TBM CAPITAL COMMUNICATIONS

We catch what others miss.

We challenge what others accept.

We strengthen what investors will test.

Effective Date: October 18, 2026

TBM Marketing LLC, doing business as TBM Capital Communications ("TBM Capital Communications," "TBM," "we," "us," or "our"), respects the privacy of individuals and businesses who visit our website, use our digital products, communicate with us, or engage our professional services.

This Privacy Policy explains how we collect, use, process, retain, protect, and disclose personal information in connection with our website at https://www.tbmcapitalcommunications.com, associated webpages, sales funnels, forms, memberships, digital products, and professional services (collectively, the "Services").

It also explains how our RAISE READY self-assessment software handles information differently from our membership and professional service offerings.

By using our Services, you acknowledge that you have been provided with this Privacy Policy. Where applicable law requires consent for particular processing activities, we will request that consent separately.

1. Information We Collect

We collect information necessary to operate our business, provide our Services, communicate with customers, and fulfill applicable legal and administrative obligations.

1.1 Information You Provide

Depending on your interactions with us, this may include:

Name and contact information, including email address and telephone number.
Company or organization name and professional title.
Business or project descriptions.
Funding objectives, capital requirements, development stage, and timelines.
Information submitted through contact, inquiry, qualification, registration, or scheduling forms.
Information provided when subscribing to newsletters, accessing resources, or registering for memberships.
Billing details, purchase records, and transaction information.
Communications exchanged with us by email, contact forms, social media, or other communication channels.
Documents and materials voluntarily submitted in connection with an agreed professional engagement.

Professional documents may include financial models, investor presentations, business plans, budgets, forecasts, capitalization information, and supporting business records.

We ask that you provide only the information reasonably necessary for the relevant interaction or service.

Please do not submit passwords, banking credentials, Social Security numbers, or other highly sensitive personal information unless expressly requested through an appropriate secure process for an agreed and legitimate purpose.

1.2 Information Collected Automatically

When you access our website or use our online Services, our website platform, hosting providers, and integrated services may automatically process technical and usage information, including:

Internet Protocol (IP) address.
Browser and device information.
Operating system.
Approximate location derived from an IP address.
Referring websites or traffic sources.
Pages visited and links selected.
Dates and times of visits.
Website performance and diagnostic information.
General interaction and usage information.

This information may be processed through server logs, cookies, analytics technologies, and other website functionality.

The information collected depends on the platform, features, and services being used.

1.3 Information From Third-Party Services

We may receive information from service providers that support our business activities, including membership administration, email communications, payments, scheduling, digital-product delivery, and customer management.

Examples include contact information, registration status, purchase confirmation, subscription activity, appointment information, and transaction identifiers.

The information we receive depends on the service provider and the nature of your interaction with our business.

2. How We Use Personal Information

We may use personal information for the following purposes:

Responding to inquiries and communications.
Evaluating whether our professional services are appropriate for a prospective client.
Providing purchased services and digital products.
Creating and administering membership accounts.
Delivering requested resources and educational content.
Processing purchases, invoices, and payment confirmations.
Scheduling and managing appointments.
Preparing and delivering agreed professional work.
Maintaining appropriate business and financial records.
Sending service-related communications.
Sending promotional communications where permitted by applicable law.
Improving website functionality and user experience.
Understanding website performance and general audience activity.
Preventing fraud, unauthorized access, and misuse.
Protecting our business, customers, systems, and intellectual property.
Complying with legal, regulatory, tax, and accounting obligations.
Establishing, exercising, or defending legal claims.

We may also process information for another purpose disclosed at the time of collection or otherwise permitted by applicable law.

Where relevant privacy legislation applies, processing may rely on consent, contractual necessity, compliance with legal obligations, legitimate interests, or another applicable legal basis.

3. Memberships and Digital Products

Certain TBM Capital Communications products and educational resources are provided through private memberships or external delivery platforms.

These may include RAISE READY, Early Founder, and other educational or business resources.

Registration, enrollment, purchases, access credentials, and related membership administration may be processed through Systeme.io or other providers supporting these services.

Membership information may include your name, email address, enrollment status, purchase information, and relevant account activity.

