Last Updated: September 2, 2025

BMC Investment Company, LLC and BLDG Management II Co., LLC (together with their respective affiliates, “BMC Investments” or “we,” “us,” or “our”) are committed to privacy. This Privacy Policy (“Policy”) describes how we collect, use, protect and disclose Personal Information when you: (1) access the BMC Investments investor portal, made available by our third party partner, Agora, or any websites owned or controlled by BMC Investments (now or in the future), including https://bmcinv.com/ and webpages available from that website (collectively, our “Websites”); and/or (2) use any services provided by BMC Investments through our Websites, including in connection with the formation and ongoing activities of our private investment funds (collectively, the “Services”) (collectively, the Website and the Services are referred to herein as the “Investor Portal”).

PLEASE READ THIS POLICY CAREFULLY. THIS POLICY DOES NOT APPLY TO THE COLLECTION, USE, DISCLOSURE OR PROTECTION OF PERSONAL INFORMATION BY ANY THIRD PARTY, INCLUDING, WITHOUT LIMITATION, AGORA OR ANY THIRD PARTY WHO YOU ARE CONNECTED TO OR OTHERWISE INTERACT WITH THROUGH OR IN CONNECTION WITH YOUR ACCESS TO OR USE OF OUR INVESTOR PORTAL.

WE MAY MODIFY THIS POLICY AT ANY TIME. ALL CHANGES WILL BE EFFECTIVE IMMEDIATELY. MATERIAL CHANGES WILL BE CONSPICUOUSLY POSTED ON THE INVESTOR PORTAL OR OTHERWISE COMMUNICATED TO YOU. IF YOU DO NOT WANT US TO COLLECT, USE OR SHARE YOUR INFORMATION IN THE WAYS DESCRIBED IN THIS POLICY, PLEASE DO NOT USE THE INVESTOR PORTAL.

If you have any questions about this Policy, please contact us at investors@bmcinv.com.

1.      What is Personal Information?

When we refer to “Personal Information” in this Policy, we mean information that identifies, relates to, describes or is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to a specific person. Please note, Personal Information does not include information that is publicly available from government records, from deidentified or aggregated consumer information or is otherwise publicly available. In addition, any anonymized information we provide to third parties is not considered Personal Information and is not subject to the terms of this Policy.

2.     The Information We Collect

This section describes what Personal Information we collect and the different ways we collect it. We may collect the following Personal Information from or about you:

Information We Collect from You

In order to use or engage in some of our Services or use the Investor Portal, you will need to register for an account and provide certain Personal Information to us.

This also applies if you are acting on behalf of an institution. If you do not provide the Personal Information we request, you may not be able to benefit from our Services if that information is necessary to provide you with the applicable Service or we are legally required to collect it. Examples of Personal Information we may collect include the following:

·         Contact Information: Your name, your address, phone number, email address, telephone number, or contacts.

·         Regulated Information: This includes your social security number or employer identification number (as applicable) and financial account information.

·         Communications: We may also collect information about you when you communicate with us, including answering your questions or when you provide feedback, such as relevant contact information and the contents of your messages. This can also include information we receive from you on subscription agreements, investor questionnaires or other forms that you submit to us or contracts that you enter into with us, and information obtained from meetings and telephone conversations with you.

·         Protected Classifications: This type of information may include your age, race, marital status, or citizenship.

·         Sensitive Personal Information: Some of the information we collect from you may be considered sensitive personal information, including your social security number, financial account information.

·         Commercial Information: Meaning your records of personal property, our products and services you have obtained or considered, including information about your transactions with us, our affiliates or others.

Information Automatically Collected

Like many websites, our Website uses “cookie” technology to collect additional website usage data. A cookie is a small data file that we transfer to your computer’s hard disk. We may use both session and persistent cookies. A session cookie enables certain features of our Website and is deleted from your computer when you disconnect from or leave our Website. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to our Website.

When you use the Website, our systems automatically collect information that your browser or device sends whenever you visit a website or utilize an application. This information may include:

·         Identifiers: Such as your IP address, your mobile telephone number, cookie identifiers, and your device identifier.

·         Internet Activity: The type of device you are using, the internet service provider or mobile carrier you are using, and your activities within the Services, including the links you click, the pages or screens you view, your session time, the number of times you click a page/screen or use a feature of the Investment Portal, your browsing and search history, the date and time you click on a page or use a feature and the amount of time you spend on a page or using a feature.

·         Geolocation: Your general geographic location (like your country and zip code associated with your IP address).

Information We Collect from Service Providers and Third Parties

·         Service Providers: We collect your personal information from service providers when you register for the Services to validate your identity. This practice is mandatory under federal “Know Your Customer” requirements. Information we may receive from these service providers includes contact information, commercial information, and government-issued identifiers.

·         Recruiters: We may receive information about you from employment recruiters who provide us with prospective job applicants. Information we may receive from recruiters includes contact information and employment history.

3.     How We Use the Information We Collect

We may disclose your Personal Information to nonaffiliated third parties as permitted by law and in accordance with the agreements governing your investment in our private funds. Examples of how we may use the Personal Information collected are described below. We will not sell any Personal Information to third parties that is collected through the Investor Portal.

Customer Service and Customer Communications

We may use the Personal Information we collect to provide you with the Services you requested, customer service, alerts and updates about the Services, to respond to your questions and receive your feedback about the Investor Portal.

Account Registration and Management

We use your Personal Information to register you with an account with us and to manage your account as necessary to provide you with the Investor Portal and maintain the security of your account.

Website Analytics

We may use Personal Information to better understand how you interact with our Website, to monitor aggregate usage by our users and web traffic routing on our Website, and to improve our Investor Portal.

Business Purposes

We may use the Personal Information we collect for non-marketing business purposes including (1) validating your identity; (2) conducting statistical or demographic analysis; (3) customizing your experience with the Investor Portal; (4) carrying out our obligations and enforcing our rights arising from any contracts we have entered into, including, but not limited to, any contracts between you and us; (5) operating and improving the Investor Portal; and (6) for other business purposes permitted under applicable law.

Law Enforcement/Legal Purposes

We may use Personal Data to cooperate with law enforcement or other legal purposes including: (1) complying with legal and regulatory requirements; (2) satisfying contractual obligations; (3) protecting and defending BMC Investments against legal actions or claims; (4) preventing fraud; (5) cooperating with law enforcement or other government agencies for purposes of investigations, national security, public safety or matters of public importance when we believe that disclosure of Personal Information is necessary or appropriate to protect the public interest; and (6) protecting and defending against legal actions or claims.

Marketing Purposes

We may use the Personal Information we collect for our own marketing purposes including notifying you of investment opportunities and events via email and other means, subject to compliance with applicable laws. We may also link Personal Information (including your name, mobile phone number, and email address) with non-personal information (including Personal Information automatically collected as described in this Policy) and use such information for our own marketing purposes. If you do not want to use your Personal Information for marketing purposes, you may opt-out in accordance with the procedures described in the “Managing Your Personal Information” below.

4.     How Long Do We Keep Your Personal Information?

We retain Personal Information only as long as we have a legitimate business purpose to keep it. These purposes may include retaining Personal Information to: (1) complete the purpose for which the Personal Information was collected; (2) continue our ongoing business relationship with you; (3) ensure the security and integrity of the Investor Portal; and (4) satisfy any legal, regulatory, tax, accounting, or reporting requirements.

To determine the appropriate retention period for individual categories of Personal Information we collect, we consider the nature and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of the Personal Information, the purposes for which we process that Personal Information and whether we can fulfill those purposes through other means, the governing documents of the relevant investment and applicable legal, regulatory, tax, accounting, reporting or other requirements.

5.     With Whom We Share Personal Information

For business purposes, we may share Personal Information we receive from and about you, and about your relationship with us, with our affiliates and certain third parties. This section describes some examples of third parties we may share your Personal Information with and the purposes for that sharing.

Third-Party Service Providers

Your Personal Information may be shared with or collected by third party service providers who provide us with services, including, but not limited to data hosting or processing and verifying your identity pursuant to applicable law. We require these third-party service providers to exercise reasonable care to protect your Personal Information and restrict their use of your Personal Information to the purposes for which it was provided to them.

Third-Party Businesses

We may share certain limited Personal Information with other companies with whom we have a contractual relationship for their business and other lawful purposes.

Advertising and Analytics Technology

We may also allow third party businesses to use cookies or similar technologies to collect information about your browsing activities over time and across different websites following your use of the Website.

Parties to Business Transactions; Bankruptcy

In the event of a merger, acquisition, bankruptcy or other sale of all or a portion of our assets, we may transfer or allow third parties to use information owned or controlled by us, including any Personal Information. We reserve the right, in connection with these types of transactions, to transfer or assign your information and other information we have collected from our customers to third parties or to authorize third parties to use any such information retained by us. Other than to the extent ordered by a bankruptcy or other court, the use and disclosure of all transferred user information will be subject to this Policy. However, any information you submit or that is collected after this type of transfer may be subject to a new privacy policy adopted by the successor entity.

Government and Law Enforcement

BMC Investments cooperates with government and law enforcement officials or private parties to enforce and comply with the law. To the extent permitted under applicable law, we may disclose any information about you to government or law enforcement officials or private parties as we believe is necessary or appropriate to investigate, respond to, and defend against legal claims, for legal process (including subpoenas), to protect the property and rights of BMC Investments or a third party, to protect BMC Investments against liability, for the safety of the public or any person, to prevent or stop any illegal, unethical, fraudulent, abusive, or legally actionable activity, to protect the security or integrity of the Services and our Website and any equipment used to make the Investor Portal available, or to comply with applicable law.

Professional Advisors

We may disclose your Personal Information to our professional advisors, such as our attorneys, accountants, financial advisors, and business advisors, in their capacity as advisors to us.

Others

We may disclose your Personal Information to any other third party upon your request or with your express consent to do so.

6.     Additional Information About Our Privacy Practices

Deidentified and Aggregated Information

We may also use information in the aggregate to understand how our users as a group use the Investor Portal. BMC Investments will not collect additional categories of Personal Information or use the Personal Information we collect for materially different, unrelated or incompatible purposes without providing you notice.

Protecting Your Personal Information

We maintain commercially reasonable safeguards to maintain the security and privacy of Personal Information that you provide to us. Nevertheless, when disclosing Personal Information, you should remain mindful that there is an inherent risk in the use of email and the internet and we cannot and do not guarantee that these measures will prevent every unauthorized attempt to access, use or disclose your Personal Data despite our efforts.

We cannot guarantee the security of any information you disclose online, and you do so at your own risk.

Children’s Privacy

We do not knowingly collect or allow the collection of Personal Information via the Investor Portal from persons under the age of 13. If we learn that we have collected the Personal Information of someone under the age of 13, we will take appropriate steps to delete this information. If you are a parent or guardian of someone under the age of 13 and discover that your child has submitted Personal Information, you may contact us at investors@bmcinv.com and ask us to remove your child’s Personal Information from our systems.

Notice to Individuals Outside the United States

Unless approved in advance by BMC Investments, BMC Investments’ Services are not intended for individuals located outside the United States. If you are not a resident of the United States, please do not provide us with any Personal Information without the prior written approval of BMC Investments.

Third-Party Websites

For your convenience, the Website may contain or provide links to other sites and resources provided by third parties. Except as otherwise described in this Policy, these links are provided for your convenience only and do not imply any affiliation with, or an endorsement, authorization, sponsorship or promotion of any third party. We are not responsible for the privacy policies or practices of any third-parties or any third-party websites. If you choose to access third-party websites, you do so at your own risk, and you should read the terms and conditions and privacy policies for each website that you visit. By using the investor portal offered by Agora, you will be subject to Agora’s privacy policy.

Social Media

We are active on social media, including Instagram and LinkedIn (“Social Media”). Anything you post on Social Media is public information and will not be treated confidentially. We may post (or re-post) on the Website and our Social Media pages any comments or content that you post on our Social Media pages. Your use of Social Media is governed by the privacy policies and terms of the providers that own and operate those websites and not by this Policy. We encourage you to review those policies and terms.

7.     Managing Your Personal Information

You may decline to share certain information with us, in which case, we may not be able to permit you to participate in some of the Services we offer or access to the Website. To protect your privacy and security, we take reasonable steps to verify your identity before granting you account access or making corrections to your information. You are responsible for maintaining the secrecy of your unique password and account information at all times.

Updating Your Contact Information

You may update your contact information and communication preferences by contacting us as described below or logging into your online account.

Closing Your Account

You may close your account with us by sending us an email at investors@bmcinv.com with the phrase “Close My Account” in the subject line, and we will close your account.

Email Opt-Out

From time to time (and with your consent when required), you may receive periodic marketing mailings or emails from us with news or other information from us or on our behalf. If at any time you wish to stop receiving emails or mailings from us, please send us an email at investors@bmcinv.com with the phrase “Privacy Opt-Out: BMC Investments Mailings” in the subject line, and we will remove you from our mailing list.

