Privacy Policy

PRIVACY NOTICE

Last updated: March 13, 2025

Invite Capital Partners Co considers the protection of your privacy to be of paramount importance. This Privacy Statement (“Statement”) applies to visitors to Invite Capital Partners Co’s website, users, and current, former, or prospective clients. This Statement explains how we collect, use, share, and otherwise process personal information that you may provide when using our website located at investcapitalpartner.com (the “Website”) and our services (collectively, the “Services”), as well as the rights and choices you may have with respect to your information.

If you do not agree to the terms of this Statement, you must immediately discontinue use of the Services. We may update this Statement from time to time, and your continued use of the Services constitutes your express acceptance of the terms of the Statement then in effect.

Information Collection

We collect personal information that you provide to us, as well as personal information we obtain from business partners, social media platforms, other users, and other publicly available sources. The information we collect includes, but is not limited to, the following:

Information You Provide to Us

Personal information we collect about you through the Services or otherwise may include:

• Contact Information, such as your name, email address, and mailing address.
• Identification Data, such as Social Security numbers (where permitted), tax identification numbers, passport numbers, driver’s license or state identification numbers, and images or details of related identification documents (e.g., identification numbers, date of birth, country and date of issuance, and expiration date).
• Account Data, such as the email address and password you establish when creating an account with us.
• Financial Data, such as your stated income, economic or financial circumstances (including source of funds), financial institutions, financial account names and numbers, investor profiles, information related to your investment eligibility, and payment information.
• Transaction Data, such as purchases, sales, and account balances.
• Data About Other Individuals, such as the names, addresses, email addresses, and other contact details, dates of birth, Social Security numbers (where permitted), or other tax or national identification numbers (where applicable) of individuals representing your organization, underlying investors, beneficial owners, or controlling persons.
• Communications Data, such as your preferences for receiving communications regarding our activities and publications, and details about how you interact with our Website and communications.
• Feedback Data, such as information you provide when you contact us with questions, provide feedback, upload attachments, or otherwise communicate with us online (including on our social media pages).
• Other Information not specifically listed here, which we will use as described in this Statement or as otherwise disclosed at the time of collection.

Information from Other Sources

We may combine personal information we receive from you with personal information obtained from other sources, such as:

• Public sources, including social media platforms;
• Business partners, such as joint marketing partners, affiliates, and event co-sponsors.

Automatically Collected Information

We, our service providers, and third-party partners may automatically collect information about you, your computer or mobile device, and your activity on the Website and other online services, including:

• Device Data, such as your operating system type and version, manufacturer and model, browser type, screen resolution, IP address, referring website, and general location information (e.g., city, state, or geographic region).
• Online Activity Data, such as pages or screens viewed, time spent on pages or screens, navigation paths, interaction details, access times, and duration of visits.

Cookies

Invite Capital Partners Co uses cookies and similar technologies to automatically collect certain information described above. These technologies are designed to help improve the user experience. Each cookie is a small text file that a website downloads to a user’s device. Cookies we use contain information that identifies your computer and store data regarding your visits to the Website.

• Analytics/Performance Cookies enable us to understand how and when users visit our Website, their technical preferences, and to ensure proper site functionality. We use cookies set by Google Analytics (including utma, utmb, utmc, utmt, and utmz) to help improve our Website.
• Session Cookies allow the Website to remember a user’s navigation from page to page. These cookies expire when the user leaves the Website or closes the browser.
• Log Cookies are collected to optimize page load performance (sometimes referred to as Real User Monitoring or RUM). We use New Relic to collect these cookies during session tracking in end-user browsers.

Use of Information

We use your personal information for the purposes described below and as otherwise described in this Statement or at the time of collection:

Service Provision

• Provide, operate, and improve the Services;
• Create and maintain your user profile;
• Communicate with you regarding the Services, including announcements, updates, security alerts, and administrative messages;
• Communicate with client representatives and other relevant parties to provide Services;
• Enable Website security features;
• Understand your needs and interests and personalize your experience;
• Protect the security of the Website and our systems;
• Provide support and respond to inquiries and feedback.

Research and Development

We may use personal information for research and development purposes, including analyzing and improving our Services and business. We may create aggregated, de-identified, or anonymized data for legitimate business purposes.

Marketing

We may send marketing communications as permitted by law. You may opt out as described in the “Choices” section below.

Compliance and Operations

• Operate our business;
• Comply with applicable laws and legal processes;
• Protect rights, safety, and property;
• Audit compliance with policies and obligations;
• Enforce terms and conditions;
• Prevent fraud and unlawful activities.

We do not sell personal information. Except as permitted or required by law, or with your written consent, we do not disclose your personal information.

