Privacy Policy

Darrery Capital, LLC

PRIVACY NOTICE

Last Revised: May 14, 2026

INTRODUCTION

Darrery Capital, LLC and its affiliates (collectively, “Darrery,” “we,” “our,” “us”) provide investment-related services through our website at https://www.darrery.vc, our password-protected investor portal, our mobile application, and related URLs under the control of Darrery (collectively, the “Website”). This Privacy Notice applies to all of these channels and the services accessible through them (the “Services”).

This Privacy Notice explains how we collect, use, share, and protect the personal information of our investors, prospective investors, and other users of the Services.

“Personal Data” means information that identifies, relates to, describes, or could reasonably be associated with a particular individual or household, as defined by applicable privacy laws.

By accessing or using the Services, or by providing information to Darrery, you consent to the privacy practices described in this Privacy Notice. If you do not agree, please do not access or use the Services or provide us with your information.

MODIFICATIONS AND REVISIONS

We may update this Privacy Notice from time to time to reflect changes in our privacy practices, applicable law, or our Services. We will notify you of any material changes by posting the revised Privacy Notice on our Website and updating the “Last Revised” date above. For material changes, we will also provide notice by email or through a prominent notice on our Website or investor portal. Your continued use of the Services after the “Last Revised” date constitutes your acceptance of the updated Privacy Notice. We encourage you to review this Notice periodically.

COLLECTION OF PERSONAL DATA

We collect Personal Data directly from you, automatically through your use of the Services, and from third-party sources. Where permitted by law, we may combine information from these sources.

Personal Data We Collect Directly From You

Depending on your use of the Services, we may collect:

  • Contact Information. Your name, email address, phone number, nature of inquiry, and any other information you choose to provide when contacting us.

  • Account and Profile Information. When you register for an account or join our investor network, we collect your name, date of birth, email address, phone number, username, and password. You may also voluntarily provide investment profile details, such as your experience level, areas of investment interest, job title, company, professional background, and social media profiles.

  • Investor Network Participation. Information related to your participation in our investor network, including your interest in specific deals or industry sectors, your engagement with deal flow materials, and your responses to investment opportunity updates or communications.

  • Investment and Payment Information. Payment details such as bank account number and routing number, which we use to originate fund transfers and process investment disbursements. We also collect information about your account transactions and investment activity.

  • Communications and Interactions. Records of your communications with us, including emails, calls, and messages, and our responses to you.

  • Survey and Feedback Responses. Your responses to surveys or questionnaires regarding user satisfaction, investment preferences, or other aspects of the Services.

  • Marketing and Promotions. If you opt in to marketing communications, we collect your name, email address, phone number, and preferences. If you participate in promotions, we collect relevant identifying and eligibility information.

  • Investment Preferences. Information about your investment preferences, including risk tolerance, investment goals, preferred asset classes, investment time horizon, and sectors of interest. This information helps us tailor the deal flow and market updates we provide through our communications.

  • Audio, Video, and Electronic Recordings. If you participate in recorded presentations, webinars, or calls conducted through or in connection with the Services, we may collect audio and video recordings of those sessions. 

Personal Data We Collect for Identity Verification

When you make investments or join our investor network, we may collect and process Personal Data to conduct identity verification checks as part of our Know Your Customer (“KYC”), Anti-Money Laundering (“AML”), and accredited investor verification requirements. We may use third-party verification services for these purposes. Depending on the circumstances, additional documentation may be required. Verification information may include your name, net worth, income history, social security number, government-issued identification, and bank account information.

Personal Data We Collect Automatically

We and our third-party providers automatically collect certain information when you use the Website or Services, including through cookies and similar technologies. This may include:

  • Device and Browsing Information. IP address, browser type, operating system, device type, unique device ID, Internet service provider, referring and exiting URLs, access times, and similar technical information.

  • Usage and Activity Data. Information about how you interact with the Services, including links clicked, features used, pages viewed, time spent on the platform, and interactions with deal flow or investment content.

  • Location Information. General location information derived from your IP address. If you enable precise location sharing on your device, we may collect more specific location data. You may disable location sharing through your device settings.

Personal Data We Collect from Third-Party Sources

We may receive Personal Data from business partners, identity verification providers, data analytics providers, credit agencies, fraud prevention organizations, bankruptcy registries, tax authorities, regulatory authorities, and public databases. We may combine this information with Personal Data we collect directly from you.

USE OF PERSONAL DATA

We use your Personal Data for the following purposes:

  • Providing Investment Opportunities and Services. To fulfill your requests, operate the Services, communicate with you about your account and investments, provide access to our deal flow information, and notify you of important changes to the Services.

  • Investor Network Operations. To manage your participation in our investor network, including distributing early-access deal flow, industry updates, market reports, and other investor communications through our portal and other channels.

  • Investment Management. To process payments, manage investment transactions, and administer investment opportunities and your investor profile.

  • Portal Access and Security. To authenticate your identity when you access the password-protected investor portal, monitor for unauthorized access or misuse, and maintain the security and integrity of the portal.

  • Communications. To respond to your inquiries, send requested materials, distribute newsletters and industry updates, provide information about investment opportunities, and send administrative notices regarding the Services.

  • Marketing and Promotions. To send you information about Darrery and our Services, including investment opportunities and other content that you have opted in to receive.

  • Analytics and Service Improvement. To understand how users access and interact with the Services, improve our platform and features, and conduct internal quality control and training.

  • Research, Development, and Surveys. To administer surveys and questionnaires, conduct market research, and develop new products, services, or investment offerings.

  • Security and Protection of Rights. To protect the Services, our investors, and our business; to detect and prevent fraud, unauthorized access, and misuse; and to investigate suspected illegal activity or violations of our terms.

  • Compliance and Legal Obligations. To comply with applicable laws and regulations, respond to legal process (including subpoenas, court orders, and regulatory inquiries), and fulfill our obligations as an investment-related services provider.

  • Auditing, Reporting, and Internal Operations. To conduct financial, tax, and accounting audits; assess compliance with our privacy, security, and legal obligations; maintain business records; and enforce company policies.

  • Business Transactions. To assess and implement mergers, acquisitions, reorganizations, financings, and other corporate transactions.

SHARING OF PERSONAL DATA

We may share your Personal Data in the following circumstances:

  • Affiliates, Subsidiaries, and Business Partners. We may share Personal Data with our corporate affiliates, subsidiaries, and business partners as necessary to deliver the Services or fulfill your requests.

  • Vendors and Service Providers. We may share Personal Data with service providers who perform functions on our behalf, such as IT and hosting services, KYC/AML verification, payment processing, marketing, data analytics, customer support, data storage, legal counsel, and auditing.

  • Investor and Network Operations. We may share certain aggregated or anonymized information about investor network activity with network participants as part of operating the investor community and deal flow distribution service. We will not share individually identifiable Personal Data with other investors without your consent, except as required by law.

  • Identify Verification Partners. We use third-party service providers (“Identity Verification Partners”) to assist us in verifying your identity, preventing fraud, and complying with legal and regulatory obligations. These services are necessary to provide our products and services, maintain platform integrity, and protect against unauthorized or unlawful activity. Our Identity Verification Partners may combine the information we provide with information from their own records and other sources to verify your identity, assess risk, and provide us with identity verification results, risk scores, or related insights. We do not control the independent data practices of these partners with respect to information they obtain from sources other than us, which are governed by their own privacy notices.

  • Marketing and Analytics Providers. We may disclose device, browsing, and usage information to marketing networks, data analytics providers, and similar companies who assist with marketing or analytics on our behalf.

  • Business Transfers. If Darrery is acquired, merged, financed, or undergoes a corporate restructuring or insolvency proceeding, we may disclose or transfer your Personal Data to the relevant parties (including prospective acquirers, lenders, and advisors) in connection with such transaction.

  • Legal and Regulatory Compliance. We may disclose Personal Data as required by law, regulation, subpoena, court order, or governmental or regulatory request, including in response to law enforcement or national security requirements.

  • Tax Authorities. We may share Personal Data with domestic and foreign tax authorities to comply with applicable tax laws and reporting obligations.

  • Professional Advisors. We may share Personal Data with our attorneys, accountants, auditors, and other professional advisors for legal, compliance, and business purposes.

