Effective 23 September 2026 · Last updated 23 September 2026
This policy explains what personal information mOrganic Holdings, LLC collects, why we collect it, who we share it with, and what you can ask us to do about it. We have tried to write it in plain language rather than the usual fog.
It applies to morganic.us, to our email communications, and to information you give us in the course of a business or investment conversation. In this policy, “mOrganic”, “we” and “us” mean mOrganic Holdings, LLC, a Wyoming limited liability company, and its subsidiaries and series entities.
1 · What we collect
Information you give us
- Contact details — name, email address, postal address, telephone number, and the organization you represent.
- Subscription preferences — which of our communications you have asked to receive.
- Investor questionnaire responses — if you complete an accreditation questionnaire, the categories you indicate under Rule 501(a) of Regulation D, your state or country of residence, any investing entity you name, and the professional adviser you nominate to confirm your status.
- Correspondence — the content of emails, form submissions and messages you send us.
Information collected automatically
- Technical data — IP address, browser type and version, device type, operating system, referring page, and the pages you visit on our site, together with the dates and times of those visits.
- Email engagement — whether a message we sent you was delivered, opened, or had a link clicked. This is standard email measurement and is how we know a sequence is working. You can defeat open tracking by blocking images in your email client.
- Cookies and similar technologies — see section 6.
Information from third parties
- Verification confirmations — where a certified public accountant, attorney, registered broker-dealer or registered investment adviser confirms your accredited investor status to us, we receive and retain that confirmation.
- Business sources — publicly available professional information, and details passed to us by a mutual contact who introduced us.
2 · Why we use it
| Purpose | What that means in practice |
|---|---|
| Communicating with you | Answering your questions, sending the updates you subscribed to, and running email sequences you have not opted out of. |
| Securities compliance | Verifying accredited investor status under Rule 506(c), maintaining the records that support a Regulation D exemption, and making filings such as Form D and state notice filings. |
| Offering administration | Evaluating and processing subscriptions, and administering an investment if you make one. |
| Operating our business | Running the website, measuring how our communications perform, improving what we publish, and keeping ordinary business records. |
| Security and legal obligations | Preventing fraud and abuse, enforcing our terms, and complying with law, subpoenas and regulatory requests. |
Where the EU or UK General Data Protection Regulation applies to you, our legal bases are: your consent (marketing email, which you may withdraw at any time); the performance of a contract or steps taken at your request before entering one; our legitimate interests in operating and promoting the business, balanced against your rights; and compliance with a legal obligation.
3 · Who we share it with
We do not sell your personal information, and we do not rent or trade it. We share it only as follows.
- Service providers who work on our behalf under contract — email delivery, website hosting, customer relationship management, analytics, cloud storage and document signature. They may use your information only to provide the service to us.
- Professional advisers — our attorneys, accountants, auditors and insurers, where they need it to advise us.
- Accreditation verifiers — the professional you nominate, or a third-party verification service, for the sole purpose of confirming your status.
- Regulators and law enforcement — where we are required to disclose by law, regulation, subpoena, court order or a lawful regulatory request.
- A successor — in connection with a merger, acquisition, financing or sale of assets, subject to this policy continuing to apply.
4 · How long we keep it
We keep personal information for as long as we need it for the purpose we collected it, and then for as long as the law requires.
- Marketing contact details — until you unsubscribe, and then on a suppression list indefinitely, because that is the only way to make sure we do not email you again.
- Accreditation and offering records — for the life of the relevant offering or investment and for the applicable statute of limitations thereafter. Securities exemptions are defended on their records, so we retain them deliberately rather than by accident.
- Correspondence and ordinary business records — in line with our normal retention practice.
5 · Security
We use administrative, technical and physical safeguards appropriate to the sensitivity of the information, including encryption in transit, access controls limiting who can see offering records, and vendors selected in part for their own security posture.
No method of transmission or storage is completely secure, and we cannot guarantee absolute security. Please do not send sensitive financial or identification documents to us by ordinary email; ask us for a secure channel instead.
6 · Cookies and analytics
We use cookies and similar technologies to keep the site working, to remember your preferences, and to understand how the site is used in aggregate. You can refuse or delete cookies through your browser settings; parts of the site may not work as well if you do.
Our email messages may contain a small tracking pixel and links that record clicks, which is how we measure whether a communication was useful. Blocking images in your email client prevents open tracking.
We honour Global Privacy Control signals where our systems receive them.
7 · Email, and how to stop it
Every commercial email we send carries a working unsubscribe link and our postal address, as the CAN-SPAM Act requires. Unsubscribing takes effect immediately and in no case later than ten business days.
If you hold securities issued by mOrganic or one of its entities, we are required to continue sending you communications about that investment — statements, tax documents and notices your subscription agreement obliges us to deliver. Those are not marketing and unsubscribing does not stop them.
8 · Your rights
If you are in California
Under the California Consumer Privacy Act as amended by the CPRA, you may ask us to tell you what personal information we have collected about you, the sources, the purposes and the categories of recipients; to provide a copy of it; to correct it; and to delete it. You may also opt out of any “sale” or “sharing” of personal information — though as stated above, we do not sell or share it in that sense. We will not discriminate against you for exercising these rights. You may use an authorised agent.
If you are in the EU, the UK, or another region with comparable law
You may request access to your personal data, correction, erasure, restriction of processing, portability, and you may object to processing based on our legitimate interests. Where we rely on consent, you may withdraw it at any time without affecting the lawfulness of processing before withdrawal. You may also lodge a complaint with your supervisory authority.
Everyone
Whatever your location, you may ask us to correct information that is wrong, to stop emailing you, or to tell you what we hold. Write to the address in section 12 and we will respond within the time the applicable law allows — generally 45 days in California and one month under the GDPR. We may need to verify your identity before acting on a request.
9 · International transfers
We are based in the United States and our service providers are principally in the United States. If you are outside the United States, your information will be transferred to and processed there, where data protection law may differ from your own. Where required, we rely on appropriate safeguards such as the European Commission’s standard contractual clauses.
10 · Children
This site and our communications are directed to adults conducting business. We do not knowingly collect personal information from anyone under 18. If you believe a minor has given us information, write to us and we will delete it.
11 · Changes to this policy
We may update this policy. When we do, we will change the “last updated” date at the top, and where the change is material we will give notice by email or a notice on the site before it takes effect.
12 · How to reach us
Questions, requests and complaints about privacy go to ceo@morganic.ag, or by post to:
mOrganic Holdings, LLC
Attn: Privacy
30 N Gould St, Ste R
Sheridan, WY 82801
United States