VECTOR7 CAPITAL INC.
PRIVACY POLICY
ANNUAL NOTICE TO CLIENTS – REGULATION S-P COMPLIANT
FOR PUBLIC DISTRIBUTION
Adoption Date: [10/10/2026] | Effective Date: [10/10/2026]
Version: 1.0
WHAT THIS POLICY COVERS — AND WHAT IT MEANS FOR YOU
At Vector7 Capital Inc., your privacy is fundamental to how we operate. This policy explains what personal information we collect about you, how we use it, who we share it with, and what rights you have.
Here is the short version:
• We collect information you give us directly — and some information that platforms collect automatically — in order to manage your account and deliver our services.
• We do not sell your data. We do not share it with marketers or unaffiliated third parties.
• We share information only with the service providers and custodians we need to operate — and only for that purpose.
• You have the right to know what we hold, request corrections, and opt out of certain sharing.
• We are required by federal law (SEC Regulation S-P) to provide you this notice annually. This document satisfies that requirement.
If you have any questions, contact us at V7@vector7capital.com or (312) 500-6440.
WHO WE ARE
Vector7 Capital Inc. ("Vector7 Capital," "we," "our," or "us") is a registered investment adviser in the State of Illinois. We provide investment advisory and related financial services to individuals, families, institutional clients, and retirement plan clients pursuant to written Advisory Agreements and in accordance with our Form ADV disclosures.
Registration as an investment adviser does not imply a certain level of skill or training.
INFORMATION WE COLLECT
We collect personal information that is necessary to establish, maintain, and service your account, meet our legal and regulatory obligations, and deliver the services described in your Advisory Agreement. The categories of information we collect include:
Information You Provide Directly
• Identity information: full name, date of birth, Social Security Number or Tax Identification Number, government-issued identification
• Contact information: mailing address, email address, phone number
• Financial information: account numbers, net worth, income, investment objectives, risk tolerance, tax status, and beneficiary designations
• Employment and background information as required for account opening or suitability assessment
• Communications: emails, text messages, documents, notes, and records of conversations between you and Vector7 Capital
Information Collected Automatically Through Platforms
When you access our website or communicate with us through digital platforms, certain technical information may be collected automatically by the platforms we use, including:
• Internet Protocol (IP) addresses and approximate geographic location
• Browser type, operating system, and device identifiers
• Website session data and navigation information (collected by our website host and content delivery network for security and performance purposes)
• Metadata associated with electronic communications processed through our business technology platforms
This technical data is operational in nature and is not used for marketing or advertising purposes.
HOW WE USE YOUR INFORMATION
We use the information we collect for the following purposes:
• To provide and manage your advisory services — including portfolio management, financial planning, account reporting, and client communications
• To meet our legal and regulatory obligations — including obligations under the Investment Advisers Act of 1940, SEC rules and regulations, state securities laws, anti-money laundering requirements, and tax reporting obligations
• To verify your identity — in accordance with Know Your Customer (KYC) and related compliance requirements
• To communicate with you — regarding your account, market updates, regulatory disclosures, and firm announcements
• To maintain our books and records — in accordance with applicable laws and regulations governing registered investment advisers
• To operate and improve our business — including internal compliance, risk management, and operational functions
We do not use your personal information for marketing to unaffiliated third parties, and we do not sell your information.
INFORMATION WE SHARE — AND WITH WHOM
We do not sell, rent, or trade your personal information. We share your information only as described below.
Service Providers and Technology Vendors
We share information with companies that help us operate our business and deliver services to you. These include, but are not limited to:
• Technology and productivity platform providers that support our communications, document management, and business operations
• AI-assisted research and productivity tools used exclusively for internal firm operations
• Compliance, legal, and accounting service providers who assist in meeting our regulatory obligations
• Cybersecurity and IT support providers
All service providers are engaged under agreements that restrict their use of your information to the purposes for which it was shared.
Custodians and Financial Institutions
We share information with the broker-dealers and custodians that hold and administer your investment accounts. This sharing is necessary to execute trades, generate account statements, and service your account.
Required Disclosures
We may disclose your information when required to do so by law, regulation, court order, or governmental authority — including disclosures to the SEC, FINRA, state securities regulators, or law enforcement agencies in connection with regulatory examinations, investigations, or legal proceedings.
With Your Consent
We may share information with other parties if you authorize us to do so in writing.
We do not share your personal information with unaffiliated third parties for marketing or promotional purposes.
YOUR OPT-OUT RIGHTS
Under SEC Regulation S-P, you have the right to opt out of certain disclosures of your personal information to nonaffiliated third parties.
Because Vector7 Capital shares your information only with service providers and custodians necessary to service your account — and not with unaffiliated third parties for marketing or other non-essential purposes — your opt-out rights in this context are limited. Most sharing we engage in is required in order to deliver the services you have engaged us to provide, and opting out of that sharing would prevent us from being able to manage your account.
