Delta Rock® respects the privacy of visitors and investors who interact with our online services. This Privacy Policy explains how we collect, use, disclose, and protect information when you browse our public website and when you use any investor onboarding, subscription, account, or related online features we make available (collectively, the "Services").
1. Scope of This Policy
This Privacy Policy applies to information collected through the Services. It does not apply to information collected offline, through third-party websites or platforms we do not control, or through separate contractual relationships that may be governed by additional agreements, disclosures, or notices. If any supplemental privacy notice or agreement applies to a specific product, fund, or onboarding flow, that notice will apply in addition to this Policy.
2. Information We Collect
We collect information in three main ways: (a) information you provide, (b) information collected automatically when you use the Services, and (c) information we receive from third parties in connection with providing the Services and meeting legal and regulatory obligations.
A. Information you provide voluntarily (public website)
If you contact us through the website or otherwise submit information through the public-facing portions of the Services, we may collect information such as your name, email address, organization or affiliation, and the content of your message or inquiry. Providing this information is voluntary, and you may choose not to submit it; however, doing so may limit our ability to respond.
B. Information you provide for investor onboarding and account-related features
If you use investor onboarding, subscription, or account features, we may collect information necessary to evaluate eligibility, process subscriptions, administer investor accounts, and comply with applicable legal and regulatory requirements. Depending on the context, this may include contact information (such as name, email, phone number, and address); identity information (including date of birth and government-issued identifiers); taxpayer identification information (including Social Security number or other tax identification number); copies or images of identification documents (such as a driver's license or passport); entity formation and beneficial ownership information (if investing through an entity); subscription details, executed documents, and related records; and payment or funding information used to facilitate contributions and distributions (such as bank or wire details).
C. Information collected automatically (website and onboarding)
When you access or use the Services, we may automatically collect limited technical and usage information, such as IP address, browser type, operating system, device identifiers, general location inferred from IP address, pages or screens viewed, time spent, referring and exit pages, and log and security event data. This information helps us operate the Services, maintain security, troubleshoot issues, and understand how the Services are used.
D. Information from third parties
In connection with onboarding, compliance, security, and providing the Services, we may receive information from third parties such as identity verification providers, compliance and screening services, fraud prevention services, fund administrators, and other service partners involved in processing subscriptions or supporting investor account administration.
3. How We Use Information
We use information collected through the Services for legitimate business and operational purposes, including to provide, operate, maintain, and secure the Services; respond to inquiries and provide support; facilitate investor onboarding, subscription processing, investor communications, and account administration; verify identity and eligibility; perform know-your-customer ("KYC"), anti-money laundering ("AML"), sanctions, fraud, and similar compliance screening; monitor, investigate, and help prevent suspicious, unauthorized, or illegal activity; improve the performance, functionality, and user experience of the Services; and comply with legal, regulatory, and contractual obligations.
We may also use information to communicate with you about Delta Rock® and our products, services, offerings, and updates, including in ways that may be considered marketing or promotional communications where permitted. We do not use information in a manner that is inconsistent with this Policy, and we may aggregate or de-identify information so it can no longer reasonably be used to identify you; we may use such aggregated or de-identified information for analytics, security, and business purposes.
4. Cookies, Analytics, and Similar Technologies
We use cookies and similar technologies to enable essential site functionality, support security, and collect basic usage analytics. Cookies are small files stored on your device that help websites function properly and help us understand how visitors use the Services. Cookies do not provide access to personal files or other information stored on your device beyond what your browser makes available.
We use Google Analytics to help measure and understand how visitors interact with the Services, such as pages viewed, session duration, and general device and browser information. This information helps us improve performance and user experience. You can manage cookies through your browser settings and, depending on your browser and device, you may have additional controls to limit certain analytics collection. If you disable cookies, some features of the Services may not function as intended.
5. Information Sharing and Disclosure
We do not sell personal information for money. We may share information in the following circumstances:
Service providers and business partners
We may disclose information to vendors, contractors, and other service providers who assist us in operating, securing, developing, maintaining, and improving the Services and our business. This may include providers supporting identity verification, KYC/AML and sanctions screening, fraud detection, document processing and electronic signature workflows, investor account administration, customer support, analytics, software development, and related operational services. These providers are permitted to use information only for authorized purposes and are expected to protect it in accordance with applicable obligations.
Legal, regulatory, and safety purposes
We may disclose information when we believe it is necessary to comply with law, regulation, legal process, or governmental requests; to respond to lawful inquiries; to enforce our terms and agreements; and to protect the rights, property, or security of Delta Rock®, our investors, our users, or others.
Business transfers
If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, dissolution, or sale of some or all assets, information may be transferred in connection with that transaction, subject to customary confidentiality protections.
With your direction or consent
We may share information when you direct us to do so or when you otherwise provide consent.
6. Marketing and Communications Preferences
Where permitted, we may send communications about Delta Rock®, our offerings, and updates that may be considered marketing or promotional in nature. You may opt out of certain promotional communications by following the unsubscribe instructions included in those messages or by contacting us. Opting out of promotional communications will not affect non-promotional communications that are necessary to provide the Services, administer an investor relationship, complete transactions, or deliver notices that may be required by law or regulation.
7. Confidential, Proprietary, and Sensitive Information
Please do not submit confidential, proprietary, or sensitive information through the public website unless a mutual non-disclosure agreement is in place. Information submitted without such an agreement will not be treated as confidential.
Investor onboarding may require the submission of sensitive information (such as taxpayer identification numbers and identification documents) to support eligibility checks, compliance screening, and account administration. We use this information only for the purposes described in this Policy and apply safeguards designed to protect it.
8. Data Security
We maintain reasonable administrative, technical, and organizational measures designed to protect information collected through the Services. Despite these efforts, no method of transmission or storage is completely secure. Accordingly, we cannot guarantee absolute security.
9. Data Retention
We retain information only as long as reasonably necessary to fulfill the purposes described in this Policy, including maintaining the Services, resolving disputes, enforcing agreements, and meeting legal and regulatory obligations. Retention periods may vary depending on the type of information, the purpose for which it was collected, and applicable requirements (including recordkeeping obligations associated with investor onboarding and account administration).
10. International Visitors
The Services are operated from the United States. If you access the Services from outside the United States, you understand that your information may be processed and stored in the United States and in other jurisdictions where we or our service providers operate. Where required by applicable law, we will take steps designed to support lawful cross-border data transfers.
11. Your Choices and Rights
You may choose not to provide certain information; however, doing so may limit our ability to respond to inquiries or provide onboarding and account-related Services. You can manage cookies through your browser settings, and you may opt out of certain promotional communications as described above.
Depending on your state of residence and applicable law, you may have rights regarding personal information, which can include the right to request access, correction, deletion, or other rights recognized under applicable state privacy laws. We will take reasonable steps to verify requests before responding, and we may decline or limit requests where permitted or required by law (including where retention is necessary for compliance, security, or recordkeeping). See the Your Data page for how to submit a request.
12. Third-Party Links
The Services may contain links to third-party websites. We are not responsible for the privacy practices or content of those third-party sites, and we encourage you to review their privacy policies before providing information.
13. Children's Privacy
The Services are not directed to children under the age of 18, and we do not knowingly collect personal information from children.
14. Changes to This Policy
We may update this Privacy Policy from time to time. Any changes will be posted on this page with an updated effective date. Continued use of the Services after an update constitutes acceptance of the revised Policy.
15. Contact
Questions or requests regarding this Privacy Policy may be submitted through the website contact form or by email at [email protected].