Puebla Investments LLC Privacy Policy

Effective Date: July 6, 2026

Puebla Investments LLC (“Puebla Investments,” “we,” “us,” or “our”) is committed to protecting the privacy of visitors to our website, https://pueblainvestments.com, and of individuals who interact with us in connection with our investment and advisory activities. This Privacy Policy describes the categories of personal information we collect, how we use and disclose that information, and the privacy rights available to California residents and residents of other U.S. states under applicable law, including the California Consumer Privacy Act as amended by the California Privacy Rights Act (CCPA/CPRA).

Disclaimer

No securities are being offered by these summary materials. This document has been designed for informational purposes only and under no circumstances should any information contained herein be used or considered to be an offer to sell or solicitation of any offer to buy any securities or any other instruments. Investors may lose some or all of their investment in connection with some of such securities. This communication is not intended to provide accounting, legal, or tax advice or investment recommendations. Investors should contact their own accounting, legal, or tax advisors for additional information. Information contained herein is subject to change and the provider undertakes no duty to update the information or to supply corrections. This communication does not constitute any offer or solicitation to residents of any jurisdiction in which such an offer or solicitation is not authorized or to any person to whom it is unlawful to make such an offer or solicitation. This material is for your private information and may not be copied or disseminated, and by accepting this material the recipient agrees that it will not distribute to any other person

Notice at Collection: Personal Information We Collect

We collect the following categories of personal information, directly from you, automatically through your use of our website, and from investors and their representatives in connection with prospective or existing investments:

  • Identifiers – name, email address, phone number, mailing address, and IP address. Collected when you contact us, request information, or register for the Investor Portal, and automatically when you visit our website. Used to respond to inquiries and operate our website and Investor Portal.
  • Commercial and Financial Information – investment interests, accreditation and suitability information, and tax identification information. Collected directly from prospective and current investors. Used for investor onboarding, diligence, and regulatory compliance.
  • Internet and Network Activity – browser type, device type, pages visited, and referring URLs, collected automatically through cookies and similar technologies. Used to operate, secure, and improve our website.
  • Professional Information – firm affiliation and title, collected directly from you. Used for relationship management.
  • Sensitive Personal Information – government-issued identification or tax identification numbers and financial account information, collected directly in connection with investor onboarding, identity verification, and anti-money-laundering requirements. We use sensitive personal information only for these purposes and do not use it to infer characteristics about you.

We do not knowingly collect personal information from children under the age of 16.

How We Use Your Information

  • To respond to inquiries and provide information about our firm and investment activities
  • To administer access to the Investor Portal and manage investor relationships
  • To conduct investor identification, suitability, and due diligence, and to meet anti-money-laundering and other regulatory obligations
  • To maintain, secure, and improve our website
  • To comply with applicable law, regulation, and legal process

How We Protect and Retain Your Information

We maintain administrative, technical, and physical safeguards, including encryption and secure transmission protocols, designed to protect personal information from unauthorized access, use, or disclosure. Access to personal information is limited to personnel and service providers who need it to perform their functions and who are bound by confidentiality obligations.

We retain personal information only as long as reasonably necessary to fulfill the purposes described in this Policy, or as required to meet our legal, tax, accounting, and regulatory recordkeeping obligations, which for certain investor records may extend for a period of years following the end of the relationship.

Sharing and Disclosure of Your Information

We do not sell personal information, and we do not share personal information for cross-context behavioral advertising, as those terms are defined under the California Consumer Privacy Act (CCPA).

We may disclose personal information to:

  • Service providers who support our operations, such as fund administrators, custodians, auditors, and technology providers, under confidentiality obligations
  • Regulators or other parties as required by law, subpoena, or other legal process
  • A successor entity in connection with a merger, reorganization, or sale of assets

Your Privacy Rights (California and Other U.S. States)

If you are a California resident, the California Consumer Privacy Act, as amended by the California Privacy Rights Act (CCPA/CPRA), gives you the following rights with respect to your personal information. We extend these same rights to residents of all U.S. states as a matter of policy, consistent with similar comprehensive privacy laws in states such as Virginia, Colorado, Connecticut, Utah, Texas, Oregon, and Montana, among others:

  • Right to Know/Access – the categories and specific pieces of personal information we have collected about you
  • Right to Delete – deletion of personal information we have collected from you, subject to certain exceptions
  • Right to Correct – correction of inaccurate personal information
  • Right to Opt-Out of Sale or Sharing – as noted above, we do not sell or share personal information
  • Right to Limit Use of Sensitive Personal Information – we use sensitive personal information only as necessary to provide our services and do not use it for purposes beyond those permitted by law
  • Right to Non-Discrimination – we will not discriminate against you for exercising any of these rights
  • Right to Appeal – if we decline to act on your request, you may appeal by contacting us as described below

To exercise these rights, contact us by phone at +1.347.324.8497 or by email at paul@pueblainvestments.com. We will verify your identity before responding and will respond within the time periods required by applicable law. You may also designate an authorized agent to submit a request on your behalf.

Cookies and Tracking Technologies

Our website uses cookies and similar tracking technologies to enhance your browsing experience, analyze website traffic, and personalize content. You can control cookie settings through your browser preferences.

Other Important Information

Changes to This Policy: We may update this Privacy Policy from time to time. Updates will be posted on this page with a revised effective date.

Children’s Privacy: Our website and services are not directed to children, and we do not knowingly collect personal information from anyone under the age of 16. If we learn we have done so, we will delete that information.

Accessibility: If you use assistive technology and experience difficulty accessing this Policy, please contact us using the information below and we will provide the information in an alternative format.

Contact Us

Questions about this Privacy Policy, our data practices, or requests to exercise your privacy rights may be directed to:

Puebla Investments LLC
547 Alhambra Circle, Coral Gables, FL 33134
Phone: +1.347.324.8497
Email: paul@pueblainvestments.com