If you believe we are sharing your information in a way you wish to limit, or if you have questions about your opt-out rights, please contact us at:
(312) 500-6440
420 W Grand Ave, Chicago, IL 60654
HOW WE PROTECT YOUR INFORMATION
We maintain physical, electronic, and procedural safeguards designed to protect your personal information against unauthorized access, disclosure, alteration, or destruction. Our security practices include:
• Access controls limiting information access to personnel with a legitimate business need
• Encryption and secure transmission protocols for electronic communications and data storage
• Regular review of our information security policies and procedures
• Use of business-grade technology platforms with enterprise security standards
No security system is impenetrable. While we take reasonable steps to protect your information, we cannot guarantee that unauthorized parties will never gain access to your personal data. In the event of a security incident that affects your information, we will notify you as required by applicable law.
DATA RETENTION
We retain your personal information for as long as necessary to fulfill the purposes described in this Privacy Policy, and for as long as required by applicable laws and regulations governing registered investment advisers. Our retention practices are designed to meet or exceed all applicable federal and state recordkeeping requirements.
When your information is no longer required to be retained, we dispose of it in a secure manner appropriate to its sensitivity.
ADDITIONAL RIGHTS FOR ILLINOIS RESIDENTS
As an Illinois-registered investment adviser serving Illinois residents, Vector7 Capital Inc. is subject to Illinois state privacy and data protection requirements in addition to federal securities regulations. This section describes rights that apply specifically to Illinois residents.
Right to Know
You have the right to request information about the categories and specific pieces of personal information we have collected about you, the sources from which that information was collected, the purposes for which we use it, and the categories of third parties with whom we share it.
Right to Correction
You have the right to request correction of inaccurate personal information we hold about you. Given our fiduciary obligations, we encourage clients to notify us promptly of any changes to their personal or financial circumstances.
Right to Deletion
You may request deletion of your personal information, subject to our legal obligations to retain certain records under applicable securities laws and regulations. We will inform you if a deletion request cannot be fulfilled due to regulatory recordkeeping requirements.
Right Against Discrimination
We will not discriminate against you for exercising any of the rights described in this section.
Illinois Biometric Information Privacy Act (BIPA)
Vector7 Capital Inc. does not collect, store, or use biometric identifiers or biometric information as defined under the Illinois Biometric Information Privacy Act (740 ILCS 14). If this practice changes, we will update this Privacy Policy and obtain any required consents prior to collection.
How to Submit a Request
To exercise any of the rights described above, contact us at:
(312) 500-6440
We will respond to verifiable requests within the timeframes required by applicable law.
ELECTRONIC COMMUNICATIONS AND DIGITAL PRIVACY
By communicating with us electronically — including via email, text message, or digital document platforms — you acknowledge that electronic communications may not always be secure. We recommend that you do not transmit highly sensitive personal or financial information through unencrypted channels.
Our electronic communications with you, including email and text messaging services, are governed by our Electronic Communications Disclosure and SMS Terms of Use, incorporated herein by reference, and are subject to retention and supervision requirements under applicable securities regulations.
THIRD-PARTY WEBSITES AND PLATFORMS
Our website and communications may contain links to or references to third-party websites, platforms, or services. This Privacy Policy does not apply to those third-party properties. We are not responsible for the privacy practices or content of any third-party services. We encourage you to review the privacy policies of any third-party services you access.
ANNUAL NOTICE — SEC REGULATION S-P
This Privacy Policy constitutes the annual privacy notice required under SEC Regulation S-P (17 CFR Part 248). It is provided to clients of Vector7 Capital Inc. at the inception of the advisory relationship and annually thereafter.
A copy of this notice is available at any time by contacting us at v7@vector7capital.com or (312)-500-6440 and is posted on our website at vector7capital.com.
CHANGES TO THIS PRIVACY POLICY
We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or for other operational reasons. When we make material changes, we will notify you by delivering an updated notice in accordance with our annual distribution obligations under Regulation S-P, or sooner if required by law.
Your continued use of our services following notice of any update constitutes your acceptance of the revised Privacy Policy. The effective date at the top of this document reflects the date of the most recent revision.
CONTACT US
If you have questions, concerns, or requests relating to this Privacy Policy or our privacy practices, please contact us:
Vector7 Capital Inc.
420 W Grand Ave
Chicago, IL 60654
(312) 500-6440
Vector7 Capital Inc. is registered as an investment adviser in the State of Illinois. Registration does not imply a certain level of skill or training. This Privacy Policy satisfies the annual notice requirement under SEC Regulation S-P (17 CFR Part 248). For Form ADV and other disclosures, visit vector7capital.com or contact us at V7@vector7capital.com.