Privacy Policy

Effective Date: July 20, 2026 · Last Updated: August 17, 2026

1. Introduction

High Value Capital Group LLC (“HVCG,” “we,” “us,” or “our”) respects your privacy.

360 Growth Solution is a marketing technology and client marketing-management platform operated by High Value Capital Group LLC. Individual clients and tenants, including healthcare or dental practices that may use the platform, do not own the application.

This Privacy Policy explains how we collect, use, disclose, retain, and protect information when you visit our Website, contact us, schedule a consultation, submit a form, download a resource, interact with an online feature, use 360 Growth Solution, connect a Google Ads account, or otherwise communicate with us.

This policy applies to information collected through the public Website, 360 Growth Solution, and related online interactions. Separate agreements or notices may apply to client engagements, employees, contractors, applicants, investors, lenders, transaction participants, or other specialized relationships.

2. Information We May Collect

Depending on how you interact with HVCG, we may collect the following categories of information.

Information You Provide

• Name
• Business name
• Job title
• Email address
• Telephone number
• Mailing address
• Business website
• Industry
• Business stage
• Financing interests
• Requested funding amount
• Revenue or other general business information
• Consultation preferences
• Messages and inquiry details
• Documents you choose to provide
• Event-registration information
• Newsletter preferences
• Survey or assessment responses, including Enterprise Value Assessment (EVA) answers
• Information submitted through scheduling, chat, intake, contact, privacy-request, or secure-upload tools

360 Growth Solution Account and Advertising Information

When an authorized business customer uses 360 Growth Solution, we may process:

• Business contact and user account information
• Organization and client configuration
• Marketing campaign configuration
• Advertising account identifiers
• Google Ads customer and campaign metadata
• Campaign, ad group, ad, and keyword configuration
• Geographic targeting settings
• Budget settings
• Advertising performance metrics such as impressions, clicks, and cost
• Conversion-action configuration and permitted click-based attribution identifiers (for example, gclid, gbraid, or wbraid) when those identifiers are available
• OAuth authorization metadata needed to maintain a connected Google Ads integration
• Application logs and security or audit metadata

Automatically Collected Information

When you visit the Website, our hosting infrastructure and browser environment may process limited technical information such as:

• IP address
• Browser type
• Device type
• Operating system
• Referring page
• Pages viewed
• Date and time of access
• Approximate geographic region derived from network routing
• Diagnostic and security information generated by the hosting platform

As of the current production configuration audit, the Website does not load third-party analytics SDKs, advertising pixels, retargeting tags, session-replay tools, or similar marketing trackers. Therefore, the Website does not currently generate advertising cookie identifiers or cross-site analytics profiles through HVCG-controlled scripts.

Information From Third Parties

We may receive information from:

• Service providers that support hosting, email, CRM, or scheduling when those integrations are configured
• Referral partners
• Publicly available sources
• Business-information providers
• Lenders, investors, or professional partners when authorized
• Other parties involved in a potential or active business engagement

Google API and Google Ads Data

When an authorized user connects a Google Ads account, 360 Growth Solution may use Google OAuth and the Google Ads API to access authorized advertising information required to provide the service. The current Google OAuth scope requested for this integration is Google Ads account access (https://www.googleapis.com/auth/adwords). HVCG does not request Gmail, Google Drive, Google Calendar, or Google Contacts access for this integration.

Access. Google data is accessed only after an authorized user completes Google OAuth authorization and only within the permissions granted.

Examples of advertising information that may be accessed include:

• Accessible Google Ads customer and account identifiers
• Campaign information and campaign status
• Budgets
• Ads, ad groups, keywords, and negative keywords
• Geographic targeting
• Conversion-action configuration
• Advertising performance metrics

Use. Google Ads information is used to provide advertising management, reporting, analytics, governance, and related functions requested by authorized customers, including to:

• Display and analyze advertising performance
• Configure authorized campaigns
• Manage approved campaign settings
• Enforce budgets and governance rules
• Produce internal and client marketing reports
• Support attribution and marketing analytics

Storage. Authentication credentials and tokens are stored using secure cloud secret-management controls. Related advertising metadata and performance metrics may be stored in HVCG-operated application systems with access controls. This policy does not publish internal infrastructure names, secret names, or credential values.

