Capital Partners platform. Our principal place of business is in Wichita, Kansas. This Privacy Policy describes how we collect, use, share, and protect personal information when you visit novella-equity.com, communicate with us, or invest with us.

2. Information We Collect

2.1 Information You Provide Directly

We collect information you submit through forms, calendar bookings, email, phone, text message, or document uploads, including:

• Identity information: First and last name, email address, phone number, mailing address, date of birth, and government-issued identification when required for accreditation verification or anti-money-laundering compliance.
• Financial information: Net worth, annual income, source of funds, investment vehicle (personal, IRA, trust, LLC), banking and wire transfer details, tax identification numbers, and documents supporting accredited investor status (CPA letters, attorney letters, tax returns, brokerage statements, W-2s).
• Communications: Email correspondence, recorded or transcribed call notes, text messages, and any documents you share with us.
• Investment activity: Subscription documents, capital contributions, distribution history, and tax-related filings (K-1s).

2.2 Information Collected Automatically

• Device and usage data: IP address, browser type, operating system, device identifiers, pages visited, time on site, and referring URLs.
• Cookies and similar technologies: We use first-party and third-party cookies to operate the site, remember preferences, and measure performance.

2.3 Information from Third Parties

We may receive information from accreditation verification services (CPAs, attorneys, broker-dealers, registered investment advisors), background-check providers, our affiliate Valoris Capital Partners, and our subscription portal vendor (Cashflow Portal).

3. How We Use Your Information

We use your personal information to:

• Verify your identity and accredited investor status as required by SEC Rule 506 and the Securities Act of 1933;
• Evaluate your suitability for offerings and pre-existing relationship requirements under Rule 506(b);
• Provide investment materials, schedule calls, send subscription documents, and process wire transfers;
• Distribute capital, prepare and deliver tax documents (K-1s), and produce quarterly reports;
• Communicate with you about your investment, future offerings, and firm updates;
• Comply with legal obligations including AML/KYC, tax reporting, and SEC filings;
• Detect and prevent fraud, unauthorized access, and abuse of our services;
• Improve our website, communications, and service quality.

4. SMS / Text Messaging Disclosure

5. How We Share Information

We do not sell or rent personal information. We share information only as follows:

• Service providers: Companies that perform services on our behalf (CRM and email infrastructure, calendar scheduling, e-signature, document storage, Cashflow Portal subscription processing, accounting, audit, legal, and tax professionals). These providers are contractually obligated to use information only as directed by us and to maintain appropriate security.
• Affiliates: Valoris Capital Partners and related entities for joint operational, compliance, and reporting purposes.
• Regulators and authorities: When required by law, subpoena, court order, or to comply with SEC, FinCEN, IRS, or state regulatory obligations.
• Business transfers: In connection with a merger, acquisition, financing, or sale of assets, subject to confidentiality obligations and notice where required.

We do not share, sell, or transfer mobile phone numbers or SMS opt-in data with any third party for marketing purposes, regardless of whether they are affiliates or unaffiliated parties.

6. Cookies & Tracking

Our website uses cookies and similar technologies for essential site functions, analytics, and conversion tracking. Most browsers allow you to refuse or delete cookies through browser settings. Disabling cookies may affect site functionality. We do not respond to "Do Not Track" browser signals at this time.

7. Data Security

We maintain administrative, technical, and physical safeguards designed to protect personal information from unauthorized access, disclosure, alteration, and destruction. This includes encrypted transmission (TLS), access controls, secure document storage, and routine security review. No system is completely secure; we cannot guarantee absolute security of information transmitted to or stored by us.

8. Data Retention

We retain personal information for as long as necessary to fulfill the purposes described in this Policy, comply with legal obligations (including SEC, FinCEN, and IRS recordkeeping requirements that often exceed seven years), resolve disputes, and enforce agreements. When information is no longer required, we delete or anonymize it in accordance with our retention schedule.

9. Your Rights

Depending on your jurisdiction, you may have rights to:

• Request access to the personal information we hold about you;
• Request correction of inaccurate information;
• Request deletion of personal information, subject to legal retention requirements;
• Object to or restrict certain processing;
• Opt out of marketing communications, including SMS, at any time;
• Receive a copy of your information in a portable format.

To exercise any of these rights, contact us using the details in Section 13. We may need to verify your identity before responding. We will respond within timeframes required by applicable law.

9.1 California Residents

If you are a California resident, the California Consumer Privacy Act (CCPA) provides additional rights, including the right to know what personal information is collected, the right to delete personal information, the right to correct inaccurate information, and the right to opt out of "sale" or "sharing" of personal information. We do not sell personal information. Submit CCPA requests to the contact below.

10. Children's Privacy

Our services are not directed to children under 18, and we do not knowingly collect personal information from children. If we learn that a child under 18 has provided us with personal information, we will delete it.

11. International Users

Novella Equity operates from the United States. If you access our services from outside the U.S., your information will be transferred to, stored, and processed in the United States, where data protection laws may differ from those of your country.

12. Changes to This Policy

We may update this Privacy Policy from time to time. The "Last Updated" date at the top reflects the most recent revision. We will notify you of material changes by email or by posting a prominent notice on our website. Your continued use of our services after the effective date of any change constitutes acceptance of the revised Policy.

13. Contact Us

Questions, concerns, or requests regarding this Privacy Policy or your personal information may be directed to:

This Privacy Policy is provided for transparency and is not investment advice. Investing in private real estate offerings involves risk, including possible loss of principal. See our Terms of Use for additional information.