Privacy Policy and Accessibility Statement

Privacy Policy

Effective: October 14, 2022
Last updated: April 3, 2023

Affinius Capital (“ “we” or “us”) has a firm commitment to privacy. The following discloses our information gathering and dissemination practices for this website: The Data Privacy Policy of Affinius Capital covers these issues in more detail.

This Privacy Policy describes our practices regarding information that could be used to identify you or that is associated with information that identifies you (“Personal Information” or “Personal Data”) when you use the Site or in connection with an actual or potential business relationship with us. This Privacy Policy concerns only the Site and does not concern any website to which the Site may link. We do not have control over the data practices of these third-party sites and those practices are governed by the sites’ own privacy policies. If you choose to visit these third-party sites, you should review their privacy policies to ensure that you understand and are comfortable with their practices concerning your Personal Information. Except as set forth in this Privacy Policy, Affinius Capital will not share, sell, or rent individual Personal Information with anyone without your advance permission or unless ordered by a court of law.

This Privacy Policy does not encompass our privacy practices with respect to any Nonpublic Personal Information we may collect from you as an investor in investment vehicles that we sponsor or manage, and that is not collected through this Site. We address these practices in separate notices to investors or potential investors.

The Types of Personal Information We Collect About You Through The Site

When you enter and browse the Site, we may collect two different types of information about you: information you provide to us, and information we collect automatically through technology.

Personal Information You Provide to Us

In order to obtain access to certain information or materials provided via the Site, you may have to provide Personal Information, including but not limited to your name, e-mail address, mailing address and phone number. You may also provide this information when you contact us with inquiries (for example, through the contact form on our Site). Additionally, we may collect and retain a record of all communications with you. This site gives users the option to remove their information from our database to stop future communications.  You can send requests to

Affinius Capital also works with third-party web site operators to provide services such as document sharing and portfolio management (“Portal Sites”). When you input Personal Information to one of Affinius Capital’s Portal Sites, you are providing that information to a third-party. Affinius Capital’s Portal Sites may utilize framing techniques to make it appear that the user is still on the Site when the user is actually on a Portal Site. For example, if you are on a page that has the look and feel of, but the URL listed in your browser is a different URL than, then any information you provide is being collected by this third-party and not governed by this Privacy Policy.

When you leave the Site and are transferred to a Portal Site, you may be notified that you are no longer on the Site. You should carefully review the privacy policy and terms of use for any Portal Site before using and providing Personal Information through a Portal Site. The operators of such Portal Sites may share the information you enter with Affinius Capital.

Personal Information We Collect Automatically Through Technology

We may collect information about you automatically using technology. For example, we may collect your Internet Protocol or IP address each time you request a page during a visit to the Site. (An IP address is often associated with the portal through which you enter the Internet.) At times, we may also use IP addresses to collect information regarding the frequency with which users browse various parts of the Site.

We collect information about your use of the Site through cookies (see the “Cookies and How We Use Them” section below).

The technical methods we use on the Site may involve the transmission of information either directly to us or to another party authorized by us to collect information on our behalf. We may also use these technical methods in HTML e-mails that we send our Site users to determine whether such users have opened those e-mails and/or clicked on links in those e-mails. We may collect the information from use of these technical methods in a form that is personally identifiable.

During some visits we may use software tools such as JavaScript to measure and collect session information, including page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse overs), and methods used to browse away from the page. We may use this information to measure Site activity, to develop ideas for improving our websites and for any other purpose to the extent permitted by applicable law.

Other examples of data we may automatically collect include:

  • The kind of browser or computer you use.
  • State or country from which you accessed the Site.
  • Date and time of your visit.
  • Name of your Internet service provider.
  • Web page you linked to our Site from.
  • Pages you viewed on the Site.

This information is collected to help us administer and operate the Site, better understand how users interact with and access the Site, and understand the types of users access the Site.

Cookies and How We Use Them

This website stores cookies on your computer with the help of HubSpot. These cookies are used to collect information about how you interact with our website and allow us to remember you. We use this information in order to improve and customize your browsing experience and for analytics and metrics about our website visitors. Cookies are small text files that may be placed on your browser when you visit our Site. In particular, the Site uses Google Analytics to track and analyze the traffic patterns on the Site, such as the frequency with which our users visit various parts of the Site. This includes compiling statistical information concerning, among other things, the frequency of your use of our Site, the pages visited, and the length of each visit, as well as information about your computer, operating system, internet service provider, IP address browser, language, and country. The information generated by the Google Analytics about your use of the Site (including your IP address) will be transmitted to and stored by Google, Inc. in the United States. You can prevent your data from being collected by Google Analytics on our Site by downloading and installing the Google Analytics Opt-out Browser Add-on for your current web browser. For more information on Google Analytics privacy practices, read here and, for information on Google Analytics cookies expiration, read here.

The Site also uses a session cookie to maintain a user session throughout the user’s visit to the Site. The associated session automatically expires after you leave the Site. Because this cookie is essential for using and navigating the Site, you cannot refuse it. Moreover, we use a cookie to record your agreement to our use of cookies on our Site.

By choosing to use the Site after having been notified of our use of analytics cookies in the ways described in this Privacy Policy, and, in applicable jurisdictions, through notice and unambiguous acknowledgement of your consent, you agree to such use.

Using the settings of your Internet browser, you may be able to choose to have your computer warn you each time a cookie is being sent, or to turn off all cookies. Consult your browser help menu to learn more about your options. If you disable cookies, you may not have access to many features that make your browsing of our Site smoother, and some of our services may not function properly. For more information on cookies and deletion of cookies, please visit:

Other Types of Personal Information We Collect About You

We may collect Personal Information from you in connection with an actual or potential business relationship with us (for example, if you are a supplier). The data we collect includes information that you voluntarily give to us, such as your contact details. We will use this information to develop a business relationship and in a manner consistent with the purpose you gave the information for.

How We Use Your Personal Information

Personal Information. We use Personal Information we collect about you when you visit and browse the Site as part of our normal business operations, and to send you communications either about your interactions with us or about features of the Site, including any future changes to this Privacy Policy. We may use your Personal Information for marketing, research and other business purposes (with your consent if required by the applicable law), and we may associate your Personal Information with other information we collect about you, such as details about your usage patterns and interests.

We may also use the information you provide to improve the Site or our services, to customize your experience on Site, to serve you specific content, or for other business purposes.

Non-personally identifiable information. We may use non-personally identifiable information that does not personally identify you, including anonymous information and aggregate data, in order to understand better how our visitors use the Site, research our visitors’ demographics, interests, and behavior, improve the Site, provide visitors with customized services and information, and for other similar purposes. We may share this information with others for information or promotional purposes, and may use non-personally identifiable information in any manner permitted by law. When any non-personally identifiable information is combined with other information that identifies you, it will be treated as Personal Information in accordance with this Privacy Policy.

If you are an individual in the European Union (“EU”), please see the “EU Users” section below for information on the legal bases we rely on to process your Personal Data and your rights in relation to your data.

Sharing With Third Parties

Affinius Capital may share your Personal Information with third-party service providers to facilitate our services or platform functions on our behalf, in particular providers of hosting, cloud services and other information technology services providers; email communication software providers; web analytics services (for more details on the third parties that place cookies through the Site, please see the “Cookies and How We Use Them” section above). These companies and individuals may have access to your Personal Information as needed to perform their functions.

We may also share your Personal Information, as well as certain aggregated demographic information that does not identify you personally, with our business partners or affiliates in order to provide services and offerings to you.

We will also share Personal Information:

  • When we believe that such disclosures are required by law, regulation, legal process, subpoena, document request or governmental or legal request;
  • To enforce our Terms of Use, to cooperate with law enforcement, to protect your or our safety or security, including the safety and security of property that belongs to you or Affinius Capital, or to protect the safety and security of our websites, databases or third parties, including the safety and security of tangible or intangible property that belongs to us or to third parties;
  • To protect Affinius Capital against liability; and
  • In the event of a transaction or proposed transaction involving the transfer of substantially all of the assets of Affinius Capital or one or more of its businesses to another entity, whether an affiliate or a third party, in which case user information may be shared in the diligence process or to otherwise facilitate the transaction, and with individuals assisting in the transaction; Personal Information may also be one of the transferred assets.
Protection of Information

Affinius Capital uses reasonable technical, administrative and physical methods to maintain the integrity and security of our databases, including firewalls. Please be aware, however, that there is no absolute guarantee of security on the Internet. You use our Site and send us information at your own risk.

Your California Privacy Rights

California Consumer Privacy Act (CCPA)

Note that nonpublic personal information provided by investors is not subject to the CCPA, and will be addressed in separate notices to investors or potential investors.  However, some Personal Information collected by Affinius Capital may be subject to the provisions of the CCPA or other state privacy laws.

The CCPA and other state consumer privacy laws, if applicable, may provide residents with the following rights with respect to your personal information:

  • Right to know the categories of Personal Information we have collected about you;
  • Right to know the specific information we have collected about you;
  • Right to correct inaccurate information that we maintain about you;
  • Right to request that we delete any information we have collected about you in accordance with applicable law; and
  • Right to opt-out of the sale of any personal information we have collected about you.

To submit a request pursuant to any of these rights, please contact at:

  • Phone: 800 531 8182
  • E-mail:
  • Visitor address: 9830 Colonnade Boulevard, Suite 600; San Antonio, TX 78230

Please be sure to provide your full name and mailing address so that we can fulfill your request. When you exercise these rights and submit a request to us, we may verify your identity by asking for certain information. The rights request form link outlines the verification process. You will not receive discriminatory treatment for the exercise of these privacy rights.

You have the right to appeal any decision or action that we take related to the above-described privacy rights. If you believe that Affinius Capital has failed to take appropriate action in response to your privacy rights request or you believe that we have denied your request improperly, you may appeal by contacting us as described below.

Data Retention

We may retain your Personal Information for as long as necessary to fulfill the purpose for which it was collected or to comply with legal or regulatory requirements or as otherwise disclosed to you.

“Shine the Light” Law

California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the Third Parties to whom we have disclosed their Personal Information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of Personal Information disclosed to those parties. Affinius Capital does not share your Personal Information with third parties for their direct marketing purposes.

How We Respond to “Do Not Track” Signals

Our Site currently does not respond to “Do Not Track” (DNT) signals and operates as described in this Privacy Policy whether or not a DNT signal is received. If we do so in the future, we will describe how we do so in this Privacy Policy.


Affinius Capital services and the Site are not directed to children and we do not knowingly collect Personal Information from children under the age of 13. If you have reason to believe that a child under the age of 13 has provided Personal Information to Affinius Capital through the Site, please contact us and we will endeavor to delete that information from our databases.

EU Users

Scope. This section applies if you are an individual in the EU (for these purposes, reference to the EU also includes the European Economic Area countries of Iceland, Liechtenstein and Norway and, to the extent applicable, Switzerland).

Data Controller. Affinius Capital is the data controller for the processing of your Personal Data. To find out our contact details, please see the “Contact Us” section below, which also provides the contact details of our representative in the EU for purposes of the General Data Protection Regulation (GDPR).

Legal Bases for the Processing. We use Personal Data we collect through our Site as necessary for certain legitimate business interests, described below:

  • To respond to your inquiries, comments, feedback or questions;
  • To send administrative information to you, for example, information regarding the Site, and changes to our terms, conditions, and policies;
  • To analyze how you interact with our Site through the use of cookies and other technical methods, described above, and provide, maintain and improve the content and functionality of the Site (please see the “Personal Information We Collect Automatically Through Technology” section above);
  • To prevent fraud, criminal activity, or misuses of our Site, block prohibited reseller traffic, and to ensure the security of our IT systems, architecture and networks; and
  • To comply with legal obligations and legal process and to protect our rights, privacy, safety or property, and/or that of our affiliates, you or other third parties.

We use Personal Data we collect in connection with an actual or potential business relationship with you as necessary for our legitimate interest in developing a relationship with you. If we entered into a contract with you for the provision of services, we will use Personal Data collected from or about you as necessary to perform our contract with you and to pursue our legitimate interests in complying with legal obligations and legal process and protecting our rights, privacy, safety or property, and/or that of our affiliates, you or other third parties.

As used in this section, “legitimate interests” means our interests in conducting our business and developing a business relationship with you or your company. This Privacy Policy describes when we process your Personal Data for our legitimate interests, what these interests are and your rights. We will not use your Personal Data for activities where the impact on you overrides our interests, unless we have your consent or those activities are otherwise required or permitted by law.

Your Rights. Subject to applicable EU law, you have the following rights in relation to your Personal Data:

  • Right of access: If you ask us, we will confirm whether we are processing your Personal Data and, if so, provide you with a copy of that Personal Data along with certain other details. If you require additional copies, we may need to charge a reasonable fee.
  • Right to rectification: If your Personal Data is inaccurate or incomplete, you are entitled to ask that we correct or complete it.
  • Right to erasure: You may ask us to delete or remove your Personal Data, such as where you withdraw your consent.
  • Right to restrict processing: You may ask us to restrict or ‘block’ the processing of your Personal Data in certain circumstances, such as where you contest the accuracy of the data or object to us processing it (please read below for information on your right to object). We will tell you before we lift any restriction on processing.
  • Right to data portability: You have the right to obtain your Personal Data from us that you consented to give us or that was provided to us as necessary in connection with our contract with you, and that is processed by automated means. We will give you your Personal Data in a structured, commonly used and machine-readable format. You may reuse it elsewhere
  • Right to object: You may ask us at any time to stop processing your Personal Data, and we will do so:
    • If we are relying on a legitimate interest to process your Personal Data — unless we demonstrate compelling legitimate grounds for the processing or the processing is necessary for the establishment, exercise or defense of legal claims.
  • Right to withdraw consent: If we rely on your consent to process your Personal Data, you have the right to withdraw that consent at any time. Withdrawal of consent will not affect any processing of your data before we received notice that you wished to withdraw consent.
  • Right to lodge a complaint with the data protection authority: If you have a concern about our privacy practices, including the way we handled your Personal Data, you can report it to the data protection authority that is authorized to hear those concerns.

Please see the “Contact Us” section below for information on how to exercise your rights.

Data Transfers. Affinius Capital is based in the United States and we transfer your Personal Data to the United States as necessary for the purposes described in this Privacy Policy. The United States may have data protection laws less stringent than or otherwise different from the laws in effect in the country in which you are located. We take steps to ensure that your Personal Data receives an adequate level of security protection where it is processed and your rights continue to be protected. By visiting the Site and interacting with Affinius Capital, you consent to the transfer and processing of your Personal Data in the United States or other countries. For more information, please contact us as described below.

Data Retention. We will keep your Personal Data for as long as reasonably necessary for the purposes described in this Privacy Policy, while we have a legitimate business need to do so, or as required by law (e.g. for tax, legal, accounting or other purposes), whichever is the longer.

If you have elected to receive marketing communications from us, we retain information about your marketing preferences until you opt out of receiving these communications and in accordance with our policies.

To determine the appropriate retention period for your Personal Data, we will consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we use your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements. In some circumstances we may anonymize your Personal Data so that it can no longer be associated with you, in which case it is no longer Personal Data.

Contact Us

If you are an individual in the EU, you can also contact us at gdprinforequest@affinius   Affinius Capital Europe Holdco, B.V., who has been appointed as Affinius Capital representative in the EU pursuant to Article 27 of the General Data Protection Regulation on matters related to the processing of Personal Data that take place in the EU.

Information Sharing for Marketing Purposes

Federal law gives you the right to limit information sharing between affiliated entities for marketing purposes. You may limit our affiliates from marketing products or services to you based on your personal information that we collect and share with them. This information includes your date of birth, email and physical addresses, bank account and other account information.  To limit information sharing for marketing purposes, please contact us at Your choice to limit marketing offers from our affiliates will remain in effect until you tell us to make a change.

Accessibility Statement

Affinius Capital is committed to ensuring digital accessibility for people with disabilities. We are continually improving the user experience for everyone and applying the relevant accessibility standards.

Conformance status

The Web Content Accessibility Guidelines (WCAG) defines requirements for designers and developers to improve accessibility for people with disabilities. It defines three levels of conformance: Level A, Level AA, and Level AAA. Affinius Capital is conformant with WCAG 2.1 level AA.

Letter of Accessibility


We welcome your feedback on the accessibility of Affinius Capital. Please let us know if you encounter accessibility barriers on Affinius Capital: