Privacy Policy

Effective Date: March 12, 2025
Last Updated: March 12, 2025

This privacy notice (the “Privacy Policy”) describes the types of “Personal Information” (as defined below) that Purchase Capital LLC and/or its affiliates (each, individually and separately “we”, “us”, or “our”) we may collect from you or that you may provide to us, including Personal Information we may collect when you visit our website located at www.PurchaseCapital.com (the “Website”), as well as Personal Information we collect or you may provide to us as we perform investment and related services in the conduct and operation of our business, and in connection with any services, tools, technology, products, features, events, and mobile apps (collectively, the “Services”). 

This Privacy Policy also describes our practices for collecting, using, maintaining, protecting, processing and disclosing such Personal Information, your rights and choices with respect to your Personal Information, and how you can contact us with questions or requests about your Personal Information.

We may modify this Privacy Policy at any time by posting an updated version on the Website.

In addition, we may provide you with real time disclosures or additional information about the Personal Information handling practices of specific parts of our Services. Such notices may supplement this Privacy Policy or provide you with additional choices about how we process your Personal Information.

Section 1 – Personal Information We Collect Through Your Use of the Website or our Services

“Personal Information” is information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device.  Personal Information does not include:

  • Publicly available information from government records and other sources.
  • Anonymized or aggregated consumer information.

When we perform any activity with respect to Personal Information, including actions like collecting, storing, using, accessing, transferring, or destroying such Personal Information, whether the activity is automated or manual, we are “processing” your Personal Information. 

We collect Personal Information, including your name, phone number, e-mail address and/or physical address or other Personal Information in connection with your accessing or using the Website or our Services, including:

  1. Information You Provide to Us. In connection with the Services, we may collect the following categories of Personal Information from you:
    • Business and Professional Information:  Examples of business and professional information that may be collected by us include your name, employer/company, job title, telephone number, business and/or personal address(es), email address, information regarding your job, identification numbers (such as a passport number or other government issued ID), and/or other information regarding your preferences where it is relevant to the Services. If you apply for a job with us, we may collect your name, phone number, email address, and physical address, information about your current role, education history, employment history, qualifications, certifications, and professional memberships, and information about your country of birth, immigration status, government identification documents (including drivers licenses, ID cards, passports, and residency permits), and, in some cases, your social security number (or equivalent national identification number). We may also collect Personal Information that you provide directly to us during conversations, during formal interviews, or in your application materials.
    • Financial  Information: Examples of financial information that may be collected by us include bank account details, credit card number, money transfers (including communications regarding bank transfers), assets, investment profile, credit history, debts and expenses.
    • Voluntary Information: We may collect Personal Information you provide to us voluntarily by completing web forms, participating in surveys, submitting information to us or contributing to blogs, forums, postings, social media pages or contacting customer service.
  2. Automatically Collected Usage Information. When you use the Services online or through our Website, we automatically collect information about the Services and Website pages you use and how you use them (“Usage Information”), as described below.
    • Service Data: We collect information about your interactions with the Website and/or our Services, such as the pages or other content you view, and other actions you perform while using the Website or our Services.
    • Log Data: We automatically collect log information when you use the Website. This might include your IP address, access times, hardware and software information, device information, device event information (e.g., crashes, unsuccessful logins, browser type), the website page you’ve viewed or engaged with before or after using the Website or our Services, data related to when you open our message or click on any links or banners it contains.
    • Cookies and Similar Tracking Technologies: We may use various tracking technologies to collect and store information about your use of our Website and the Services. We use these tools to ensure that you receive a personalized experience, to provide you with certain functions on our Website and in connection with our Services, for security purposes, and to improve and optimize our Website and our Services. See Section 9 below for more information.
  3. Information Collected from Other Sources:  We may collect Personal Information from other sources, including, for example, our affiliates, business partners, service providers, online social media networks, and other third parties, or from publicly available sources.

Section 2 – How We Use Your Personal Information

Your Personal Information may be used for various purposes, including:

  1. To Provide Our Services. When you access or use our Services, we process certain Personal Information about you to administer and maintain our Website and business. Some examples of how we process your Personal Information in connection with our Services include, but are not limited to:
    • making, maintaining, managing and disposing of our investments;
    • conducting due diligence and evaluating business opportunities;
    • developing new investment opportunities; 
    • managing, operating and growing our business, administering the Services and managing investor accounts, including through the use of third–party service providers.
  2. To Communicate with You. When you communicate with us or submit information to us, you will receive Service-related communications. Our Service-related communications are transactional messages about your business, investment opportunity, policy changes, or other Service-related notifications. Service-related communications are necessary for us to continue to provide our Services to you.
  3. Marketing Communications. We may also use your Personal Information for marketing, promotional, or business development-related communications and initiatives. You can manage your email preferences and opt out of certain communications by emailing us at info@purchasecapital.com or by following the instructions within the emails you receive from us, as discussed further in Section 4 below.
  4. To Enforce our Terms, Agreements, or Policies. We use your Personal Information to make sure our terms, policies, and agreements with you and any third parties are enforced. We may monitor, investigate, prevent, and mitigate any suspected or actual prohibited activities in connection with our Website and/or our Services. We may process your Personal Information for this purpose in connection with providing our Website and Services.
  5. For Research and Analytics. We may process your Personal Information to improve, optimize, or expand our Services or features of our Website and Services and to understand market trends and developments. We may take additional security measures when processing your Personal Information for such purposes, such as by de-identifying your Personal Information and limiting access to such data. 
  6. To Comply with Applicable Laws. We may be required to process your Personal Information under certain laws and regulations, such as tax laws. We may also process any and all information to law enforcement agencies or others if required to do so by law or in the good faith belief that such preservation or disclosure is reasonably necessary to: (a) comply with legal or regulatory process (such as a judicial proceeding, court order, or government inquiry) or obligations that we may owe pursuant to ethical and other professional rules, laws, and regulations; (b) enforce the Purchase Capital Website User Agreement and other policies; (c) respond to claims that any content violates the rights of third parties; or (d) protect the rights, property, or personal safety of Purchase Capital, its employees, its users, its clients, and the public. We cannot provide the Website or the Services to you without such processing.

Section 3 – How We Share Your Personal Information 

We may share your Personal Information as follows:

  1. Third-Party Service Providers. We may share Personal Information with third parties that perform certain services on our behalf in connection with the Website and/or our Services such as:
    • to process and store data, including your Personal Information;
    • to track, analyze, and modify our Services;
    • for marketing, advertising, and event planning; and
    • to administer our Website or support our IT and security efforts.

      Google Analytics. Google Analytics is one of our analytics service providers. For more information on the privacy practices of Google, please visit the Google Privacy & Terms at  https://www.google.com/policies/privacy/. You can also find out more about how Google uses data at “How Google uses data when you use our partners’ sites or apps” located at www.google.com/policies/privacy/partners/ as well as their policies for safeguarding data at https://support.google.com/analytics/answer/6004245. The Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics (available at https://tools.google.com/dlpage/gaoptout/ and https://chrome.google.com/webstore/detail/google-analytics-opt-out/fllaojicojecljbmefodhfapmkghcbnh?hl=en).

      Certain third-party service providers, such as payment transaction processors, have their own privacy policies with respect to the information we are required to provide to them for your transactions.

      For these providers, we recommend that you read their privacy policies so you can understand the manner in which your Personal Information will be handled by these providers. In particular, remember that certain providers may be located in or have facilities that are located in a different jurisdiction than either you or us. If you elect to proceed with a transaction that involves the services of a third-party service provider, then your information may become subject to the laws of the jurisdiction(s) in which that service provider or its facilities are located.
  2. To Perform Investment Services. We may also disclose Personal Information to the following categories of third parties: (i) anyone involved in the matter we are working on, including counsel, counterparties, experts, mediators, opponents, attorneys and witnesses, on a need to know basis, as necessary to provide the Services or otherwise assist in the fulfillment of our business obligations, (ii) law enforcement, tax and regulatory agencies and bodies, and (iii) insurers. 
  3. Between Purchase Capital Affiliated Companies.  We may share Personal Information among our corporate affiliates (e.g., parent company, sister companies, subsidiaries, or other companies under common control). If a third party acquires, or plans to acquire, our company, business, or our assets, or invest in us or provide financing to us, we may also share information with them, including at the negotiation stage.
  4. Merger, Bankruptcy, or Corporate Reorganization. We may disclose and transfer your Personal Information to a subsequent owner, co-owner, or operator of Purchase Capital or the Website or the Services, or in connection with a merger, consolidation, restructuring, the sale of substantially all of our interests and/or assets (including a bankruptcy or similar proceeding), or other corporate change.
  5. Legal Obligations, Security, or Exercise of Our Rights. We may share your Personal Information if it is reasonably necessary to:
    • Comply with a valid legal process (e.g., subpoenas, warrants, court orders or other legally required disclosures);
    • Comply with requests or investigations by public authorities;
    • Comply with applicable laws or regulations;
    • Establish, exercise or enforce our rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our policies, or to comply with your requests or the provision of Services;
    • Protect the security or integrity of the Website and our Services; or
    • Protect the rights, property, or safety of Purchase Capital, our employees or users, partners and affiliates, or other natural persons.
  6. For Any Other Purpose, With Your Consent.  We may share your Personal Information on your behalf or at your request. We will only do so as you instruct us or with your specific consent. If you provide your consent to share your Personal Information, you may withdraw your consent at any time. Withdrawing your consent will not undo or reverse the lawfulness of any previous processing, and in some cases Personal Information may not be retrieved once shared. Contact us by email, phone or regular mail using the contact information provided in the “Questions & Contact Information” section below if you would like to withdraw your consent. We do not sell your Personal Information.

Section 4 – Your Choices

  1. Voluntary Information. You may choose not to provide us with your Personal Information. For example, you are not required to complete any survey we send to you. Note, if you do not provide certain Personal Information, we may not be able to provide our Services, make investments, or otherwise analyze a company.
  2. Communication Preferences.  Some jurisdictions give you a right to make the following choices regarding your Personal Information:
    • Access To Your Personal Information: You may request access to your Personal Information or confirmation that we have Personal Information about you. In certain limited circumstances, you may also request to receive access to your data in a portable, machine-readable format. 
    • Changes To Your Personal Information: We rely on you to update and correct your Personal Information. You may ask us to correct information that is inaccurate or incomplete. Note that we may keep historical information in our backup files as permitted by law. 
    • Deletion Of Your Personal Information: You may request that we delete your Personal Information. If required by law, we will grant a request to delete Personal Information, but you should note that in many situations we must keep your Personal Information to comply with our legal obligations, resolve disputes, enforce our agreements, or for another business purposes. 
    • Opt-out of Targeted Advertising: You may opt-out of targeted advertising by submitting a request as described below.  
    • Objection to Certain Processing: You may object to our use or disclosure of your Personal Information by contacting us at the address provided in the “Questions & Contact Information” below. 
    • Promotional Emails: You may choose to provide us with your email address for the purpose of allowing us to send newsletters, surveys, offers, and other promotional materials to you. You can stop receiving promotional emails by following the unsubscribe instructions in emails that you receive. If you decide not to receive promotional emails, we may still send you Service-related communications. If you unsubscribe from Service-related communications, we may not be able to continue providing the Services to you.  
    • Promotional Mailings: If at any time you do not want to receive offers and/or circulars from us you can remove yourself from our mailing lists by emailing us (our contact information is provided in the “Questions & Contact Information” section below) with “NO MAILERS” in the subject line along with your name, address, and zip code. Please note that our mailings are prepared in advance of their being sent. Although we will remove your name from our mailing list after receiving your request, you may still receive mailings from us that had been initiated prior to your name being removed.
    • Promotional Text Messages: If you receive a text message from us that contains promotional information you can opt-out of receiving future text messages by replying “STOP.”

Please note, not all of the rights described above are absolute, and they do not apply in all circumstances. In some cases, we may limit or deny your request because the law permits or requires us to do so, or if we are unable to adequately verify your identity. We will not discriminate against individuals who exercise their privacy rights under applicable law.

Submitting Requests

You may exercise the rights described above by contacting us as indicated in the “Questions & Contact Information” section below. Note that, as required by law, we will require you to prove your identity. We may verify your identity by phone call or email. Depending on your request, we will ask for information such as your name or the date of your last interaction with us. We may also ask you to provide a signed declaration confirming your identity. Following a request, we will use reasonable efforts to fulfill your request.

In some circumstances, you may designate an authorized agent to submit requests to exercise certain privacy rights on your behalf. If you are an authorized agent submitting a request on behalf of an individual, you must attach a copy of a letter signed by the individual indicating that you are able to act on another person’s behalf.

Section 5 – Third-Party Websites and Services

You may find links to other websites, third party applications, and widgets on our Website or as part of our Services, which we do not own or control, such as social media, portfolio company websites, or related news. When you click on links in Website or our Services, they may direct you away from our Website. We are not responsible for the privacy practices of other sites and encourage you to read their privacy statements. Once you leave our Website or the Services or are redirected to a third-party website or application, you are no longer governed by this Privacy Policy or our Website’s User Agreement or Terms of Use.