Sharing. Google Ads account data may be disclosed to:

• The applicable authorized client or account users
• HVCG personnel or authorized contractors supporting the service
• Infrastructure and service providers necessary to operate the service
• Government or legal authorities when legally required

HVCG does not sell Google Ads account data for advertising or data-broker purposes. Infrastructure providers necessarily process information in order to host, secure, and operate the service.

Google is an independent third party. Use of Google services remains subject to Google’s own terms and privacy practices. HVCG is not sponsored, endorsed, certified, or approved by Google.

Healthcare and Patient Information

For healthcare or dental clients, 360 Growth Solution is designed to prevent patient clinical data and protected health information from being transmitted to Google Ads through the Google Ads integration.

The Google Ads integration is designed so that clinical and patient-health information is not intentionally transmitted to Google Ads. The integration is not represented as sending patient records, treatment history, clinical notes, call transcripts, medical or dental diagnoses, appointment notes, or clinical practice-management information to Google Ads.

HVCG does not claim that 360 Growth Solution is HIPAA certified. This section describes product design, not a legal compliance guarantee.

3. Sensitive Information

Do not submit highly sensitive information through general Website forms.

This includes:

• Complete Social Security numbers
• Taxpayer identification numbers
• Bank usernames or passwords
• Complete payment-card information
• Authentication codes
• Private encryption keys
• Detailed medical information
• Protected health information
• Unredacted identity documents
• Confidential transaction documents not requested by HVCG

When sensitive documents are needed, HVCG may provide an approved secure upload method or client portal.

4. How We Use Information

We may use information to:

• Respond to inquiries and privacy requests
• Schedule consultations
• Evaluate whether our services may be appropriate
• Prepare for meetings
• Provide requested information and assessment feedback
• Deliver services under a separate agreement
• Operate and improve the Website
• Maintain business records
• Communicate with prospective and existing clients
• Send requested resources
• Send newsletters or marketing communications when permitted
• Manage referrals and professional relationships
• Detect fraud, abuse, or security threats
• Debug and maintain Website functionality
• Protect our legal rights
• Enforce agreements
• Comply with legal obligations
• Complete a merger, financing, restructuring, acquisition, sale, or similar business transaction
• Carry out other purposes disclosed when information is collected

5. Legal and Operational Bases

Where applicable, HVCG processes information based on:

• Your consent
• Your request for information or services
• Steps taken before entering an agreement
• Performance of a contract
• Legitimate business interests
• Compliance with legal obligations
• Protection of HVCG, its clients, visitors, and others

This section does not represent that any particular international privacy law applies to HVCG unless confirmed through separate legal review.

6. Cookies and Similar Technologies

The Website may use limited browser technologies for necessary operation:

• Strictly necessary / functional local storage: The EVA assessment and certain forms may store progress or confirmation stubs in your browser’s localStorage so you can resume work or see submission status on this device.
• Hosting / CDN: The Website is hosted on Azure Static Web Apps. Azure and related Microsoft edge infrastructure may process standard request logs and security telemetry needed to deliver pages securely.
• Fonts: The Website loads fonts from Google Fonts (fonts.googleapis.com / fonts.gstatic.com). Your browser may contact Google’s font servers to retrieve typefaces. Google may receive technical request data such as IP address according to Google’s own practices.

Current tracking posture: nonessentialTrackingEnabled is set to false in the site legal configuration. A production audit found no Google Analytics, Google Tag Manager, Meta Pixel, Hotjar, Microsoft Clarity, or similar advertising or session-recording pixels installed. Because the Website does not currently load nonessential analytics or advertising trackers, HVCG does not display a cookie preference banner or “Cookie Preferences” control. Displaying a consent banner for technologies that are not present would be misleading.

If HVCG later enables nonessential analytics, advertising, retargeting, or session-replay technologies, this policy and the Website controls will be updated before those technologies are activated, including an appropriate Cookie Preferences mechanism where required.

You may clear or restrict cookies and local storage through your browser settings. Doing so may affect form autosave and similar functional features.

7. Analytics and Advertising

As of the current production configuration:

• HVCG does not use Google Analytics, Google Tag Manager, Meta Pixel, LinkedIn Insight Tag, TikTok Pixel, Hotjar, Microsoft Clarity, or similar analytics, advertising, retargeting, call-tracking, session-replay, or conversion-measurement pixels on the public Website.
• No advertising or retargeting partners are receiving personal information from HVCG Website scripts for cross-context behavioral advertising.

