Effective Date: February 24, 2026

GAP Asset Management, LLC and its affiliates (“Graham Allen Partners,” “GAP,” “we,” “our,” or “us”) is a private investment firm registered as an investment adviser with the U.S. Securities and Exchange Commission. GAP respects your privacy and is committed to protecting the personal information you share with us. This Privacy Policy describes how we collect, use, disclose, and safeguard information when you visit our website (the “Site”) or communicate with us through other channels, including text messaging.

By accessing or using our Site or communicating with us via text message, you agree to the terms of this Privacy Policy. If you do not agree with any part of this policy, please do not use our Site or text messaging services.

Information We Collect

Information You Provide to Us

We may collect personal information that you voluntarily provide when you interact with our Site or communicate with us through other channels, including when you submit a contact form, send us a text message, or otherwise reach out to us. This information may include:

•       Name

•       Email address

•       Phone number

•       Company or organization name

•       Message content or inquiry details, including text messages

Text Messaging

We offer the ability to contact us via text message through Zoom Phone, a communications platform provided by Zoom Video Communications, Inc. (“Zoom”). When you send us a text message, the following information may be collected and processed:

•       Your phone number

•       The content of your text messages

•       Date and time of messages

Text messages sent to us are transmitted through and may be stored by Zoom in accordance with Zoom’s own privacy policy. We encourage you to review Zoom’s Privacy Policy at zoom.us/privacy for information on how Zoom handles your data. By texting us, you consent to the collection and processing of this information by both GAP and Zoom.

Standard messaging rates from your wireless carrier may apply. We do not charge for text messages sent to us. You may opt out of text message communications at any time by texting STOP or by contacting us directly.

Information Collected Automatically

When you visit our Site, certain information is collected automatically through cookies and similar tracking technologies used by Squarespace, our website hosting platform. This may include:

•       IP address

•       Browser type and version

•       Operating system

•       Pages visited and time spent on those pages

•       Referring website or source

•       Device type and screen resolution

•       Geographic location (at the city or region level)

How We Use Your Information

We use the information we collect for the following purposes:

•       To respond to your inquiries and communicate with you

•       To operate, maintain, and improve our Site

•       To analyze Site usage and trends to enhance the user experience

•       To comply with legal obligations and enforce our policies

•       To protect against unauthorized access, fraud, or other illegal activity

•       To fulfill regulatory recordkeeping and reporting obligations applicable to SEC-registered investment advisers

Cookies and Tracking Technologies

Our Site uses cookies and similar technologies to collect and store information when you visit. Cookies are small data files placed on your device that help us understand how visitors interact with our Site.

Squarespace Analytics. Our Site is hosted on Squarespace, Inc. (“Squarespace”), which provides built-in analytics that use cookies to help us understand how visitors interact with our Site. Squarespace’s analytics cookies collect information such as visitor counts, page views, traffic sources, and geographic data. This information is used to evaluate Site usage and improve our online presence. Squarespace may also place necessary cookies on your device to enable core Site functionality. For more information on how Squarespace handles data, please visit Squarespace’s Privacy Policy at squarespace.com/privacy.

You can control cookie preferences through your browser settings. Please note that disabling cookies may affect the functionality of certain parts of the Site.

Disclosure of Your Information

We do not sell, rent, or trade your personal information to third parties. We may share your information in the following circumstances:

•       Service Providers: We may share information with third-party vendors who perform services on our behalf, such as website hosting and analytics (Squarespace), communications platforms (Zoom for text messaging), and email delivery, subject to confidentiality obligations.

•       Legal Requirements: We may disclose information if required to do so by law, regulation, legal process, or governmental request, including in connection with SEC examinations or investigations.

•       Business Transfers: In the event of a merger, acquisition, reorganization, or sale of assets, your information may be transferred as part of that transaction.

•       Protection of Rights: We may disclose information to protect the rights, property, or safety of GAP, our users, or the public.

Data Security

We implement reasonable administrative, technical, and physical safeguards designed to protect the personal information we collect. We maintain an incident response program to detect, respond to, and remediate security incidents involving personal information, in accordance with applicable regulatory requirements. However, no method of transmission over the internet or method of electronic storage is completely secure. While we strive to protect your personal information, we cannot guarantee its absolute security.

Data Retention

We retain personal information only for as long as necessary to fulfill the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law or by applicable regulatory requirements, including SEC books and records rules. Contact form submissions and text message records are retained for the duration of our business relationship and as needed for recordkeeping purposes. Please note that text message data may also be retained by Zoom in accordance with its own data retention policies.

Third-Party Links

Our Site may contain links to third-party websites or services that are not owned or controlled by GAP. We are not responsible for the privacy practices of those third parties. We encourage you to review the privacy policies of any third-party sites you visit.

Children’s Privacy

Our Site is not directed to individuals under the age of 13, and we do not knowingly collect personal information from children under 13. If we learn that we have collected personal information from a child under 13, we will take steps to delete that information promptly.

Your Rights and Choices

Depending on your jurisdiction, you may have certain rights regarding your personal information, including the right to access, correct, delete, or restrict the processing of your data. To exercise any of these rights, please contact us using the information provided below.

If you are a resident of California, you may have additional rights under the California Consumer Privacy Act (CCPA). Please contact us for more information.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. We will post the updated policy on this page with a revised effective date. We encourage you to review this Privacy Policy periodically.

Contact Us

If you have any questions about this Privacy Policy or our data practices, please contact us at info@graham-allen.com or (574) 485-2146. Our principal office is located at 100 E. Wayne Street, Suite 450, South Bend, IN 46601.