06.30.2026
This Notice of Privacy Policy (“Privacy Policy”) is being sent to you by and on behalf of Eagle Capital Management, LLC (the “Adviser”) and its affiliated entities, including Eagle Capital Equity Fund, L.P. (the “Fund,” and together with the Adviser and its affiliated entities, “Eagle Capital,” “we,” or “our”) in connection with the services we provide. This Privacy Policy describes how we collect, use, and disclose personal information that we collect about individuals who are prospective, former or current investors. For legal entities that provide personal information of associated individuals, such as investors or employees, this Privacy Policy will be relevant for those individuals and those entities should transmit this document to such individuals or otherwise advise them of its content.
We collect the following types of personal information from the following sources:
• Investor applications and other forms, which may include your name(s), address, social security number or tax identification number, employment information, assets, income, net worth, amounts and types of investments, and information revealed in know-your-customer (KYC) and anti-money laundering (AML) due diligence;
• Written and electronic correspondence, including telephone contacts;
• Transaction history, including information about transactions and balances in accounts;
• Third-party service providers (e.g., background screening, investment brokers, consumer reporting agencies, or public databases) who perform services on our behalf or verify or supplement our information; and
• Our website, including registration information and any information captured via cookies or similar technologies.
We may collect information that is considered “sensitive” under some laws including the California Consumer Privacy Act, as amended by the California Privacy Rights Act (together, the “CCPA”), such as your social security number. When we do so, we use such information for lawful purposes in compliance with applicable data protection laws, such as to perform the services requested by you and to resist malicious, deceptive, fraudulent or illegal actions.
You may be asked to provide some of the personal information referred to in this Privacy Policy for one or more of the purposes described below. If you fail to provide this personal information when requested, and the information is necessary for us to comply with our legal or contractual obligations under applicable law, we may not be able to meet the obligations placed on us. In all other cases, the provision of your personal information is voluntary.
We will use personal information you provide for purposes of contract performance, legal compliance, in furtherance of our legitimate interests and with your consent. Our uses include:
• Where necessary for us to comply with legal or regulatory obligations, such as our obligations regarding know-your-client, anti-money laundering, tax purposes, fraud, terrorist financing and sanctions – this may involve collecting specific personal information about you where required by law and disclosing such information to applicable regulators, government bodies and tax authorities;
• Where necessary for us to perform a contract with you or to take steps at your request before entering into a contract, including to: (i) provide you with information regarding our services, (ii) assist you and answer your requests, (iii) evaluate whether we can offer you a service and under what conditions;
• Where necessary for other legitimate business interests, such as:
o For our everyday business purposes - such as to process your transactions, maintain or service your account(s), communicate with you, pay funds, manage records, respond to court orders and legal investigations, and administer and provide services to you, including onboarding, research and due diligence;
o For our or our affiliates direct marketing purposes, such as offers of products and services to you by us or our affiliates; and
o For our risk mitigation purposes - to protect against fraud and security risks, including through background screening.
In some cases, we rely on your consent to process your personal information. We will only rely on your consent where we have specifically asked for it and, in each case, you will have the right to withdraw your consent at any time.
We limit access to personal information to those employees and service providers who need to know that information for business purposes. We maintain policies and procedures designed to protect personal information. Despite these security measures, no such measures can guarantee security or protect against unauthorized activity.
We will retain your personal information for as long as is necessary for the purposes set out in this Privacy Policy, unless a longer period is required under applicable law or is needed to resolve disputes or protect our legal rights. When deciding how long to retain your personal information, among other factors, we take into account our legal and regulatory obligations, the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information described herein and whether we can achieve those purposes through other means.
We may share personal information described above with affiliates or service providers for business purposes, such as to facilitate the servicing of accounts. We may share the personal information described above for business purposes with a non-affiliated third party, for example, (i) if it is necessary to effect, administer, or enforce a transaction that an investor requests or authorizes; (ii) in connection with processing or servicing a financial product or service an investor requests or authorizes; and (iii) in connection with maintaining or servicing the investor’s account. We also may disclose personal information to regulatory authorities or otherwise as required or permitted by law, and to third parties as part of a corporate business transaction such as a merger, joint venture, financing, reorganizing, or sale of company assets. We may disclose personal information as necessary to establish, defend, or otherwise manage a legal claim. We do not sell personal information or share personal information for purposes of cross-context behavioral advertising.
We process personal information in the United States and will, from time to time, send some of your personal information to recipients based in other countries that are located outside the United Kingdom (“UK”) or European Economic Area (“EEA”). Your personal information may be transferred, stored and/or otherwise processed in a country other than the one in which your personal information is collected. As these countries are not within the UK or EEA, this may mean that such countries are not deemed to provide an adequate level of protection for your personal information. When transferring your personal information to the US or other countries, we have implemented procedures designed to ensure that appropriate safeguards based on risk are in place to protect the personal information regardless of where it is being transferred.
To the extent your personal information is transferred to countries outside of the UK or EEA, such transfers will only be made in accordance with applicable data privacy laws, including use of standard contractual clauses approved or recognized by relevant authorities. For further information about the safeguards/derogations used, please contact: compliance@eaglecap.com.
We are committed to providing individuals with reasonable and appropriate access to personal information. If you believe that we are processing personal information about you and wish to have access to that information, we can provide you with that data or at least an explanation of why we cannot do so in the particular context, such as when responding to the request would be unreasonably expensive. We are happy to correct inaccurate data or delete information that is not appropriate to retain. Please also let us know if you have any questions, concerns, disputes, or issues.
You may also have certain rights regarding your personal information, which may be subject to limitations and restrictions. These rights vary by jurisdiction and applicable law and may include the right to: (i) request access to and correction or deletion of your personal information; (ii) restrict or object to processing of your personal information, including limiting our use of any sensitive personal data; (iii) the right to data portability; and (iv) the right to lodge a complaint with a relevant supervisory authority. Please be aware that individual investor information is protected by federal financial privacy law under the Gramm Leach Bliley Act and not subject to the CCPA.
These rights are not absolute, and we reserve all of our rights available to us at law in this regard. We will not discriminate against you for exercising any of these rights. If you wish to exercise one of these rights, please send us your request using the Contact Information below. We will process your request within the time provided by applicable law.
California’s “Shine the Light” law permits California residents to annually request and obtain information free of charge about what personal information is disclosed to third parties for direct marketing purposes in the preceding calendar year. We do not distribute your personal information to outside parties for their direct marketing to you without your consent.
Investors who submit requests will be required to verify their identity. We will not disclose or delete any information until an investor’s identity is verified.
You may designate an authorized agent to submit a request on your behalf by providing that agent with your written permission. If an agent makes a request on your behalf, we may still ask that you verify your identity directly with us before we can honor the request. Agents who make requests on behalf of individuals will be required to verify the request by submitting written authorization from the investor. We will not honor any requests from agents until authorization is verified.
You can exercise any of these rights by contacting us using the Contact Information below.
If you have any questions or concerns about this Privacy Policy or our personal information handling practices, please contact us at compliance@eaglecap.com or + 1 (212) 293-4040 (for CCPA related inquiries, please call + (877) 313-0155).
We may change this Privacy Policy from time to time, and at our sole discretion. Upon any material change to this Privacy Policy, we will provide an updated notice to you.
