Privacy Policy

Revised: January 2025

We recognize and respect the privacy expectations in the investment vehicles of Andom Capital. The following describes the kinds of personal information we collect about our individual investors and users of this website and the circumstances in which that information may be disclosed to affiliated and non-affiliated third parties. All personal information, whether relating to current or former investors or website users, is subject to our Privacy Policies and Procedures, which are described in this notice. We process investors’ personal information for the purpose of providing the services set forth in the subscription documents and other agreements between the investors and Andom Capital and/or its affiliates.

Sources of Personal Information

We collect personal information about investors and website users from the following sources:

Subscription Documents, Investor Questionnaires and other forms, which may include an investor’s name, address, Social Security number and other personally identifiable financial information.
Account History, including information about an investor’s capital account, such as capital contributions, profit and loss allocations and distributions and withdrawals with us and our affiliates.
Transactions with us and our affiliates, including information we receive and maintain relating to securities transactions with and through us and our affiliates.
Correspondence, written, telephonic or electronic, between a website user or an investor and us or any of our affiliates or with third-party service providers who perform services and functions on our behalf to support our interactions with our investors and website users (“Service Providers”).
Website cookies and analytics tools, which may include technical information such as the type of device used to access our website, or browser information, device identifier, IP address or operating system type. We may also collect cookie and analytics information to help us understand how website users interact with our website.
In addition to the sources listed above, we may also collect information about an investor from the investor’s website(s) and from other public sources.

Use of Personal Information

We may use personal information about investors and website users in the following ways:

To provide and improve our services and administer our business operations.
To communicate with website users and investors, including by answering questions and providing updates about our services.
To determine investors’ eligibility for our services.
For security purposes, including to protect our company, our investors and our website users or to investigate potential fraud.
For marketing purposes, including providing investors and website users with information about our company and our business initiatives, and using information to create personalized experiences on our platform. We may also use cookies and tracking technologies to retarget website users or engage in online behavioral advertising.
As authorized by an investor or website user, or as required or permitted by applicable law.

Disclosure of Personal Information

We may disclose personal information about investors in the following ways:

As Authorized – if an investor requests or authorizes disclosure of the information.
As Required by Law – to cooperate, for example, with regulators or law enforcement authorities.
With our Service Providers – to enable our Service Providers to help us run our business.
For Marketing Purposes – including, with respect to website user information, companies that provide cookie, pixeling, online advertising and retargeting services.
As Permitted By Law – for example, sharing information with companies that maintain, process or service customer accounts of financial products and services or who effect, administer or enforce customer transactions is permitted. We may share information with persons acting in a representative or fiduciary capacity on an investor’s behalf. We may share with investors and potential investors in Andom Capital investment vehicles the names of investors (both company names and individuals as appropriate) and the amounts they have invested. In addition, we may share information to the extent reasonably necessary to prevent fraud, unauthorized transactions or liability.

Access to Information

We have implemented controls designed to restrict access to personal information about investors and website users that we maintain on our information technology systems and in our facilities to those with a need to know, including, but not limited to, our employees and our agents or Service Providers who need to know the information to enable us to provide services to investors and website users. Investors may review the personal information we maintain about them by contacting us directly at the email address first set forth on this website.

Information Security

We maintain physical, electronic and procedural safeguards designed to guard investors’ and website users’ personal information.

We cannot promise that the use of our website will be completely safe. We encourage website users and investors to use caution when using the Internet. A username and password are needed to access certain areas of our website. It is the responsibility of the individual who is assigned the username and password to protect such username and password.

Personal information is stored for as long as is necessary to perform Andom Capital’s obligations under the subscription documents or as otherwise necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Business Transfers and Corporate Changes

We reserve the right to disclose and transfer all information collected, including personal information:

to a subsequent owner, co-owner or operator; or
in connection with a corporate merger, consolidation, or restructuring, the sale of substantially all of our stock and/or assets, or other corporate change, including, without limitation, during the course of any due diligence process.

Choices Regarding Personal Information

Investors and website users have certain choices about how we use their personal information. Certain choices are browser- and device-specific.

Our Do Not Track Policy:

Some browsers have “do not track” features that allow a website user to tell a website not to track that website user. These features are not all uniform. We do not currently respond to those signals. If a website user blocks cookies, certain features on our sites may not work. If a website user blocks or rejects cookies, not all of the tracking described in this Privacy Policy will stop.

Links

Our website may contain links to other third-party sites that are not governed by this Privacy Policy. This includes third-party sites that offer resources and content which website users may be able to access through our website. If a website user clicks on a link to a third-party site, that user will be taken to a site we do not control. We are not responsible for the privacy practices used by third-party sites. We suggest that website users read the privacy policies of those sites carefully.

Storage of Personal Information

Personal Information we maintain may be stored in or outside of the United States. Investors and website users who live outside of the United States understand and agree that we may transfer their personal information to the United States.

Changes to Our Privacy Policy

If, at any time, Andom Capital adopts any material changes to the Privacy Policies and Procedures, we shall provide each investor in the investment vehicles with a revised notice reflecting the new Privacy Policies and Procedures.

Questions, comments, or concerns with respect to our privacy practices or this Privacy Policy can be directed to us at info@andomcapital.com.

At Andom, we believe in turning bold visions into thriving empires. Whether you’re an emerging startup or an established business looking to scale, our venture capital expertise and private equity growth strategies empower you to unlock your full potential. Partner with us to fuel innovation, build connections, and achieve success that reigns supreme.