PYTHIA CAPITAL

Privacy Policy — Professional Services | Effective March 2026

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Our Commitment to Privacy

At Pythia Capital, LLC ("Pythia Capital," "we," "our," or "us"), privacy is not a compliance checkbox — it is a core design principle aligned with our Living Systems Investing (LSI) framework. We have intentionally built our technology stack around privacy-first, open-source, and sovereignty-respecting tools.

This Privacy Policy applies to all websites and services across pythiacapital.io and its subdomains, including edge.pythiacapital.io, garden.pythiacapital.io, vault.pythiacapital.io, and newsletter.pythiacapital.io, as well as The Edge of Chaos Collective and The Pythia Scrolls services.

Our Privacy-First Technology Stack

We believe you deserve to know exactly where your data lives and how it is protected. Our infrastructure is built on:

Information We Collect

We collect only what is necessary to provide our services:

Personal Information You Provide:

Information Collected Automatically:

We do not use advertising networks, behavioral tracking pixels, or sell data to third parties. Ever.

Lawful Basis for Processing (GDPR Article 6)

For subscribers and members who are EU residents, we process your personal data under the following lawful bases:

How We Use Your Information

Data Retention Schedule

We retain your data only as long as necessary for the purpose it was collected, subject to legal obligations:

Community Content and Architecture

The Edge of Chaos Collective community spaces are designed with data governance in mind:

Data Storage and Security

Member data and private research materials are stored in our self-hosted Nextcloud instance on Hetzner servers in Finland (EU), subject to EU data protection standards. Hetzner is a German company operating under EU jurisdiction and is not subject to the US CLOUD Act.

We implement industry-standard security measures including encrypted connections (HTTPS/TLS), access controls, and regular security reviews.

Third-Party Service Providers

We share limited information with the following service providers solely to deliver our services:

We do not sell, trade, or rent your personal information to any other third party.

Accredited Investor Information

For The Pythia Scrolls (Hub & Spoke tier), we are required to verify accredited investor status as defined under Rule 501 of the Securities Act of 1933, as amended. Information provided for this purpose is used solely for verification and regulatory compliance and is stored securely in our Nextcloud vault.

Your Rights

You have the right to:

To exercise any of these rights, contact us at team@pythiacapital.io. We will respond within 30 days.

EU Data Subjects — Additional Rights

If you are located in the European Union or EEA, you have additional rights under the GDPR, including the right to restriction of processing, data portability, and the right to lodge a complaint with your local supervisory authority.

Pythia Capital stores primary member data on Hetzner servers in Finland (EU), which significantly reduces cross-border transfer concerns. Where data is processed by US-based services (Stripe, Buttondown), those services maintain GDPR-compliant Data Processing Agreements.

As a small US-based operator serving EU subscribers, Pythia Capital is in the process of appointing an EU representative under GDPR Article 27. Inquiries: team@pythiacapital.io.

Cookies

Our static sites use Cloudflare's strictly necessary security cookies only — no advertising cookies, no third-party tracking. No cookie consent banner is required for these sites.

Children

Our services are not directed at children under 13. We do not knowingly collect information from children under 13.

Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be communicated to active subscribers and members. The current version is always available at edge.pythiacapital.io.

Contact

Questions about this Privacy Policy? Contact us at:
team@pythiacapital.io
Lynn Marie DePippo | Founder & CEO, Pythia Capital
edge.pythiacapital.io

Pythia Capital, LLC | Commonwealth of Massachusetts | March 2026

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