This information is separate from the assessment responses users enter into RAISE READY, as explained below.

Access to a private membership does not, by itself, mean that TBM Capital Communications receives or reviews information entered into an embedded self-assessment.

Third-party membership platforms process information according to their own privacy policies and their applicable contractual arrangements with TBM.

Systeme.io's Privacy Policy is available at:

https://systeme.io/privacy-policy

4. RAISE READY: Self-Assessment and Data Privacy

4.1 Purpose of the Software

RAISE READY is a self-guided investor-readiness assessment designed to help early-stage founders evaluate their preparation for raising investment capital.

Users respond to structured questions about their businesses, financial readiness, investment materials, and capital planning.

The software evaluates those responses and generates an individualized assessment report.

RAISE READY is intended to help users evaluate their own preparation. Completing the assessment does not constitute a professional consultation, individual business evaluation, investment recommendation, or review of submitted materials by TBM Capital Communications.

4.2 Browser-Based Processing

RAISE READY is designed to process assessment information directly within the user's browser.

Assessment responses, scoring results, and generated reports are processed locally rather than being submitted to TBM Capital Communications for individual review.

Under the software's documented architecture, TBM Capital Communications does not receive, collect, or store individual assessment answers or report contents through the assessment software.

Assessment responses are not submitted to an external artificial intelligence service for analysis.

Users are not required to upload financial models, investor presentations, business plans, confidential contracts, or proprietary business documents to complete the assessment.

4.3 Local Storage and Saved Progress

RAISE READY uses browser-based local storage to preserve assessment progress.

This enables users to return to an unfinished assessment without having to begin again.

Locally saved information may include assessment responses, relevant profile information, progress status, and information used to generate assessment results.

Closing the browser or navigating away from the assessment does not necessarily erase this information.

Saved information may remain available in the same browser until the user resets the assessment, clears the relevant website data, or takes another action that removes the locally stored information.

Using another device or browser may not provide access to the previously saved assessment.

4.4 Access to Locally Stored Information

Local browser storage is not equivalent to a secure, encrypted document vault.

Although assessment information is not intended to be transmitted to TBM Capital Communications, locally stored information may be accessible to individuals with access to the same device or browser profile, browser extensions with sufficient permissions, or malicious software.

Users accessing RAISE READY on shared or public devices should remove their saved assessment after completing their session.

No browser-based storage mechanism can guarantee absolute protection against unauthorized access.

4.5 Personalization Information

RAISE READY may request limited contextual information, such as a founder's name, company name, company stage, or intended capital raise amount, to personalize the assessment experience and generated report.

Such information is distinct from personal information collected when registering for a membership or purchasing access through Systeme.io.

Users should avoid entering confidential information that is not necessary to complete the assessment.

4.6 Assessment Data and Membership Data

RAISE READY assessment data and Systeme.io membership information serve different purposes.

Membership information may be processed to create accounts, administer access, deliver purchases, provide customer support, and manage communications.

Assessment responses are designed to remain within the user's browser and are not intended to become part of TBM's membership, marketing, or customer records.

The software's browser-based privacy practices do not eliminate the technical data ordinarily processed when accessing a website, including information potentially recorded by hosting infrastructure.

4.7 Confidentiality and Responsible Use

Users are not required to disclose trade secrets, proprietary formulas, confidential customer records, investor identities, passwords, or commercially sensitive documents to complete RAISE READY.

The assessment is designed to evaluate the user's preparation through structured answers rather than the submission of underlying confidential materials.

An individual confidentiality or nondisclosure agreement is not ordinarily required simply to use this self-guided assessment.

A separate confidentiality arrangement may be appropriate where a user enters into a professional engagement and voluntarily provides TBM Capital Communications with confidential documents for review.

4.8 Technical Changes

We may update RAISE READY's functionality, storage mechanisms, or technical infrastructure over time.

If changes materially affect how assessment information is collected, transmitted, stored, or accessed, we will update the relevant privacy disclosures as required.

5. Professional Services and Client Materials

TBM Capital Communications provides capital communications, financial structuring, investor-facing materials, and related professional services.

Clients may voluntarily provide confidential business documents as part of an agreed engagement.

These may include financial projections, business strategies, capitalization information, budgets, investor presentations, project plans, and commercially sensitive records.

We use such materials for purposes reasonably connected to the agreed services, communication with the client, business administration, legal compliance, or another authorized purpose.

Client materials are not treated as information submitted through RAISE READY's self-guided assessment.

Where appropriate, additional confidentiality provisions may be established through a service agreement, proposal, or separate nondisclosure agreement.

The handling of confidential business information may be subject to contractual obligations in addition to the personal-data protections described in this Privacy Policy.

6. Email Communications and Marketing

We may send communications related to:

Membership access and enrollment.
Purchases and payment confirmations.
Requested resources.
Scheduled appointments.
Active professional engagements.
Product updates and administrative notices.
Customer support.
Newsletters, educational resources, and promotional offers.

Marketing communications are sent in accordance with applicable legal requirements.

You may unsubscribe from promotional emails by selecting the unsubscribe link provided in the message or by contacting us.

Unsubscribing from marketing communications does not prevent necessary transactional, administrative, security-related, or service communications.

Where marketing is managed through a third-party service, that provider may process subscription details, delivery information, and email interaction data.

7. Cookies, Analytics, and Similar Technologies

Our website and integrated services may use cookies and comparable technologies to support functionality, remember preferences, measure traffic, and evaluate website performance.

These technologies may be associated with:

Website hosting.
Membership login functionality.
Embedded content.
Scheduling tools.
Payment processing.
Website analytics.
Marketing attribution.
General site performance.

Some technologies may be provided by third parties.

You can manage certain browser cookies through your browser settings. Disabling essential cookies may affect access to portions of our Services.

Where applicable law requires consent before nonessential cookies or tracking technologies are used, we will provide the required controls or obtain the appropriate consent.

RAISE READY's local storage for assessment progress is described separately in Section 4.

8. Payment Processing

Purchases may be processed through third-party payment platforms, including Stripe, PayPal, or other payment providers used by TBM Capital Communications.

Payment providers may collect billing details, payment credentials, transaction information, and other information needed to process a purchase.

TBM Capital Communications generally receives transaction confirmations, purchase records, customer details, and other information necessary for accounting and service delivery.

We generally do not receive or store complete payment-card credentials.

Payment providers handle payment information in accordance with their own applicable privacy policies and security procedures.

9. How We Disclose Information

We do not sell or rent personal information.

We may disclose personal information where reasonably necessary for the following purposes.

9.1 Service Providers

We work with providers that support our website, communications, operations, digital products, and professional services.

These may include:

Website and membership platforms.
Payment processors.
Email delivery and marketing platforms.
Scheduling services.
Cloud storage and productivity systems.
Customer-management tools.
Website analytics providers.
Accounting and administrative services.

Providers may include Systeme.io, Stripe, PayPal, Google Workspace, Notion, TidyCal, and other services used in connection with our operations.

We disclose information according to the requirements of the service being provided, applicable agreements, and legal obligations.

9.2 Professional Advisers

Information may be disclosed to attorneys, accountants, tax advisers, insurers, consultants, or other professionals where reasonably necessary for legitimate business and compliance purposes.

9.3 Legal Requirements

We may disclose information where required or permitted by law, including in response to valid legal processes, regulatory obligations, or lawful requests from public authorities.

We may also disclose information where reasonably necessary to investigate suspected misconduct, protect rights and property, address security incidents, or pursue legal remedies.

9.4 Business Transactions

If TBM Marketing LLC participates in a merger, acquisition, reorganization, sale of assets, or similar business transaction, relevant information may be transferred or disclosed as permitted by law.

9.5 Your Authorization

We may disclose information when you specifically authorize or direct us to do so.

10. Data Retention

We retain personal information only for as long as reasonably necessary for the purposes for which it was collected, subject to applicable legal and operational requirements.

Retention considerations include:

The nature of the information.
The duration of the customer or client relationship.
Contractual obligations.
Tax and accounting recordkeeping.
Legal and regulatory requirements.
Fraud prevention.
Dispute resolution.
Legitimate operational needs.