If that changes, HVCG will update this section to identify each provider, purpose, data categories, and preference controls.

8. AI and Automated Tools

The Website includes an AI-assisted Enterprise Value Assessment (EVA) and related automated scoring or recommendation features. Information you submit to EVA may be processed by HVCG systems and technology providers to generate assessment output, maintain security, and deliver the feature, subject to applicable agreements and settings.

Automated or AI-assisted outputs may be incomplete, inaccurate, or outdated. They are informational only and are not legal, tax, accounting, lending, securities, investment, or other regulated advice. Independently review any AI-generated recommendation before making consequential decisions.

HVCG does not use visitor submissions to train public or third-party AI models unless that practice is specifically approved, accurately disclosed, supported by required consent, and protected by appropriate contractual and security controls.

Do not submit highly sensitive information to EVA or other AI features unless a feature has been specifically approved and secured for that purpose.

9. How We Disclose Information

We may disclose information to:

• Hosting and infrastructure providers, including Microsoft Azure Static Web Apps
• Font delivery providers (Google Fonts) for typeface loading
• CRM providers, when an optional CRM HTTP endpoint is configured
• Email and communication providers used to respond to inquiries
• Scheduling platforms, including Microsoft Bookings or similar tools, when a bookings URL or booking HTTP endpoint is configured
• Security and fraud-prevention vendors supporting the hosting platform
• Document-management and cloud-storage providers when secure upload or client-portal features are used
• Professional advisers
• Contractors and service providers
• Lenders, investors, referral partners, or transaction participants when authorized or reasonably necessary for a requested service
• Government agencies, courts, regulators, or law-enforcement authorities when legally required
• Parties involved in a proposed or completed merger, acquisition, financing, restructuring, sale, or transfer of business assets
• Other parties with your direction or consent

For 360 Growth Solution, advertising-account information may also be available to the authorized customer users of that workspace and to HVCG personnel or contractors who support the service.

Optional CRM and Bookings integrations remain inactive until configured by HVCG. When inactive, form and privacy-request submissions are stored locally in the browser (localStorage) as a confirmation stub and are not automatically transmitted to a CRM.

Service providers should receive only the information reasonably necessary to perform their functions and should be subject to appropriate confidentiality, privacy, and security obligations.

10. Sale and Sharing of Personal Information

HVCG does not sell personal information for monetary consideration.

HVCG does not sell Google Ads account data for advertising or data-broker purposes.

Based on the current Website configuration—no advertising pixels, no retargeting tags, and no cross-context behavioral advertising tools—HVCG does not “share” personal information for cross-context behavioral advertising as that concept is commonly described under certain U.S. state privacy laws.

If HVCG later enables technologies that could meet a statutory definition of sale or sharing, HVCG will provide any legally required opt-out links, preference signals recognition, and partner disclosures, and will not display a nonfunctional opt-out control.

11. Data Retention

HVCG retains information for as long as reasonably necessary to:

• Respond to inquiries
• Provide services
• Maintain business and transaction records
• Fulfill contractual obligations
• Resolve disputes
• Enforce agreements
• Maintain security
• Meet legal, tax, accounting, insurance, and compliance obligations

Retention periods may vary depending on the type of information and the nature of the relationship. HVCG does not publish a single fixed deletion period for all records.

OAuth access to a connected Google Ads account can be revoked through the user’s Google Account permissions and/or by contacting HVCG. Authorized customers may request deletion of applicable account or integration data, subject to legitimate retention requirements for security, legal, accounting, contractual, and operational purposes. Revoking Google access does not automatically delete all records that HVCG may be required or permitted to retain.

Browser localStorage stubs remain on your device until you clear them. When information held by HVCG is no longer reasonably required, HVCG may delete, anonymize, or securely dispose of it, subject to legal and operational requirements.

12. Data Security

HVCG uses reasonable administrative, technical, and organizational safeguards designed to protect information. Depending on the system, these may include access controls, tenant separation, encryption in transit, secure secrets and credential management, audit logging, least-privilege access, and human authorization controls for material actions.

However, no method of storage, transmission, or electronic communication is completely secure.

Visitors should not submit sensitive documents through unsecured forms or ordinary email unless specifically instructed.

HVCG does not claim that the Website or 360 Growth Solution is completely secure.

13. Your Privacy Choices

Visitors may:

• Decline OAuth authorization or decline to connect a Google Ads account
• Revoke Google account access using Google account controls
• Contact HVCG about connected-account access or deletion
• Decline to provide optional information
• Unsubscribe from marketing emails
• Clear cookies and local storage through browser settings
• Request access, correction, or deletion where applicable
• Request information about certain disclosures where applicable
• Opt out of qualifying sales, sharing, or targeted advertising where applicable
• Withdraw consent where processing depends on consent

Revoking Google access does not automatically delete all legally retainable records. Because nonessential tracking is currently disabled, there is no separate Cookie Preferences panel to adjust. Some requests may be limited by identity-verification requirements, legal exceptions, record-retention obligations, contractual obligations, or other applicable rules.

14. Nevada Privacy Rights

Nevada law provides certain residents with the right to submit a verified request to opt out of the sale of covered information under the Nevada Revised Statutes, when applicable.

HVCG does not currently sell covered information as described in this policy. To submit a Nevada privacy request, contact manny@highvaluecapitalgroup.com with the subject line “Nevada Privacy Request,” or use the privacy-request form below. We may request information reasonably necessary to verify your identity and process the request.

Not every transfer of information is a “sale” under Nevada law.

15. California Privacy Rights

Conditional notice: California residents may have rights under the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), depending on whether those laws apply to HVCG and to the particular information or relationship. HVCG does not state in this policy that it is presently subject to the CCPA/CPRA as a covered business unless and until applicability has been confirmed through legal review.

Where California privacy law applies, potential rights may include:

• The right to know
• The right to access
• The right to request deletion
• The right to correct inaccurate information
• The right to opt out of qualifying sale or sharing
• The right to limit certain uses of sensitive personal information
• The right not to receive discriminatory treatment for exercising applicable rights

California residents may submit requests using the form in Section 17 or by emailing manny@highvaluecapitalgroup.com with the subject line “Privacy Request.” When applicability is confirmed, HVCG will provide any additional required notices, category disclosures, lookback-period disclosures, and opt-out mechanisms.

16. Other State Privacy Rights

Residents of certain U.S. states may have additional rights under applicable privacy laws.

HVCG will respond to verified requests as required by applicable law.

This policy does not attempt to list every state statute or promise specific statutory rights that may change over time.

17. Submitting a Privacy Request

You may submit a privacy-related request by:

• Email: manny@highvaluecapitalgroup.com with the subject line “Privacy Request”
• The secure web form below

Collect only the information reasonably necessary to process and verify your request. Account creation is not required solely to submit a privacy request. Submitted privacy requests are not displayed publicly and are not added to ordinary marketing lists.

18. Identity Verification

HVCG may take reasonable steps to verify a requester’s identity before completing a privacy request.

Verification should be proportionate to the sensitivity of the requested information.

Authorized-agent requests may require proof of authorization and direct verification where permitted.

19. Marketing Communications

Visitors may unsubscribe from marketing emails using the unsubscribe link in the message or by contacting HVCG.

Transactional, security, legal, or service-related communications may continue when necessary.

HVCG does not send marketing email or text messages without a valid legal and operational basis, and does not use automatic promotional SMS enrollment through general contact forms.

20. Children’s Privacy

The Website is intended for business users and adults and is not directed to children under 13.

HVCG does not knowingly collect personal information from children under 13 through the public Website.

If HVCG learns that such information was collected, it will take reasonable steps to delete it.

21. Third-Party Websites

The Website may link to third-party websites and services.

HVCG is not responsible for their privacy, security, content, or business practices.

Visitors should review the policies of each third party they use.

22. International Visitors

The Website is operated from the United States.

Information may be processed and stored in the United States and other locations where HVCG or its service providers operate, including Microsoft Azure infrastructure.

This policy does not represent that HVCG complies with the GDPR, UK GDPR, or other international privacy regimes unless applicability and compliance have been separately reviewed.

23. Changes to This Privacy Policy

HVCG may update this Privacy Policy periodically.

The updated policy will be posted with a revised “Last Updated” date.

When appropriate or legally required, HVCG may provide additional notice of material changes.

24. Contact HVCG

For privacy questions or requests, contact:

High Value Capital Group LLC
Email: manny@highvaluecapitalgroup.com
Website: https://www.highvaluecapitalgroup.com/