  • Protection of Rights. We may disclose Personal Data where we believe it is necessary to protect the rights, property, or safety of Darrery, our investors, or others, including in connection with litigation or legal claims.

  • Aggregate and De-Identified Information. We may use, disclose, and process aggregated or de-identified information that cannot reasonably identify an individual for analytics, research, product development, and other legitimate business purposes.

  • Other Disclosures. We may disclose Personal Data in other circumstances not described above, in which case we will notify you and obtain your consent where required by law.

PASSWORD-PROTECTED INVESTOR PORTAL

Members of our investor network have access to a password-protected portal through which we distribute deal flow information, investment opportunities, industry updates, and related materials. Access to the portal is limited to credentialed members of our investor network. Use of such portal is subject to the privacy policy and terms and conditions found on such portal or future website as we may designate.

You are responsible for maintaining the confidentiality of your login credentials. You agree not to share your credentials with any third party. Please notify us immediately if you believe your account has been compromised. We reserve the right to suspend or terminate portal access if we detect unauthorized use or a breach of these obligations.

Materials distributed through the portal, including deal flow information, investment summaries, and market analysis, are confidential and intended solely for credentialed members. Unauthorized access, redistribution, or disclosure of portal content is prohibited.

USE OF COOKIES AND OTHER TECHNOLOGIES

We and our third-party providers use cookies, pixel tags, and similar technologies to collect usage data and to operate, improve, and secure the Services. We use this information to analyze how users interact with our Website and portal, identify and fix bugs, optimize performance, personalize content, and support marketing efforts.

Third-Party Analytics. We use third-party tools to analyze traffic and usage of the Services. These providers may collect information about your interactions across websites over time.

Do Not Track. The Services currently do not respond to “Do Not Track” browser signals. We will update this Notice if our practices change.

SECURITY

We implement reasonable technical and organizational measures designed to protect your Personal Data from unauthorized access, use, disclosure, destruction, or modification. These measures include access controls for our investor portal, encryption of sensitive data in transit and at rest, and ongoing monitoring of our systems.

No data transmission over the Internet or any other public network can be guaranteed to be 100% secure. While we work to protect your information, we cannot warrant the absolute security of any information you transmit to us. You provide Personal Data to us at your own risk.

CHILDREN’S PRIVACY

The Services are not intended for, and do not knowingly collect Personal Data from, individuals under the age of 18. If we learn that we have inadvertently collected Personal Data from a person under 18, we will promptly delete that information from our records. If you believe we may have collected information from a child, please contact us immediately.

THIRD-PARTY SITES AND TERMS

The Services may contain links to third-party websites, applications, or services not operated by Darrery. Additional terms may apply to specific investment opportunities or Services, and you will receive those terms where applicable. We are not responsible for the privacy practices of third-party sites or services. Personal Data collected by third parties is governed by their own privacy policies, not this Notice.

INTERNATIONAL VISITORS

The Services are hosted in the United States. If you are accessing the Services from outside the United States, please be aware that your Personal Data will be transferred to, processed, and stored in the United States. Data protection laws in the United States may differ from those in your jurisdiction. By using the Services, you consent to this transfer and processing. If you do not consent, please do not access or use the Services.

YOUR PRIVACY RIGHTS

California Residents

California’s “Shine the Light” Law. California residents may request, once per calendar year, information about (a) the categories of Personal Information we have disclosed to third parties for their direct marketing purposes, and (b) the names and addresses of those third parties. We do not share your Personal Information with third parties for direct marketing purposes without your consent. To submit a request, contact us at the email address below with the subject line “California Disclosure Information.” We will respond within 30 days.

DATA RETENTION

We retain your Personal Data for as long as necessary to fulfill the purposes described in this Privacy Notice, to comply with our legal and regulatory obligations (including applicable securities laws and investment recordkeeping requirements), resolve disputes, and enforce our agreements. When Personal Data is no longer required, we will delete, anonymize, or securely destroy it in accordance with our data retention policies.

CONTACT US

If you have questions or concerns about this Privacy Notice or our privacy practices, or if you wish to exercise your privacy rights, please contact us at:

Darrery Capital, LLC, P.O. Box 102, Pittsburgh, PA 15230

Email: info@darrery.vc  |  Subject Line: “Privacy Policy Inquiry”