When information is no longer required, we may delete, anonymize, or securely dispose of it as appropriate.

RAISE READY's locally saved assessment information is subject to the browser-storage behavior described in Section 4.

Because individual assessment answers are not intended to be collected by TBM, we generally cannot retrieve or delete those answers remotely from a user's browser.

Users may remove their locally saved assessment information using the software's available reset function or their browser's website-data controls.

11. Data Security

We use reasonable administrative, technical, and organizational measures designed to protect information under our control against unauthorized access, alteration, loss, misuse, or disclosure.

These measures may include access restrictions, account security controls, reputable service providers, software maintenance, and appropriate handling of confidential client materials.

Our security measures are intended to reflect the nature of the information processed and the practical requirements of our business.

No internet-based service, electronic transmission, browser-storage mechanism, or digital system can be guaranteed to be entirely secure.

We cannot guarantee absolute security, but we seek to apply reasonable precautions and respond appropriately to identified risks.

12. Your Privacy Rights and Choices

Depending on your location and the laws applicable to your information, you may have certain privacy rights.

These may include the right to:

Request access to personal information we hold about you.
Request correction of inaccurate information.
Request deletion of certain personal information.
Request a copy of certain personal information.
Object to or restrict certain processing activities.
Withdraw consent where consent is the applicable legal basis.
Opt out of certain marketing communications.
Exercise other rights available under applicable privacy law.
Submit a complaint to an applicable data-protection authority.

These rights may be subject to exceptions and limitations under applicable law.

We may need to verify your identity before responding to a request.

To submit a privacy-related request, please contact:

hello@tbmcapitalcommunications.com

We will respond in accordance with applicable legal requirements and will not unlawfully discriminate against individuals for exercising their privacy rights.

13. International Users and Data Transfers

TBM Marketing LLC is based in White Plains, New York, United States.

Our website, digital products, and professional services may be accessed by individuals and businesses in other countries.

Personal information processed through our website, membership platform, payment providers, or other service providers may be stored or processed in the United States or other jurisdictions where those providers operate.

Privacy and data-protection laws may differ between jurisdictions.

Where required, we will rely on an appropriate legal basis and applicable safeguards for international transfers of personal information.

Users accessing our Services from outside the United States should understand that some of their membership, transaction, communication, or website information may be processed internationally.

The local processing of RAISE READY assessment responses is described separately in Section 4.

14. Third-Party Websites and Embedded Services

Our website may contain links to external websites or incorporate embedded tools, videos, forms, payment systems, scheduling applications, and other third-party services.

We do not control the independent privacy or security practices of those third parties.

Their processing of personal information may be governed by their respective privacy policies, terms, and legal obligations.

We encourage users to review the relevant third-party policies before submitting personal information.

15. Children's Privacy

Our website, digital products, and professional services are intended for business and professional audiences.

They are not directed to children under 13 years of age.

We do not knowingly collect personal information directly from children under 13.

If you believe that a child has provided personal information to us, please contact us so that we can review the circumstances and take appropriate action.

16. Browser Privacy Preferences

Certain browsers provide privacy preferences, including cookie controls and Do Not Track settings.

Because browser settings and applicable tracking requirements vary, our website may not respond to every Do Not Track signal in the same way.

Where applicable law requires recognition of specific privacy preference signals or opt-out mechanisms, we will seek to comply with those requirements.

Users may also manage cookies and other locally stored website information through their browser settings.

17. Changes to This Privacy Policy

We may revise this Privacy Policy periodically to reflect changes in our Services, digital products, technical infrastructure, business operations, service providers, or applicable legal obligations.

When changes are made, we will update the Effective Date shown at the beginning of this document.

Where required, we may provide additional notice or request renewed consent for material changes affecting personal information.

We encourage users to review this policy periodically.

18. Contact Information

For questions, concerns, or requests relating to this Privacy Policy or our handling of personal information, please contact:

TBM Capital Communications
Operated by TBM Marketing LLC
White Plains, New York, United States

Website: https://www.tbmcapitalcommunications.com

Email: hello@tbmcapitalcommunications.com

TBM Capital Communications is operated by TBM Marketing LLC.

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