Contact Us

Consumers (including clients, prospective clients, third parties, and employees) may exercise the rights described above by contacting us at:

Invite Capital Partners Co
Compliance Department – Privacy Officer
Email: support@investcapitalpartner.com

Statutory category of personal information (“PI”) (Cal. Civ. Code § 1798.140)	PI we collect in this category (See Personal information we collect above for description)	Source of PI	Business/commercial purpose for collection	Categories of third parties to whom we “disclose” PI for a business purpose
Identifiers	• Contact data • Identity data • Account data • Data about others	• You • Other third-party sources	• Service delivery • Research & development • Marketing • Advertising • Compliance & operations	• Affiliates • Service providers • Advertising partners • Service-related third parties • Professional advisors • Authorities and others • Business transferees
California Customer Records (as defined in California Civil Code section 1798.80)	• Contact data • Identity data • Account data • Financial data • Transaction data • Data about others • Engagement data • Feedback data • Device data • Online activity data	• You • Other third-party sources	• Service delivery • Research & development • Marketing • Advertising • Compliance & operations	• Affiliates • Service providers • Advertising partners • Service-related third parties • Professional advisors • Authorities and others • Business transferees
Commercial Information	• Transaction data • Data about others • Engagement data • Feedback data • Online activity data	• You • Other third-party sources • Automatic collection	• Service delivery • Research & development • Marketing • Advertising • Compliance & operations	• Affiliates • Service providers • Advertising partners • Service-related third parties • Professional advisors • Authorities and others • Business transferees
Financial Information	• Financial data • Transaction data	• You • Other third-party sources	• Service delivery • Research & development • Marketing • Advertising • Compliance & operations	• Affiliates • Service providers • Service-related third parties • Professional advisors • Authorities and others • Business transferees
Online Identifiers	• Account data • Device data	• You • Other third-party sources • Automatic collection	• Service delivery • Research & development • Marketing • Advertising • Compliance & operations	• Affiliates • Service providers • Advertising partners • Service-related third parties • Professional advisors • Authorities and others • Business transferees
Internet or Network Information	• Transaction data • Engagement data • Device data • Online activity data	• Automatic collection	• Service delivery • Research & development • Marketing • Advertising • Compliance & operations	• Affiliates • Service providers • Advertising partners • Service-related third parties • Professional advisors • Authorities and others • Business transferees
Inferences	May be derived from your: • Contact data • Identity data • Account data • Financial data • Transaction data • Engagement data • Device data • Online activity data	N/A	• Service delivery • Research & development • Marketing • Advertising • Compliance & operations	• Affiliates • Service providers • Advertising partners • Service-related third parties • Professional advisors • Authorities and others • Business transferees
Protected Classification Characteristics	We do not intentionally collect this information but it may be revealed in identity data or other information we collect	N/A	N/A	N/A

Sensitive Personal Information

We do not use or disclose your sensitive personal information in any manner that would give rise to your right under the California Consumer Privacy Act (“CCPA”) to limit the use or disclosure of such sensitive personal information.

California Resident Privacy Rights

As a California resident, you have the rights described below. These rights are not absolute, and in certain circumstances, we may lawfully deny your request.

• Right to Know. You may request information regarding how we have collected, used, and shared your personal information during the preceding twelve (12) months. Much of this information is already provided above without the need for a request, including:
  • The categories of personal information we collect;
  • The specific pieces of personal information we have collected about you;
  • The categories of sources from which we collect personal information;
  • The business or commercial purposes for collecting and/or selling personal information;
  • The categories of third parties with whom we share personal information;
  • The categories of personal information sold or disclosed for a business purpose; and
  • The categories of third parties to whom personal information is sold or disclosed for a business purpose.
• Right of Access. You may request a copy of the personal information we maintain about you.
• Right to Deletion. You may request that we delete personal information we have collected about you.
• Right to Correction. You may request that we correct inaccurate personal information we have collected about you.
• No Sale of Personal Information. We do not sell your personal information. As described in this Privacy Statement, we use cookies and other tracking technologies to analyze website traffic. If you would like to learn how to opt out of our use of cookies and other tracking technologies, please refer to the “Cookies” and “Choices” sections of this Statement.
• Right to Non-Discrimination. You have the right to exercise the rights described above free from discrimination, as provided under the CCPA.

How to Submit a Request

To request access to or deletion of your personal information, please contact us at:

Email: support@investcapitalpartner.com

Verification; Authorized Agents

We may need to verify your identity before processing your request (including requests to know, access, appeal, correct, or delete personal information), and we reserve the right to confirm your state of residence. To verify your identity, we may require you to provide government-issued identification, a declaration signed under penalty of perjury, or other information permitted by law.

Under the CCPA, you may designate an authorized agent to submit a request on your behalf. However, we may require verification of the authorized agent’s identity and their authority to act on your behalf. We may request a copy of a valid power of attorney or other written authorization granted in accordance with applicable law. If you have not provided such authorization to your agent, we may require additional steps permitted by law to verify that the request is authorized, including: (i) providing written permission signed by you authorizing the agent to act on your behalf; (ii) providing information requested by us to verify your identity; and (iii) confirming directly with us that you have authorized the agent to submit the request.