Privacy Policy.

This Privacy Policy describes the practices of Dave Carter Group LLC (a Wyoming limited liability company), Dave Carter Integrated Services Ltd (a Nigerian limited liability company), and Kola Adisa in his capacity as an individually-licensed New York REALTOR® (collectively, "we," "us," or "our") regarding the personal information of individuals ("you") who interact with our websites, services, or business operations.

We are committed to protecting your privacy and to handling personal information with care, discretion, and respect for your rights under applicable law. This policy applies to all information we collect through our websites, email communications, client engagements, and related interactions.

By using our websites or engaging our services, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with our practices as described here, please do not use our websites or services.

We collect personal information in several ways, depending on your interaction with us:

Information you provide directly

• Name, email address, phone number, and mailing address when you submit an inquiry form or subscribe to our journal
• Professional information (company, role, location) relevant to your inquiry
• Financial information and investment details (only when provided in the context of an active engagement)
• Identity verification documents required for regulatory compliance (KYC, AML)
• Any other information you voluntarily share in communications with us

Information collected automatically

• IP address, browser type, device identifiers, and operating system
• Pages visited, time spent, referral sources, and basic analytics data
• Cookies and similar tracking technologies (see Section 08)

Information from third parties

• Referral information when a client or contact introduces you to us
• Publicly available professional information (e.g., LinkedIn) relevant to pre-engagement research
• Third-party services we use for payments, identity verification, or compliance checks

We use personal information for the following purposes:

• Responding to your inquiries and communications
• Providing advisory, consulting, and (where applicable) brokerage services
• Performing regulatory and compliance checks (KYC, AML, sanctions screening)
• Sending subscription-based content (The Advisory Journal) when requested
• Managing client engagements, invoicing, and payment processing
• Improving our websites, services, and client experience
• Protecting our rights, property, and legitimate business interests
• Complying with applicable legal, tax, and regulatory obligations

We do not use your personal information for third-party advertising, behavioral profiling for marketing purposes, or sale to data brokers.

We share personal information only in limited, specific circumstances:

• With service providers: Third-party vendors who support our operations (email platforms, payment processors, cloud storage, analytics) — bound by confidentiality obligations.
• With professional advisors: Attorneys, accountants, and auditors who require access to fulfill their professional duties to us or to a client engagement.
• For compliance: When required by law, regulation, subpoena, court order, or legitimate government request.
• During business transitions: In the event of a merger, sale, or restructuring of Dave Carter Group LLC or its affiliates, with continued privacy protections.
• With your consent: Any other disclosure that is expressly authorized by you in writing.

We do not sell, rent, or trade your personal information to third parties for their marketing purposes. Client identities and the substance of engagements are treated as strictly confidential.

We implement reasonable administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, disclosure, alteration, or destruction. These measures include:

• Encrypted transmission of sensitive data (TLS/SSL)
• Access controls limiting who within our organization can view client information
• Secure hosting and cloud storage with established providers
• Written confidentiality obligations for all team members and service providers
• Regular review of security practices and prompt remediation of identified risks

Despite these measures, no method of transmission over the internet or method of electronic storage is 100% secure. While we strive to use commercially reasonable means to protect your information, we cannot guarantee absolute security.

We retain personal information for as long as necessary to fulfill the purposes for which it was collected, including:

• The duration of any active client engagement
• The period required to comply with applicable legal, tax, and regulatory obligations (typically 7 years for financial records)
• The period required to establish, exercise, or defend legal claims
• As required by professional standards governing brokerage and advisory relationships

When personal information is no longer needed, we take reasonable steps to securely delete or anonymize it.

Depending on your jurisdiction, you may have certain rights regarding your personal information, including:

• Access: Request a copy of the personal information we hold about you.
• Correction: Request correction of inaccurate or incomplete information.
• Deletion: Request deletion of your personal information, subject to legal retention obligations.
• Objection: Object to certain processing of your information.
• Portability: Request transfer of your information to another service provider.
• Withdraw consent: Withdraw consent for processing that relies on your consent.
• Lodge a complaint: File a complaint with a relevant data protection authority.

To exercise any of these rights, please contact us at info@davecartergroup.com. We will respond within a reasonable time and in accordance with applicable law.

Our websites use minimal cookies and similar technologies to ensure functionality and understand basic usage patterns. We do not use cookies for invasive tracking or third-party advertising purposes.

Types of cookies we may use

• Essential cookies: Required for website functionality and security.
• Analytics cookies: Help us understand aggregate usage (e.g., Google Analytics) — anonymized where possible.
• Preference cookies: Remember your preferences (e.g., language, display options).

You can control cookies through your browser settings. Disabling cookies may affect website functionality.

We operate across multiple jurisdictions, including the United States and Nigeria. Personal information may be transferred to, stored, and processed in countries other than the country in which you reside. These countries may have data protection laws that differ from those of your home country.

When we transfer personal information internationally, we take steps to ensure appropriate safeguards are in place, including contractual protections and reliance on recognized transfer mechanisms under applicable law.

Our services are intended for adults engaged in real estate investment, advisory, or professional business. We do not knowingly collect personal information from individuals under the age of 18.

If we become aware that we have inadvertently collected personal information from a minor, we will take reasonable steps to delete such information from our records.

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or business operations. The "Effective Date" and "Last Reviewed" notations at the top of this page indicate when the policy was most recently updated.

For material changes, we will provide reasonable notice — through our websites, email, or other appropriate means — before the changes take effect. Your continued use of our services after such notice constitutes acceptance of the updated policy.