Privacy Policy

1. Introduction

Aequitas, Inc. (“Company,” “we,” “us,” or “our”) respects your privacy and is committed to protecting the personal information you share with us. This Privacy Policy describes how we collect, use, disclose, and safeguard your information when you visit our website at aequitasengine.com, use our investor portal, or otherwise interact with our services.

2. Information We Collect

Personal Information

We may collect personally identifiable information that you voluntarily provide, including but not limited to:

• Full legal name
• Email address
• Organization or company name
• Investor type and accreditation status
• Phone number
• Mailing address
• Tax identification information (partial, last four digits only)
• Government-issued identification documents (for KYC/AML compliance)
• Financial information related to accredited investor verification

Automatically Collected Information

When you access our website, we may automatically collect certain information about your device and usage patterns, including IP address, browser type, operating system, access times, and pages viewed. This information is used for analytics and to improve our services.

3. How We Use Your Information

We use the information we collect for the following purposes:

• To process and respond to your inquiries and data room requests
• To verify your accredited investor status as required under SEC Regulation D, Rule 506(c)
• To conduct KYC (Know Your Customer) and AML (Anti-Money Laundering) screening as required by applicable law
• To provide you with fund documentation, performance reports, and account statements
• To communicate with you regarding your investment, including material updates and regulatory notices
• To maintain and improve our website, portal, and investor services
• To comply with legal obligations, regulatory requirements, and internal policies

4. Data Security

We implement industry-standard security measures to protect your personal information, including:

• AES-256 encryption for all personally identifiable information at rest
• TLS 1.3 encryption for all data in transit
• Social Security Numbers are never stored in full. Only the last four digits are retained alongside a one-way cryptographic hash
• Role-based access controls limiting data access to authorized personnel
• Regular security audits and monitoring

While we employ commercially reasonable safeguards, no method of electronic storage or transmission is 100% secure. We cannot guarantee absolute security of your information.

5. Information Sharing and Disclosure

We do not sell, trade, or rent your personal information. We may share your information only in the following circumstances:

• Service Providers: With third-party vendors who assist in operating our business (e.g., cloud infrastructure, identity verification services), subject to confidentiality agreements
• Legal Compliance: When required by law, regulation, subpoena, court order, or governmental authority
• Fund Administration: With fund administrators, auditors, and legal counsel as necessary for fund operations
• Regulatory Bodies: With the SEC, FINRA, or other regulatory authorities as required for compliance with securities laws

6. Data Retention

We retain your personal information for as long as necessary to fulfill the purposes outlined in this policy, comply with legal obligations, resolve disputes, and enforce our agreements. Investor records are retained for a minimum of five (5) years following the termination of the investment relationship, or longer as required by applicable law.

7. Your Rights

Depending on your jurisdiction, you may have the right to:

• Access the personal information we hold about you
• Request correction of inaccurate or incomplete information
• Request deletion of your personal information, subject to legal retention requirements
• Opt out of non-essential communications
• Withdraw consent where processing is based on consent

To exercise these rights, please contact us at aequitas@aequitasengine.com.

8. Cookies and Tracking

Our website may use essential cookies for site functionality and session management. We do not use third-party advertising cookies or tracking pixels. Analytics data, if collected, is aggregated and anonymized.

9. Third-Party Links

Our website may contain links to third-party websites. We are not responsible for the privacy practices or content of those sites. We encourage you to review the privacy policies of any third-party site you visit.

10. Children's Privacy

Our services are not directed to individuals under the age of 18. We do not knowingly collect personal information from minors.

11. 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 our services following any changes constitutes acceptance of the revised policy.

12. Contact Us

If you have questions about this Privacy Policy or our data practices, please contact us at: