Last Updated: April 21, 2022

This privacy policy (“Policy”) describes how Overseas Capital Management (“Company”) collects, uses and shares personal information of consumer users of this website, www.ocmcap.com (the “Site”). We respect your privacy and are committed to protecting it through our compliance with this policy.

We collect information about users of our website in a range of ways:
• Information You Give Us. We collect information by which you may be personally identified, such as your name, email address as well as other information you directly give us by filling in forms on our Site, or by emailing us.
• Information Automatically Collected. We automatically log information about you and your computer. For example, when visiting our Site, we log information about your use of and actions on our Site.

• We do not collect any sensitive data such as: race or ethnic origin, political opinions, religious or philosophical beliefs, trade union memberships, genetic of biometric data, health or mortality, sex life or sexual orientation, unless required by law.

We use your personal information as follows:
We use your personal information to communicate via telephone, electronic mail or online.

We do NOT share any information received by our website. All your information is kept confidential and will NOT be passed to any other third party. We only keep information for as long as it is necessary.

We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal requirements). When we have no ongoing business need to process your information, we will delete it, or if this is not possible (for example, because your personal information has been archived), then we will securely store your personal information until deletion is possible.

We endeavor to take all reasonable steps to protect your personal information, but cannot guarantee the security of any data you disclose online. Please note that email is not a secure medium and should not be used to send confidential or sensitive information. You accept the inherent security risks of providing information over the Internet and will not hold us responsible for any breach of security, unless this is due to our negligence or willful default.

We may disclose your personal information to comply with any court order, law, or legal process, including to respond to any government or regulatory request. We may also disclose your information if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of our firm, our clients, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

We strive to provide you with choices regarding the personal information you provide us. We have created mechanisms to provide you with the following control over your information:
• Tracking technologies. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
• Promotional offers from us. If you do not wish to have your contact information used by us to promote our own or third parties’ products or services, you can opt-out by sending us an email asking to be omitted from future email distributions.

We do not currently sell our site visitors’ data, and thus, the Nevada Revised Statutes Chapter 603A’s opt-out requirements are not triggered.

Overseas Capital Management LLC is not subject to the California Consumer Privacy Act (the “CCPA”) as it does not meet the threshold requirements.

If you are a data subject for purposes of the GDPR, you have a number of important rights, including rights to:
• Fair processing of information and transparency over how we use your personal information;
• Access to your personal information and to certain other supplementary information that this Policy is already designed to address;
• Require the correction of any mistake in the personal information that we hold about you;
• Require the erasure of personal information concerning you in certain situations;
• Receive the personal information concerning you that you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit that data to a third party in certain situations;
• Object at any time to the processing of your personal information for direct marketing;
• Object to decisions being taken by automated means that produce legal effects concerning you or similarly significantly affect you;
• Object in certain other situations to our continued processing of your personal information; and
• Otherwise restrict our processing of your personal information in certain circumstances.

For further information on each of these rights, including the circumstances in which they apply, guidance is available from applicable data protection authorities.

CHANGES TO THIS PRIVACY POLICY. We may change this privacy policy. If we make any changes, we will change the Last Updated date above. If we make material changes to how we treat our users’ personal information, we will notify you through a notice on the Site home page. We encourage you to periodically visit our Site and this privacy policy to check for any changes.