Alternatively, for email communications, you may opt out of receiving certain communications by following the unsubscribe instructions set forth in most promotional email message from us. Your unsubscribe request or email preferences change will be processed promptly, though this process may take several days. During that processing period, you may receive additional promotional emails from us. Please note, opting out of email communications will not apply to email communications we send you about your account or other transactional email communications.

Browser Settings

Most browsers automatically accept cookies. You can disable this function by changing your browser settings but disabling cookies may impact your use and enjoyment of the Website. You cannot disable all cookies on the Website, such as cookies that are essential to the functioning of the Website. You can manually delete persistent cookies, or cookies that track your activity across websites, through your browser settings.

Consumer Resources

To change your preferences with respect to certain online ads and to obtain more information about third-party ad networks and online behavioral advertising, visit National Advertising Initiative Consumer opt-out page or the Digital Advertising Alliance Self-Regulatory Program. Changing your settings with individual browsers or ad networks will not necessarily carry over to other browsers or ad networks. As a result, depending on the opt-outs you request, you may still see our ads.

Site Analytics

·         Google Analytics: We may use Google Analytics, a web analytics service provided by Google, Inc. (“Google”), to assist us in understanding how our Website is used. Google Analytics will place cookies on your browser that will generate information that we select about your use of our Website, including your computer’s or mobile device’s IP address. That information will be transmitted directly to and stored by Google. The information will be used for the purposes of evaluating use of our Website, compiling reports on activity on our Website for our use and providing other services relating to activity on, and usage of, our Website. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. To prevent this data from being used by Google Analytics, follow the instructions to download and install the Google Analytics Opt-out Browser Add-on for each web browser you use. Using the Google Analytics opt-out browser add-on will not prevent us from using other analytics tools and will not prevent data from being sent to the Website itself or to Google. Opting out will not affect your use of the Website. For more information on how Google uses Personal Data, visit Google’s Privacy Policy and Google’s page on How Google uses data when you use our partners’ sites or apps.

·         Google Tag Manager: We may use Google Tag Manager (“GTM”), a tag management system that allows JavaScript and HTML tags to be quickly deployed and updated on portions of our Website for tracking and analytics. We may use GTM on our Website to include Google Analytics. If you have opted out of Google Analytics, GTM will take this opt out into account. For more information about Google’s privacy practices applicable to GTM, please refer to Google’s Privacy Policy and the terms of use at Google Tag Manager’s Use Policy.

8.      Additional Privacy Rights for California Residents

The California Consumer Privacy Act of 2018 and subsequent California Privacy Rights Act (together referred to herein as the “CCPA”) provide additional rights to California residents.

Subject to exceptions permitted by applicable laws and verification of your identity, if you live in California, you may exercise the following rights with respect to your Personal Information. Capitalized terms in this Section that are not defined elsewhere in this Policy have the definitions set forth in the CCPA.

Sharing Information

In the last 12 months we have not Sold your Personal Information to a third party for monetary compensation.

We may Share the following categories of Personal Information with third parties that provide us with targeted advertising or data analytics services.

·         Identifiers

·         Commercial Information

·         Internet or Other Electronic Network Activity

·         Non-Sensitive Geolocation Information

·         Inferences

You have the right to opt-out of the Sharing of your Personal Information and can do so by emailing us at investors@bmcinv.com or contacting us using the information in the “Contact Us” section below.

Sensitive Information

We do not use or disclose sensitive Personal Information for any purpose other than our business purposes, as specified under the CCPA.

Your Rights and Choices

The CCPA provides consumers with specific rights regarding their Personal Information, subject to certain exceptions. If you live in California, this section describes your CCPA rights and explains how to exercise those rights.

·         Right to Know. You have a right to request that we disclose certain information to you about our collection of your Personal Information over the last 12 months. Once we receive your request and confirm your identity, we will disclose to you as required under the CCPA:

o    The categories of Personal Information we collected about you;

o    The categories of sources for the Personal Information we collected about you;

o    Our business or commercial purpose for collecting, disclosing, sharing, or selling that Personal Information;

o    The categories of third parties with whom we share that Personal Information;

o    The specific pieces of Personal Information we collected about you;

o    The categories of Personal Information that we sold, shared, or disclosed for a business purpose; and

o    The categories of third parties to whom Personal Information about you was sold, shared or disclosed for a business purpose.

·         Right to Delete. Except in certain cases where the CCPA does not require us to do so or provides an exception, you have the right to request that BMC Investments delete any of your Personal Information that we collected from you and retain. Once we receive and verify your request, we will comply with such request (and direct our service providers and other applicable third parties to do the same) unless an exception applies or the CCPA does not require us to do so.

·         Right to Correct. You have the right to request that we correct inaccurate Personal Information that we collect about you. If we receive a verifiable request, we will consider it, taking into account the nature of the Personal Information and the purposes of the processing of the Personal Information. We may deny your request if we are unable to verify your identity, or if we determine that the contested Personal Information is more likely than not accurate based on the totality of the circumstances. We may request that you provide us with documentation that is relevant to your request. Please note, we may choose to delete the contested Personal Information as an alternative to correcting it if doing so would not negatively impact you or you consent to our deletion.

·         Right to Opt-Out of Sale or Sharing of Personal Information. You have the right to opt-out if we sell or share Personal Information with a third party.

Exercising Your Rights

In addition to any other options provided in this Privacy Policy, to exercise your rights described above, please submit a verifiable consumer request to us by: calling us at 303-996-2323, emailing investors@bmcinv.com, or mailing an inquiry to BMC Investments, 205 Detroit Street, Suite 400, Denver, Colorado 80206.

Who Can Make a Request

If you are a California resident, only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information. See the section titled "Using an Authorized Agent" below for more information. A parent or legal guardian may make a request on behalf of their child.

Verifying Your Request

In order to process your request to know, delete or correct, you must provide:

·         Information sufficient to allow us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.

·         A request with sufficient detail to allows us to properly understand, evaluate, and respond to it.

When we receive your request to exercise your rights under the CCPA, we will: (1) acknowledge receipt of your request; (2) try to match the information you provide in making the request with information we already maintain about you; (3) if required to verify your identity, we may ask you to provide additional information, including Personal Information; and (4) consider various factors when determining how to verify your identity, such as the sensitivity and value of the data, the risk of harm, the likelihood of fraud, etc.

Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to Personal Information associated with that specific account.

We will only use Personal Information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (an additional 45 days up to a total of 90 days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

For right to know requests, we will select a format to provide your Personal Information to you.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. If applicable, the response we provide will also explain the reasons we cannot comply with a request.

If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Using an Authorized Agent

You have a right to submit requests to exercise your rights under the CCPA through an authorized agent. If you choose to use an authorized agent, you must: (a) provide signed, written permission to that authorized agent to submit requests on your behalf; (b) verify your identity directly with us; and (c) directly confirm with us that you granted permission to the authorized agent to submit the request on your behalf. For clarity, you are required to verify the identity of both yourself and the authorized agent.

We may deny a request from an authorized agent if we do not have proof that they are authorized to act on your behalf.

Non-Discrimination

We will not discriminate against you for exercising any of your rights under the CCPA. Unless permitted by the CCPA, if you exercise your rights under the CCPA, we will not:

·         deny you goods or services;

·         charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;

·         provide you a different level or quality of goods or services; or

·         suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to the value of your Personal Information and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.

Honoring Opt-Out Signals

We process opt-out preference signals (“Signals”) when you visit our Site. This means that you can opt-out of the sale or sharing of Personal Information without having to contact us or otherwise submit a request to us. For us to process your opt-out, you must have a valid Signal in a format commonly used and recognized by us such as an HTTP header field.

If we receive or detect a Signal, we will treat the Signal as a valid request to opt-out of the sale or sharing of your Personal Information for that browser or device, and, if known, for you. We may display on our Site “Opt-Out Preference Signal Honored” when a browser, device or consumer using a Signal visits our Site, or display through a toggle or radio button that they have opted out of the sale or sharing of Personal Information associated with the applicable browser or device with third parties.

To set up a Signal, you can visit https://globalprivacycontrol.org/.

California Shine the Light

Under California Civil Code Section 1798.83, California residents have the right to obtain (a) a list of all third parties to whom the Company may have disclosed your Personal Information within the past year for direct marketing purposes; and (b) a description of the categories of Personal Information disclosed. Please contact us as set forth at the end of this Privacy Policy to receive this information.

9.      Contact Us

If you have questions regarding this or the use of Personal Information collected or used by BMC Investments, please contact us using the following information:

205 Detroit Street, Suite 400
Denver, Colorado 80206
investors@bmcinv.com