Privacy Policy

AsterAlpine Privacy Notice — Version Date: 2025-03-26 (updated February 2026)

Introduction

AsterAlpine is committed to safeguarding and processing personal information ("PI"), including sensitive personal information ("SPI") in accordance with applicable privacy laws. The entity references "AsterAlpine", "we", "us" or "our" as AsterAlpine Capital, LLC and its subsidiaries collectively functioning as controllers of personal information.

The term "you" or "your" applies to individuals whose information is processed, encompassing investors and representatives with direct or indirect relationships, as well as beneficial owners connected to service provision, transactions, or third-party vendor relationships.

This Privacy Notice outlines the purposes for collecting, using, and disclosing personal information while detailing individual rights regarding that processing. Additional terms governing information collection should be read alongside this notice.

PI We Collect About You

Personal information includes data identifying individuals through information alone or combined with other sources. It excludes non-attributable information where identity has been removed. Sensitive personal information encompasses race, ethnicity, religious beliefs, sexual orientation, political opinions, trade union membership, health information, and biometric data.

Collection categories include:

Identification data: Full name, title, gender, marital status, date of birth, passport number, driving license, national identification number, signature
Contact data: Personal address, telephone number, email address
Electronic Monitoring data: Recording and monitoring electronic communications where legally permitted
Financial data: Account numbers, client reference numbers, account statements, investment history
Marketing, Behavioral and Communications data: Marketing preferences, website usage, portal interactions (detailed in Cookie Notice)
Professional Information data: Position, business address, business telephone, business email
Profile data: Usernames, passwords, investments made, services requested, survey responses
Services data: Payment details, service descriptions provided or received
AsterAlpine Building and Assets Security data: Visit records, CCTV recordings
Technical data: Online service usage, IP address, browser type and version, operating system
SPI: Criminal conviction records (when legally required), dietary requirements, disability information, political affiliations

Collection Methods

Information is collected:

Directly through completed forms and applications
Via organization or entity representatives employed with AsterAlpine
Throughout ongoing relationships when details change or services evolve
From public sources including social media and talent acquisition notifications
From third parties such as credit reference agencies
Through website visits and online service logins
Through derived records of interactions

Unless indicated as optional, requested information is necessary for providing requested products and services. Non-provision may prevent service delivery.

Purpose and Legal Basis for Processing PI

For Account Opening and Relationship Initiation

Processing includes anti-money laundering, anti-terrorism, sanction screening, fraud, and due diligence checks. Categories involve identification, contact, financial, professional information, services data, and SPI. Basis includes contract performance, legal/regulatory obligation, and legitimate interests in preventing criminal activity and unlawful conduct.

For Service Delivery

Processing encompasses liaison with third parties and technology solutions access. Identification data, contact information, financial data, profile data, services data, technical data, marketing communications, and professional information are involved. Basis includes contract performance, regulatory obligation, and legitimate interests in providing quality client services and ensuring fee payment.

For Payment and Collection Management

Identification, contact, financial, professional information, and services data are processed. Basis involves contract performance and legitimate interests in managing payments and recovering owed amounts.

For Relationship Management

Processing includes notifications about terms and privacy notice changes. Information categories encompass identification, contact, profile, marketing communications, and professional data. Basis involves contract performance, regulatory obligation, and legitimate interests in notifying about changes.

For Governmental and Regulatory Interaction

Processing involves identification, contact, financial, services, and professional information. Basis is regulatory obligation and public interest.

For Fraud Detection and Prevention

Processing addresses fraud detection and criminal activity prevention, employee protection, and asset safeguarding. Categories include identification, building security data, contact, electronic monitoring, financial, professional information, profile, services, and technical data. Basis involves regulatory obligation, public interest, and legitimate interests in protecting assets and preventing policy violations.

For Business Management and Protection

Processing supports security improvement, troubleshooting, system maintenance, testing, data hosting, and facilities management. Identification, contact, profile, technical, marketing communications, and professional information are involved. Basis includes regulatory obligation and legitimate interests in efficient, secure business operations.

For Event Invitation and Participation

Processing manages participation in market insights, seminars, and similar events. Information categories include identification, contact, profile, technical, marketing communications, and professional data. Basis involves consent and legitimate interests in maintaining current client records, promoting services, gathering feedback, and improving offerings.

For Marketing Communications

Processing sends marketing communications and service updates, analyzing website platform usage for improvement. Categories encompass identification, contact, profile, technical, marketing communications, and professional information. Basis involves consent and legitimate interests in understanding client perspectives and identifying service improvements.

For Vendor Services

Engagement Processing: Anti-money laundering, anti-terrorism, sanctions, fraud, and background checks. Information includes identification, contact, financial, services, and professional data. Basis involves contract performance, regulatory obligation, legitimate interests in preventing unlawful activities, and public interest.

Payment Management: Processing identification, contact, financial, professional information, and services data. Basis includes contract performance and legitimate interests in payment management and collection.

System Access Management: Managing security, troubleshooting, maintenance, testing, and hosting. Categories include identification, contact, profile, and technical data. Basis involves regulatory obligation and legitimate interests in secure business operations and data security.

To Whom We Disclose Your PI

Information may be disclosed to:

Other AsterAlpine team members
Professional advisors, agents, and contractors providing services
Goods and services providers, intermediaries, brokers, and partners
Competent authorities when required or permitted by law
Potential buyers, transferees, merger partners, and their advisers in connection with business transfers
Credit reference agencies or other organizations that help us to conduct anti-money laundering and anti-terrorist financing checks
Persons authorized by applicable law or regulation

Service Providers We Use

We rely on a limited set of third-party service providers to operate this website and process form submissions. Each processes information only to provide services to us. They currently include:

Render — website and form-API hosting.
Microsoft Clarity — website analytics and session replay (optional — see our Cookie Notice and Cookie Preferences).
Cloudflare — bot/spam protection on our forms (Turnstile), media delivery, and network services.
Resend — delivery of the emails generated when you submit our contact or registration forms.
Clerk — account sign-in and authentication, if you create an account.
Google Fonts — web-font delivery.

These providers may process information under their own privacy policies. This list may change as our tools evolve; we review it periodically.

International Transfers and Service Providers

Personal information may transfer internationally to AsterAlpine locations in the USA, Canada, UK, and Mexico. Despite varying privacy law levels, identical security and organizational controls apply globally. Third-party service providers contractually comply with AsterAlpine's processing criteria.

For EEA transfers, protection occurs through EU-adequate country designations or contractual EU-approved clauses ensuring equivalent protection.

Marketing and Opt-Out Rights

Certain jurisdictions require express marketing consent. Universally, individuals may opt-out anytime by clicking electronic opt-out links, contacting usual AsterAlpine representatives, using contact details provided, or exercising cookie-related rights per the Cookie Notice.

Selling, Sharing, and Affiliates

We do not sell your personal information, and we do not share it with unrelated third parties for those third parties to use for their own marketing purposes.

Affiliates. We may share personal information with companies that are under common ownership or control with us (our "affiliates"), for purposes consistent with this Privacy Notice — such as operating our business, providing and administering services, and internal management. Where we do so, affiliates are expected to handle personal information consistent with this notice.

PI Retention

Information processes as long as necessary for collection purposes or to comply with legal, regulatory, accounting, reporting, internal policy requirements, or legal claim establishment or defense.

PI Security

Security measures include:

Staff education and training regarding privacy obligations and social engineering risks
Ongoing confidentiality, integrity, availability, and resilience of processing systems
Timely restoration capability following physical or technical incidents
Administrative and technical access restriction controls
Technological measures including firewalls, industry standard SSL encryption with at least 128-bit key lengths, and anti-virus software
Physical security measures like building access controls
External technical assessments, security audits, and vendor due diligence
Perimeter security
Network segregation

Internet data transmission security cannot be guaranteed. Users should avoid sending personal information through unsecure channels. Transmission security is not guaranteed.

Your Rights

Individuals may have the following processing rights:

Access: Requesting personal information copies and usage/sharing information
Object: Objecting to processing based on legitimate interests, public task performance, or direct marketing
Correction: Requesting information updates or corrections for inaccurate or incomplete data
Erasure: Requesting deletion where no legal, regulatory, or valid processing reason exists
Restriction: Requesting processing restrictions, such as for accuracy disputes or pending objections
Portability: Requesting personal information copies in commonly used electronic formats
Automated decision making: Requesting manual intervention for legal-effect automated decisions

Rights may be exercised by emailing Privacy@AsterAlpine.com or using provided contact details. Applicable law and regulation permit appropriate fees for rights exercise.

Specific information may be requested confirming identity and access authorization. Additional information requests may locate processing-related personal information. Responses follow applicable law timescales. Rights exercise carries no disadvantages.

State-Specific Privacy Rights

Depending on your state of residence and subject to applicable law, you may have certain rights regarding the personal information we collect, use, disclose, sell, share, or otherwise process. These rights may include the right to:

Confirm whether we process your personal information;
Access the personal information we maintain about you;
Correct inaccuracies in your personal information;
Request deletion of your personal information;
Obtain a copy of certain personal information in a portable format;
Opt out of the sale of personal information, the sharing of personal information for cross-context behavioral or targeted advertising, or certain profiling activities;
Limit the use or disclosure of sensitive personal information, where applicable;
Appeal a decision we make regarding a privacy rights request, where applicable; and
Be free from unlawful discrimination or retaliation for exercising your privacy rights.

To exercise these rights, please contact us at Privacy@AsterAlpine.com. We may need to verify your identity before processing your request. If you submit a request through an authorized agent, we may require proof that the agent is authorized to act on your behalf and may also require you to verify your identity directly with us.

If we deny your request, in whole or in part, you may have the right to appeal our decision by contacting us at Privacy@AsterAlpine.com and stating that you are appealing a privacy rights decision.

We will respond to privacy rights requests within the time required by applicable law. Some rights may be limited by legal exceptions, including where we need to retain information to provide services, complete transactions, comply with legal obligations, prevent fraud, protect security, or exercise legal rights.

Where required by applicable law, we will also honor recognized browser-based or device-based opt-out preference signals, such as Global Privacy Control, for residents of states where such signals must be honored.

Contacting Us

The Global Head of Privacy and Data Protection oversees AsterAlpine privacy and data protection compliance. For rights exercise or questions, contact:

The Global Head of Privacy and Data Protection
AsterAlpine Capital, LLC
PO Box 141953, Irving, Texas USA
E-Mail: Privacy@AsterAlpine.com

California residents may call +1 (512) 200-4998.

Complaints

Personal information processing concerns should contact the Global Head of Privacy and Data Protection at Privacy@AsterAlpine.com.

Individuals retain rights to complain to data protection or competent authorities with jurisdiction over privacy law in their residence or work country, or where processing issues arose.

Cookies, Analytics, and Third-Party Services

We may use cookies, analytics tools, advertising technologies, embedded content, and other third-party services that collect information about your interactions with our website. These third parties may process information under their own privacy policies. Where required by applicable law, you may opt out of certain disclosures or uses of personal information for targeted advertising, cross-context behavioral advertising, or sale/sharing by adjusting your cookie preferences or using the controls described in our Cookie Notice.

A separate Cookie Notice describes the cookies and similar technologies we use and how to control them.

Linked Websites

This Privacy Notice does not apply to third-party owned or controlled websites or sites displaying AsterAlpine advertisements.

Changes to This Privacy Notice

Modifications may occur. Regular website visits ensure awareness of amendments. Material changes receive appropriate channel communication based on normal contact methods.

Note: Not all privacy laws define SPI; Hong Kong, Singapore, and Canada examples exclude this definition.

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