Effective Date: May 7, 2026

Oakdale Capital ("Oakdale," "we," "us," or "our") respects your privacy and is committed to protecting personal information you provide through our website at oakdale-capital.com (the "Website") or otherwise provide to us in connection with prospective or existing investor relationships. This Privacy Policy explains how we collect, use, disclose, retain, and protect personal information when you use the Website or otherwise interact with us. Where required by law, we will obtain your consent before collecting or using certain categories of personal information or before using certain tracking technologies.

1. Information We Collect

Information You Provide.

When you contact us, request information, sign up for updates, or submit an investment inquiry, we may collect: name, email, phone, mailing address, employer and title, investment-related background, and any other information you choose to provide.

Investor Verification Information.

If you express interest in a private investment offering, we may collect additional information to verify your status as an "accredited investor" under Rule 501(a) of Regulation D. This may include income statements, tax returns, brokerage and bank statements, net worth documentation, and certifications from licensed third parties, such as CPAs, attorneys, registered representatives, or registered investment advisers. Where feasible, Oakdale may permit prospective investors to provide a third-party accredited investor verification letter instead of providing underlying financial records directly to Oakdale. See Section 4 below for how this information is handled.

Automatically Collected Information.

When you visit the Website, we may automatically collect: IP address, browser type and version, device type, operating system, pages viewed, referring URL, time stamps, clickstream data, and similar usage information.

Cookies and Similar Technologies.

We may use cookies, pixel tags, and similar technologies for site functionality, analytics, performance measurement, and, where applicable, marketing. Specific tools we may use include Google Analytics, Meta Pixel, LinkedIn Insight Tag, and similar third-party services. You can manage cookies through your browser settings; some Website features may not work properly if cookies are disabled. Where required by applicable law, we will provide additional cookie notices, consent tools, or opt-out mechanisms.

Sensitive Information Submitted Through Forms.

We do not seek to collect sensitive personal information through general Website forms. Please do not submit Social Security numbers, account numbers, tax returns, bank statements, brokerage statements, or similar sensitive documents through general contact forms unless we specifically request them through a secure process.

2. How We Use Information

We use information to:

1. Respond to inquiries and communications;

2. Evaluate prospective investor relationships and verify accredited investor status;

3. Operate, maintain, secure, and improve the Website;

4. Send updates, newsletters, and marketing communications you have requested or that relate to existing relationships;

5. Detect and prevent fraud, unauthorized access, and other misuse; and

6. Comply with applicable law and respond to legal process.

3. How We Share Information

We do not sell personal information for monetary consideration. We may share information with:

1. Service providers who support Website operations, hosting, email delivery, analytics, customer relationship management, investor portals, and investor verification, under contractual obligations of confidentiality and limited use;

2. Professional advisors, including legal counsel, accountants, tax advisors, consultants, and auditors, on a need-to-know basis;

3. Regulatory authorities and law enforcement, where required by law, subpoena, court order, or other legal process;

4. Affiliates and business partners, including co-sponsors and joint venture partners, as necessary to evaluate or execute investment opportunities or administer investor relationships; and

5. Successors in connection with a merger, acquisition, financing, reorganization, or sale of assets, subject to confidentiality protections.

We require service providers to use personal information only for the services they provide to us and not for their own independent purposes, except as permitted by law.

4. Investor Verification and Sensitive Financial Information

Information collected to verify accredited investor status, including financial statements, tax returns, brokerage or bank statements, and third-party verification letters, is treated with heightened care. Such information is: (a) used solely for verification, suitability or relationship assessment where applicable, regulatory recordkeeping, and documentation of the investment relationship; (b) stored in access-restricted systems separate from general marketing data where reasonably practicable; (c) shared only with service providers and advisors who require it for the purposes described above; and (d) retained for the period required by applicable law and our recordkeeping obligations under the Securities Act of 1933, as amended, and related rules. We do not use accredited investor verification information for general marketing purposes.

5. Data Retention

We generally retain personal information for as long as reasonably necessary for the purposes described in this Privacy Policy, including to maintain business records, comply with legal and regulatory obligations, resolve disputes, and enforce agreements. Retention periods may vary depending on the nature of the information and our relationship with you. Investor verification, subscription, tax, and investment records may be retained for the period required under applicable securities, tax, and state law, and may be retained longer where necessary for legitimate business, legal, or regulatory purposes. Marketing data is retained until you opt out or until we determine it is no longer needed for the purposes described in this Privacy Policy.

6. Data Security and Breach Notification

We implement administrative, technical, and physical safeguards intended to protect personal information, including access controls, encryption in transit, vendor due diligence, and employee training. No system is completely secure, and we cannot guarantee absolute security. In the event of a security breach affecting your personal information, we will notify you and applicable regulators as required by the Illinois Personal Information Protection Act (815 ILCS 530/) and other applicable laws.

7. Marketing Communications

You may opt out of marketing emails at any time by using the unsubscribe link in any marketing email or by contacting us at investors@oakdale-capital.com. We will continue to send transactional and relationship-based communications, such as responses to your inquiries, investor updates if you are an existing investor, and tax or regulatory communications, regardless of marketing preferences. Our marketing practices are intended to comply with the CAN-SPAM Act of 2003.

8. Third-Party Websites

The Website may contain links to third-party websites and services. We are not responsible for the privacy practices or content of those sites. Review each site’s own privacy policy before providing personal information.

9. Your Privacy Rights

California Residents (CCPA/CPRA).

If you are a California resident, you may have the right to: (i) know what personal information we have collected, used, disclosed, sold, or shared; (ii) request deletion of your personal information; (iii) request correction of inaccurate personal information; (iv) opt out of the "sale" or "sharing" of personal information for cross-context behavioral advertising; and (v) limit our use and disclosure of sensitive personal information where applicable. We do not sell personal information for monetary consideration. Some analytics and advertising tools may involve the "sharing" of personal information for cross-context behavioral advertising under California law. California residents may opt out of such sharing by using the "Do Not Sell or Share My Personal Information" link in the Website footer, if available, or by contacting us at investors@oakdale-capital.com. Where required by applicable law, we will honor legally recognized browser-based opt-out signals, such as Global Privacy Control, as a request to opt out of sale or sharing. We will not discriminate against you for exercising these rights.

EU/UK/Swiss Residents (GDPR/UK GDPR).

If you are located in the European Economic Area, the United Kingdom, or Switzerland, you may have rights of access, rectification, erasure, restriction, portability, and objection under applicable data protection laws. Our legal basis for processing depends on the activity and may include your consent, performance of a contract, our legitimate interests in operating and growing our business, or compliance with legal obligations.

All Other Users.

You may request access to, correction of, or deletion of your personal information at any time by contacting investors@oakdale-capital.com. We will respond within the time required by applicable law.

Do Not Track.

The Website does not currently respond to "Do Not Track" browser signals.

10. Children’s Privacy

The Website is intended for adults age 18 and over. We do not knowingly collect personal information from children under 13 in violation of the Children’s Online Privacy Protection Act ("COPPA"). If you believe we have collected information from a child under 13, contact us immediately and we will delete it.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will post the revised policy on the Website with an updated effective date. For material changes, we will provide additional notice, such as an email to addresses we have on file or a Website banner, where required by law.

12. Contact Us

For questions about this Privacy Policy or to exercise any of your rights, contact:

Oakdale Capital
Attn: Privacy
1222 W Oakdale Avenue
Chicago, Illinois 60657
investors@oakdale-capital.com
312-620-7735