Section 6 – Security

No method of transmission over the internet, or method of electronic storage, is fully secure. While we use reasonable efforts to protect your Personal Information from unauthorized access, use, or disclosure, we cannot guarantee the security of your Personal Information. In the event that we are required by law to inform you of a breach to your Personal Information we may notify you electronically, in writing, or by telephone, if permitted to do so by law.  

Section 7 – Children’s Privacy

By using the Website, you represent and warrant that you are at least the age of majority in your jurisdiction of residence, or that you are the age of majority in your jurisdiction of residence. Our Website is not intended for children under 16 years of age, and no one under age 16 may provide any Personal Information to or via the Website. We do not knowingly collect Personal Information from children under 16. If you are under 16, do not use or provide any information on this Website or through any of its features, register on the Website, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received Personal Information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us using the information provided in the “Questions & Contact Information” section below.

Section 8 – Retention

We retain your Personal Information for only as long as necessary to fulfil the purposes outlined in this Privacy Policy, including for the purposes of satisfying any legal, accounting, or reporting requirements, unless a longer retention period is required or permitted by law. To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of the information, the purposes for which we obtained the information and whether we can achieve those purposes through other means, as well as applicable legal requirements. We will not delete any Personal Information that also relates to other individuals, unless such other individuals also request to delete their Personal Information at the same time.

Section 9 – Cookies and Other Tracking Technology

We use cookies and similar technologies such as pixel tags, web beacons, clear GIFs and JavaScript (collectively, “Cookies”) to enable our servers to recognize your web browser, tell us how and when you visit and use our Website and the Services, analyze trends, learn about our user base and operate and improve our Website and the Services. 

Cookies are small pieces of data–usually text files–placed on your computer, tablet, phone or similar device when you use that device to access our Website or the Services. 

We may also utilize a technology called a “web beacon” or “pixel tag.”  We may use web beacons to help determine which email messages sent by us were opened and whether a message was acted upon. Web beacons also help analyze the effectiveness of websites by measuring the number of visitors to a site or how many visitors clicked on key elements of a site. 

We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s).

As noted above, we also may use automated applications, such as Google Analytics to evaluate the use of our Website. Google Analytics is a web analytics service offered by Google LLC (“Google”) that tracks and reports on our web traffic. We use these tools to gather non-personal data about users to help us improve our services and user experiences. These analytics providers may use cookies and other technologies to perform their services, and may combine the information they collect about you on our Website with other information they have collected for their own purposes. This Privacy Policy does not cover such uses of data by third parties. 

We use the following types of Cookies:

  • Required Cookies: Required Cookies are required for providing you with features or services that you have requested. Disabling these Cookies may make certain features of the Website unavailable.
  • Functional Cookies: Functional Cookies are used to record your choices and settings regarding our Website, maintain your preferences over time and recognize you when you return to our Website. These Cookies help us to personalize our content for you, greet you by name and remember your preferences.
  • Performance/Analytical Cookies: Performance/Analytical Cookies allow us to understand how visitors use our Website. They do this by collecting information about the number of visitors to the Website, what pages visitors view on the Website and how long visitors are viewing pages on the Website. Performance/Analytical Cookies also help us measure the performance of our advertising campaigns in order to help us improve our campaigns and the Website content for those who engage with our advertising.

Performance/Analytical Cookies also help us measure the performance of our advertising campaigns in order to help us improve our campaigns and the Website content for those who engage with our advertising.

You can decide whether or not to accept Cookies through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit our Website and some of the Website pages and functionalities may not work.

To explore what Cookie settings are available to you, look in the “preferences” or “options” section of your browser’s menu. To find out more information about Cookies, including information about how to manage and delete Cookies, please visit http://www.allaboutcookies.org/.

Section 10 – Notice to Individuals in the State of California

  1. Marketing. California law permits California residents to ask Purchase Capital for information regarding the categories of Personal Information that we share with our affiliates and/or third parties for marketing purposes, and that provides contact information for such affiliates and/or third parties. If you are a California resident and would like such information, please submit a written request to us at the address provided under the “Questions & Contact Information” section below.
  2. Do Not Track Signals. Currently, we do not monitor or take any action with respect to Do Not Track signals.

Section 11 – Changes to this Privacy Policy

We may change our Privacy Policy and practices over time. To the extent that our Privacy Policy changes in a material way, the Privacy Policy that was in place at the time that you submitted Personal Information to us will generally govern that information unless we receive your consent to the new Privacy Policy. Our Privacy Policy includes an “effective” and “last updated” date. The effective date refers to the date that the current version took effect. The last updated date refers to the date that the current version was last substantively modified. Changes and clarifications will take effect immediately upon their posting on the Website. 

Section 12 – Cross-Border Transfers

This Website is operated, in whole or in part, from the United States. Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers. As a result, your Personal Information may be processed in a country with less stringent privacy laws than the laws in the country that you reside. Where possible, we treat Personal Information using the same privacy principles that guide the law of the country in which we first receive your data. By using the Website and/or submitting your Personal Information to us, you agree to the transfer, storage, and processing of your data in a country other than your country of residence including, but not limited to, the United States, and you consent to have us use and otherwise process your Personal Information in accordance with this Privacy Policy. 

Section 13 – European Economic Area (“EEA”) Residents

We are located in the United States and the Personal Information we collect is stored in the United States. This section applies to you if you live in the EEA.  You may have the right to:

  • Request access to your Personal Information, confirmation that we have Personal Information about you, and to receive a copy of the Personal Information we hold about you and to check that we are lawfully processing it.
  • Request correction of the Personal Information that we hold about you if it is inaccurate or incomplete.
  • Request erasure of your Personal Information, subject to certain limitations, where there is no good reason for us continuing to process it.  You also have the right to ask us to delete or remove your Personal Information where you have successfully exercised your right to object to processing (see below), where you believe we may have processed your Personal Information unlawfully or where we are required to erase your Personal Information to comply with local law.
  • Object to processing of your Personal Information where we are relying on a legitimate interest (or that of a third party) and you feel it impacts your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Information for direct marketing purposes.  In some cases, we may demonstrate that we have compelling legitimate grounds to process your Personal Information which override your rights and freedoms under certain circumstances.
  • Request restriction of processing of your Personal Information under certain circumstances if: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer (or portability) of your Personal Information to you or to a third party in a structured, commonly used, machine-readable format, in certain limited circumstances.  Note that this right only applies to automated information which you initially provided for us to use or where we used the information to perform a contract with you.
  • Withdraw consent, to the extent the processing of your Personal Information is based on your consent.
  • Complain to a government regulator if you are not satisfied with our response, depending on your location.

If you reside in the EEA, you may also request a copy of any standard contractual clauses we use for the transfer of your data outside of the EEA, which includes the categories of information transferred by contacting us using the contact information below.

Legal Bases For Processing

This section describes some of the legal bases we rely on to process your Personal Information. We may process your Personal Information for more than one legal basis depending on the specific purpose(s) for which we are using your Personal Information, including the following legal bases:

  • Contracts: Where we need to perform a contract we are about to enter into or have entered into with you, including to provide the Services to you.
  • Legitimate Interests:  Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. The following are non-exhaustive examples of where we rely on legitimate interest to process Personal Information:
    • We have a legitimate interest in processing Personal Information relating to our existing clients in order to manage our business relationship, provide our Services and provide communications and information that may be of interest, including marketing communications.
    • We have a legitimate interest in using cookies as outlined in this Privacy Policy. We have a legitimate interest in communicating with you to respond to and/or follow up on your requests, inquiries, issues, or feedback.
  • Legal Obligations:  Where we need to comply with a legal or regulatory obligation.
  • Consent:  In some cases, we rely on your consent as a legal basis for processing your Personal Information.

Section 14 – Governing Law; Language 

All matters relating to the Website and the Privacy Policy, and any dispute or claim arising therefrom or related thereto, shall be governed by and construed in accordance with the internal laws of the State of Florida, or with respect to consumers who are California residences, the internal laws of the State of California, without giving effect to any choice or conflict of law provision or rule. If any text on the Website is published in languages other than English, the English language version of any text, including this Privacy Policy, controls the legal impact and interpretation of this Privacy Policy, content on the Website and its use.

Section 15 – Questions & Contact Information

If you have any questions, comments, or complaints concerning our privacy practices, or if you need to access this Privacy Policy in an alternative format due to having a disability, please contact us by email, phone or regular mail at the applicable address below. We will attempt to respond to your requests and to provide you with additional privacy-related information. 

Purchase Capital, LLC
1395 Brickell Avenue
Suite 800
Miami, FL 33131
Email: info@purchasecapital.com
Telephone: +1 (305) 697-9600