Privacy Policy

This Privacy Policy applies to the websites and corporate digital properties of Territory Holdings, Inc. that link to it — including territory-holdings.com — and to the company inquiries, investor inquiries, communications, and corporate website activity conducted through them (together, the “Site”).

It covers what happens when you browse the Site, submit an investor inquiry, request or use access to the Investor Center, or correspond with us.

This policy does not govern:

• AnglerPass or any other operating platform that publishes its own privacy policy. AnglerPass maintains separate privacy terms for its platform users — see the AnglerPass Privacy Policy.
• Future portfolio platforms, which are expected to publish their own privacy policies before collecting platform-user information.
• Third-party providers involved in the investment process — such as document-preparation, electronic-signature, cap-table, transfer-agent, banking, identity-verification, or offering-administration providers — which maintain their own privacy policies for information submitted to them directly.

The information we collect reflects what the Site is for. Depending on how you interact with us, it may include:

• Contact details — your name, email address, telephone number, and mailing address.
• Professional and entity information — a company or entity name, your title or role, the entity's state of formation, its authorized signer, and whether you intend to invest individually or through an entity such as an LLC, trust, corporation, or fund.
• Investor-status information — whether you identify as an accredited investor and, if you choose to provide it, the self-certified basis for that status.
• Investment interest — the amount you propose to invest and the territory platforms you are most interested in. Stating an intended amount is an indication of interest, not a binding commitment or a completed investment.
• Certifications and signatures — the acknowledgements you check and the typed signature and date submitted with an investor inquiry, and, where an investment proceeds, records connected to executed offering documents.
• Communications — email correspondence, inquiry submissions, meeting requests, scheduling information, and follow-up messages.
• Investor Center access information — the email address used to request a one-time sign-in code, verification outcomes, session state, and access approvals or revocations for the invite-only Investor Center.
• Technical information — IP address, browser and device class, referring page, pages visited, timestamps, and approximate region, collected through hosting logs and the privacy-focused analytics described in Section 8.
• Security and fraud-prevention data — outcomes from the bot-protection service that guards our forms.
• Required records — corporate, tax, securities, transfer-agent, and compliance records connected to an investor or security-holder relationship.

We obtain information from a small number of sources:

• Directly from you — through the investor inquiry form, the Investor Center sign-in gate, email, telephone, meetings, and other correspondence.
• From the investment process — providers that prepare offering documents, record ownership, or otherwise administer an offering (Section 6) may confirm information about your investment back to us.
• From the services that operate the Site — hosting, analytics, security, authentication, and email infrastructure generate the technical and delivery records described in Sections 2 and 8.
• From publicly available professional or business information, where relevant to an inquiry or relationship.
• From referrals — existing investors, founders, advisors, or business contacts who introduce you to us.

We use the information described above to:

• Respond to inquiries and correspond with you.
• Evaluate investor interest and eligibility for a private offering.
• Provide access to company or investor materials, including the invite-only Investor Center.
• Administer an offering or an ongoing investment relationship, and maintain shareholder and security-holder records.
• Send company, offering, governance, and investor communications connected to your inquiry or relationship.
• Schedule and prepare for meetings.
• Operate, secure, and improve the Site, including detecting abuse, fraud, and unauthorized access.
• Maintain corporate, tax, legal, and securities records, and comply with subpoenas, laws, regulatory requirements, and contractual obligations.
• Establish and defend legal claims and enforce agreements.

Territory Holdings does not sell personal information for money. We disclose personal information only in the circumstances described here:

• Investment-process providers — the document-preparation, electronic-signature, cap-table, transfer-agent, banking, identity-verification, accreditation, or offering-administration providers described in Section 6, to the extent needed to administer an inquiry, offering, or investment.
• Professional advisors — legal counsel, accountants, auditors, tax professionals, and corporate administrators, under professional or contractual duties of confidentiality.
• Compliance and screening providers — identity, accreditation, anti-fraud, sanctions-screening, or regulatory-compliance services, if and where an offering requires them.
• Infrastructure providers — the hosting, analytics, authentication, email-delivery, and bot-protection services that run the Site, described in Section 8. These providers process information to provide their services to us, not for their own advertising.
• Affiliates and subsidiaries — where reasonably necessary for corporate administration, support, security, legal compliance, or an interaction you request (Section 7).
• Government agencies, courts, regulators, or law enforcement — where we believe disclosure is required by law, subpoena, or legal process, or is necessary to protect rights, safety, or the integrity of an offering.
• Corporate transactions — parties involved in a financing, reorganization, merger, acquisition, asset sale, or similar transaction, in which investor and corporate records are customarily reviewed and transferred subject to confidentiality protections.

We do not use advertising networks, and we do not disclose personal information to third parties for cross-context behavioral advertising. Section 12 describes rights that may apply under U.S. state privacy laws.

Territory Holdings may use third-party providers to administer an offering, investor onboarding, securities issuance, ownership records, electronic documents, identity or accreditation checks, payments, or related functions. As of the last-updated date of this policy, SAFE agreements are prepared and signed electronically through Clerky, and executed investments are recorded with Pulley, the company's cap-table provider. Territory Holdings may engage additional or successor providers — such as offering-administration platforms, transfer agents, or verification services — as an offering requires.

• Information you submit directly to those providers is governed by their own terms and privacy policies, in addition to any agreement you sign with Territory Holdings.
• Territory Holdings does not control the independent security, retention, or data-processing practices of independent providers.
• Investment transactions themselves are governed by the applicable offering and transaction documents, not by this policy.

Funding for an executed investment is transferred using the instructions provided with the executed agreement. The Site itself does not collect bank or payment details.

Territory Holdings owns or supports a portfolio of category-specific outdoor-access platforms. Each operating platform may maintain its own accounts, databases, policies, vendors, and legal terms.

• Information you submit to AnglerPass is governed by the AnglerPass Privacy Policy, not by this one. The consumer booking, club-membership, land-access, guide, and payment services offered through AnglerPass are operated by Angler Pass LLC under AnglerPass's separate legal documents.
• Information is not automatically pooled across portfolio companies.
• Territory Holdings and an affiliate may share information where reasonably needed for corporate administration, support, security, legal compliance, or an interaction you request.
• Future platforms are expected to publish their own privacy policies before collecting platform-user information.

The Site is deliberately light on tracking. It uses three things:

• Strictly necessary sign-in cookies. When an invited investor signs in to the Investor Center with a one-time email code, our authentication provider (Supabase) sets session cookies so that access persists across pages and visits. These cookies exist only to keep you signed in; they are set in the sign-in flow and are not used for advertising or cross-site tracking.
• Bot protection on forms. The investor inquiry form is protected by Cloudflare Turnstile, which runs inside the form to distinguish people from automated abuse and may use cookies or similar technologies within its widget for that purpose. When a submission is verified, your IP address is shared with Cloudflare to validate the challenge.
• Privacy-focused, cookieless analytics. We use Vercel Analytics and Vercel Speed Insights to understand aggregate page views and site performance. These tools do not set cookies and do not build cross-site visitor profiles.

We keep information for as long as it is needed for the purpose it was collected, and no single schedule fits every record:

• Inquiries and correspondence are retained while they are being evaluated and while the conversation or relationship remains active or reasonably relevant.
• Investor and security-holder records are retained for the duration of the relationship and afterward as required by corporate, tax, accounting, securities, transfer-agent, anti-fraud, contractual, and other legal obligations.
• Some records are retained as needed for dispute resolution, enforcement of agreements, and the defense of legal claims.

We cannot delete records that we are legally or contractually required to retain, and this policy does not promise otherwise.

We use reasonable administrative, organizational, and technical safeguards designed to protect the information described in this policy — including invite-only access to the Investor Center, verification challenges on public forms, and limiting access to personal information to the people and providers who need it.

No method of transmission or storage is guaranteed to be completely secure, and we cannot promise absolute security. If you believe your interaction with the Site has been compromised, contact us at hello@territory-holdings.com.

Depending on your circumstances, you may request, as applicable:

• Access to the personal information we hold about you.
• Correction of inaccurate information.
• Deletion of information we are not required to keep.
• A copy of information you provided to us.
• Withdrawal from non-transactional marketing communications. Communications required to administer an inquiry, offering, or investor relationship — confirmations, offering notices, governance and security-holder communications — are not marketing and may continue.
• Information about the disclosures described in Section 5.

These rights depend on your jurisdiction and may be limited by securities, corporate-record, tax, fraud-prevention, contractual, and legal-retention requirements. If we cannot fulfill a request, we will explain why. To make a request, email hello@territory-holdings.com. We may need to verify your identity before acting on a request.

Depending on where you live and whether the applicable law covers Territory Holdings, you may have additional rights under state privacy laws such as the California Consumer Privacy Act or the Colorado Privacy Act, including:

• The right to know or access the personal information collected about you.
• The right to correct inaccurate personal information.
• The right to delete personal information, subject to legal exceptions.
• The right to receive a portable copy of your personal information.
• The right to opt out of certain sales, sharing, targeted advertising, or profiling, where applicable.
• The right not to receive discriminatory treatment for exercising applicable rights.
• The right to appeal a denied request, where applicable law provides one.

Territory Holdings does not sell personal information for money, and it does not share personal information for cross-context behavioral advertising as those terms are defined under California law. The Site uses no advertising or cross-site tracking technology (Section 8), so no “Do Not Sell or Share My Personal Information” link is currently required. If our practices change, we will update this policy and add the controls the law requires.

State privacy laws apply only above certain thresholds, and Territory Holdings does not represent that every statute currently applies to it. We will honor the rights that applicable law actually provides. Requests can be made at hello@territory-holdings.com.

The Site and our investment-related experiences are not directed to children under 13, and we do not knowingly collect personal information from children.

Investment inquiry and offering participation are intended only for persons who are legally able to enter binding agreements and who satisfy the requirements of the applicable offering. Reading the public website carries no such requirement — general visitors are welcome.

Territory Holdings is based in the United States, and information collected through the Site is processed and stored in the United States, where privacy laws may differ from those of your jurisdiction. By using the Site or contacting us, you understand that your information will be processed in the United States.

If you are located outside the United States and have questions about rights that may apply to you, contact us at hello@territory-holdings.com.

We may update this Privacy Policy from time to time. When we do, we will post the updated version on this page and revise the effective or last-updated date at the top. For material changes, we will make the update reasonably prominent. Your continued use of the Site after an update means the revised policy applies to that use.

We do not promise individual notice to anonymous website visitors, though we may notify investors and active correspondents directly where appropriate.

Questions, requests, and concerns about this Privacy Policy can be directed to:

• Territory Holdings, Inc.
• Email: hello@territory-holdings.com
• Mail: 209 Kalamath Street, Unit One, Denver, CO 80223

Use of the Site is also governed by our Terms of Use.