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Privacy Policy

Last updated: April 8, 2026

1. Information we collect

  • Identity: legal name, email address
  • Accreditation: status, verification date, and reference ID from our third-party verifier (TrustGate)
  • Financial: capital invested, share counts, valuations
  • Documents: subscription agreements and other deal documents you sign or we deliver to you
  • Usage: log data including IP address, browser, and pages visited (used solely for security and audit)

2. How we use information

We use your information solely to provide investor reporting, comply with securities and tax law, prevent fraud, and communicate with you about your investments. We do not sell or rent your information to third parties.

3. Service providers

We share information only with the following service providers strictly as necessary to operate the portal: Vercel (hosting), Neon (database), WorkOS (authentication), TrustGate (accreditation verification), and any third-party fund administrator or tax preparer engaged by the GP. Each provider is contractually bound to handle your information confidentially.

4. Data security

We use industry-standard measures including TLS encryption in transit, encryption at rest, and per-investor access controls. Every write to investor positions and every document download is logged for audit.

5. Data retention

We retain investor and transaction records for at least seven years consistent with SEC and IRS retention requirements, or longer if required by applicable law.

6. Your rights

Depending on your state of residence, you may have rights to access, correct, port, or delete personal information. To exercise these rights, contact chris.diyanni@gmail.com. Note that some information must be retained for regulatory compliance and cannot be deleted on request.

7. Cookies

We use only essential cookies required for authentication and session management. We do not use advertising or analytics cookies in the investor portal.

8. Children

The Site is not directed to children under 18, and we do not knowingly collect information from anyone under 18.

9. Changes

We may update this policy from time to time. Material changes will be communicated by email to active investors.

10. Contact

Privacy questions: chris.diyanni@gmail.com.

    Privacy Policy — Breakout Syndicate