Wardroom Partners LLC

Privacy Policy

Effective Date: January 1. 2025 Last Updated: February 1, 2026

1. Introduction

Wardroom Partners LLC (“Wardroom Partners,” “we,” “us,” or “our”) is an investment adviser registered with the U.S. Securities and Exchange Commission. We are committed to protecting the privacy and security of the nonpublic personal information of our clients and prospective clients, and to complying with applicable federal and state privacy laws, including Regulation S-P under the Investment Advisers Act of 1940. This Privacy Policy explains what information we collect, how we use and share it, and the choices available to you. This Policy applies to our clients, prospective clients, and visitors to our website located at www.wardroom-partners.com.

2. Information We Collect

We may collect the following categories of nonpublic personal information (“NPI”) about you:

• Information you provide to us directly, such as your name, address, date of birth, Social Security number or taxpayer ID, employment information, income, net worth, investment objectives, and financial account information, typically provided on account applications, financial planning questionnaires, or in the course of our advisory relationship.
• Information about your transactions with us or others, such as account balances, positions, transaction history, and account activity.
• Information we receive from custodians, broker-dealers, other financial institutions, or consumer reporting agencies in connection with providing services to you.
• Information collected automatically through our website, such as IP address, browser type, device information, pages visited, and referring URLs, typically collected via cookies or similar technologies (see Section 8 below).
• Information you submit through website contact forms, account portal registration, or scheduling tools.

3. How We Use Your Information

We use NPI to:

• Provide, administer, and manage the investment advisory services you have engaged us to perform;
• Open, maintain, and service your account(s), including processing transactions and providing account statements and performance reports;
• Communicate with you regarding your account, our services, or regulatory matters;
• Comply with legal, regulatory, tax, and reporting obligations, including recordkeeping requirements under the Investment Advisers Act;
• Detect, investigate, and prevent fraud, unauthorized access, and other illegal activity; and
• Improve and maintain our website and internal operations.

We do not use your NPI for any purpose other than as described in this Policy or as otherwise permitted by law without your consent.

4. Information We Share and With Whom

We may share NPI with the following categories of third parties as necessary to provide our services:

• Custodians, broker-dealers, and clearing firms that hold or execute transactions in your account;
• Service providers who perform functions on our behalf, such as portfolio management and reporting software providers, customer relationship management (CRM) platforms, document management and e-signature providers, and IT/cybersecurity vendors;
• Our compliance consultants, auditors, and legal counsel;
• Regulatory authorities, self-regulatory organizations, or others as required by law, subpoena, or regulatory request; and
• Successor firms in connection with a merger, acquisition, or sale of all or part of our business, subject to confidentiality protections.

We do not sell your NPI to third parties. We do not disclose NPI to nonaffiliated third parties for their own independent marketing purposes.

5. Your Right to Opt Out

If we ever intend to share your NPI with a nonaffiliated third party in a manner that triggers an opt-out right under Regulation S-P, we will provide you with notice and a reasonable opportunity to opt out before such sharing occurs. As described above, our current practice is not to share NPI for nonaffiliated third-party marketing purposes. If this changes, we will update this Policy and provide any legally required notice.

6. How We Protect Your Information

We maintain administrative, technical, and physical safeguards reasonably designed to protect your NPI from unauthorized access, use, or disclosure, consistent with our obligations under Regulation S-P's Safeguards Rule and Identity Theft Red Flags Rule (Regulation S-ID), as applicable. These safeguards include:

• Restricting access to NPI to personnel who need it to provide services to you;
• Use of encryption for data transmitted through our website and client portal;
• Multi-factor authentication and access controls for systems containing client data;
• Ongoing employee training regarding data privacy and security obligations; and
• A written incident response program addressing detection of, and response to, unauthorized access to client information, including applicable notification procedures.

No system of safeguards can guarantee complete security, and we cannot ensure or warrant the security of any information you transmit to us over the internet.

7. Data Retention

We retain NPI for as long as necessary to provide services to you, and thereafter for the period required by applicable recordkeeping obligations under the Investment Advisers Act of 1940 and other applicable law, or as otherwise necessary for legitimate business or legal purposes.

8. Cookies, Analytics, and Website Technologies

Our website may use cookies and similar technologies to operate the site, remember preferences, and understand how visitors use our website, including through third-party analytics providers (such as [Google Analytics/other tool]). You can control cookies through your browser settings [and, where applicable, through a cookie preference tool available at the bottom of our website]. Disabling certain cookies may affect the functionality of our website.

9. Children's Information

Our services and website are not directed to individuals under the age of 18, and we do not knowingly collect NPI from children.

10. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. We will post the revised Policy on our website with an updated “Last Updated” date. For material changes affecting how we use or share your NPI, we will provide notice as required by applicable law.

11. Contact Us

If you have questions about this Privacy Policy or our privacy practices, or wish to exercise any rights described above, please contact us at: