Privacy Policy

Effective Date: January 1, 2025
Last Updated: November 28, 2025

Voralto Capital, LLC is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard personal information when you interact with our websites, investor portals, due diligence data rooms, online tools, or any digital service that links to this Privacy Policy.

1. Information We Collect

We collect personal information in three ways: information you provide to us, information collected automatically, and information from third parties.

Information You Provide: Contact information (name, email, phone, address), investor and compliance information (accreditation status, financial suitability, tax information, identification documents, KYC/AML documentation), account information (login credentials, portal preferences), professional information (company, title, role), and communications (emails, messages, form submissions).

Information Collected Automatically: IP address, device type, browser type, operating system, pages visited, click behavior, time spent on pages, referring URLs. We use cookies, pixels, tags, and related technologies to maintain session security, improve functionality, analyze usage, and support marketing where permitted.

Information From Third Parties: We may receive personal information from service providers (KYC/AML platforms, custodians), investment onboarding platforms, referral partners, marketing and analytics providers, public databases, and background verification providers.

Sensitive Personal Information: We do not intentionally collect sensitive personal information unless necessary for compliance, such as for KYC/AML checks. This may include government-issued ID numbers, citizenship information, and certain financial records.

2. How We Use Personal Information

Provide and Manage Services: Respond to inquiries, evaluate investor eligibility, facilitate onboarding and verification, provide access to investor portals and documents, communicate regarding investments.

Compliance and Regulatory: Conduct identity verification, meet legal obligations under securities laws, conduct AML checks, support tax and reporting requirements.

Improve and Personalize: Enhance functionality of the Sites, analyze usage and performance, tailor content and communication.

Security and Fraud Prevention: Protect the Sites from malicious activity, detect and investigate suspicious behavior, maintain the integrity of investor accounts.

Marketing (Where Permitted): Deliver targeted or relevant information, measure marketing effectiveness. You may opt out of marketing communications at any time.

3. How We Share Personal Information

We do not sell personal information. We may share personal information with:

  • Service Providers: Hosting and security, KYC/AML and compliance processors, analytics tools, investment documentation platforms, email and communication tools
  • Affiliates and Investment Entities: If you inquire about or invest in a specific fund
  • Professional Advisors: Auditors, legal counsel, or compliance consultants
  • Regulatory or Government Authorities: Where required by law, including SEC, IRS, anti-money laundering agencies, court orders
  • Business Transfers: If Voralto undergoes a merger, acquisition, or restructuring

4. Your Privacy Rights

Depending on your state of residence, you may have rights including:

  • Right to know what information we collect
  • Right to access your personal data
  • Right to correct inaccurate information
  • Right to delete personal information (subject to legal exceptions)
  • Right to opt out of certain data processing activities
  • Right to restrict the use of sensitive information
  • Right to non-discrimination when exercising privacy rights

To exercise these rights, contact us using the details provided at the end of this Policy. We may need to verify your identity before fulfilling your request.

5. Children's Privacy

Our Sites are not directed to children under age 16. We do not knowingly collect personal information from children under 16. If we become aware that we have collected such information, we will delete it promptly.

6. Data Retention

We retain personal information only as long as necessary to provide services, fulfill legal, regulatory, and tax obligations, maintain business and investment records, and support security and fraud prevention. When data is no longer needed, it is securely deleted or anonymized.

7. Data Security

We use reasonable administrative, technical, and organizational safeguards to protect personal information. While we strive to protect your information, no system can guarantee absolute security.

8. Third-Party Links

Our Sites may contain links to third-party websites or tools. We are not responsible for the privacy or security practices of these third parties. You should review their policies before providing information.

9. International Visitors

Our Sites are intended for users located in the United States. If you visit from outside the U.S., you consent to the transfer and processing of your information in the United States.

10. Cookies and Tracking

We use cookies, analytics tools, and similar technologies to operate and improve our Sites. You can adjust cookie preferences through your browser settings. Some features may not function properly if cookies are disabled. A standalone Cookie Notice may provide further details.

11. Changes to This Policy

We may update this Privacy Policy periodically. The “Last Updated” date reflects the most recent changes. Your continued use of the Sites constitutes acceptance of the updated Policy.

12. Contact Us

If you have questions about this Privacy Policy or wish to exercise your privacy rights, please contact:

Voralto Capital Management — Privacy Office
Email: privacy@voralto.com