Website Privacy Policy
Last Revised: June 30, 2026
This Website Privacy Policy (the “Privacy Policy”) and CCPA notice at collection describes how Eagle Capital Management, LLC (“Eagle Capital”, “we”, “us”, or “our”) collect and use personal information about you when you visit our website at https://www.eaglecap.com/ (the “Website”) or in other contexts. If you are an investor in a fund or the holder of an account managed directly or indirectly by us (or, in either case, their representative), please refer to the investor privacy notice for further information about how Eagle Capital collects and processes personal information about its current, prospective and former investors.
If you are located outside the European Economic Area (“EEA”) or the United Kingdom (“UK”), by accessing and using the Website, you agree and consent to the collection, use, processing and disclosure of your personal information as outlined in this Privacy Policy. If you are located in the EEA or the UK, this Privacy Policy is provided for informational purposes only.
Eagle Capital is a controller of your personal information. We may ourselves, or through a third party, process the personal information that you provide to us.
Personal Information We Collect:
Personal information includes information such as your name, address, email address, telephone number(s) and date of birth, from which you can be directly or indirectly personally identified, and includes information such as identification, tax references and account numbers. This personal information may relate to your finances, employment, avocations or other personal characteristics, as well as transactions and interactions with or through us or with others.
We collect personal information about you in connection with providing our services to you. This information may include your name, date of birth, address and other contact details, national identification or social security number, identity documents such as passports and other “know your client” documents and may also include other information such as:
Sensitive Personal Information:
Subject to the relevant jurisdictional regulatory requirements, we may process sensitive personal information, such as your social security number. We will only use and disclose sensitive personal information in compliance with applicable privacy laws. Unless we request it, we ask that you not send us, or disclose, any sensitive personal information.
Why We Collect and How We Use Personal Information:
We process your personal information to deliver superior service to you. Such service includes advising you about our products, services and other opportunities, maintaining your accounts with us, processing transactions requested by you or other persons authorized by you, and administering our business. We also collect your personal information in order to comply with statutory obligations and other tax and regulatory requirements to which we may be subject, including anti-money laundering requirements.
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.
Your personal information may be processed by us, or our affiliates, agents, employees, delegates or sub-contractors, for the following purposes:
a) for the purposes of performing the contract you have entered into with us, including to facilitate the opening of your account with us, the management and administration of your holdings with us or any related account on an ongoing basis which are necessary for the performance of your contract with us;
b) for compliance with our legal obligations, including anti-money laundering checks, compliance with applicable tax and regulatory reporting obligations and related actions which we consider appropriate to meet any legal obligations imposed on us, including to comply with valid legal process such as a search warrant, subpoena, or court order;
c) to pursue our legitimate interests in relation to the prevention of fraud, money laundering, terrorist financing, bribery, corruption, tax evasion and to prevent the provision of financial and other services to persons who may be subject to economic or trade sanctions, on an on-going basis;
d) where our use is for a legitimate purpose of our group, including:
i. for day to day operational and business purposes, including board and group reporting and management purposes;
ii. taking advice from our external legal and other advisors;
iii. to help us improve our services and systems, and to improve your experience on our Website and online services;
iv. to undertake market research, statistical and product development analyses;
v. to communicate with you, including by providing updates pertaining to your interests and/or services, in addition to receiving occasional Eagle Capital news, updates, related product or service information, etc. To opt out of marketing or promotional materials, you can click the unsubscribe link in the email message or contact us at any time at compliance@eaglecap.com;
vi. marketing purposes;
vii. to protect our rights, property and interests and the security of our assets, systems and networks;
viii. to enforce our terms and conditions; and
ix. to monitor and record calls for quality, business analysis, training and related purposes; and
e) where necessary to establish, exercise or defend our legal rights or for the purpose of legal proceedings.
In some circumstances, we may also process your personal information where we have received your consent. For example, depending where you are located, in order to send you marketing materials. Where processing is based on your consent, you have the right to withdraw that consent at any time.
We do not “sell” or “share” your personal or sensitive personal information as each of these terms is defined under the California Consumer Privacy Act (CCPA).
How Long We Retain Personal Information:
We will only retain your personal information for as long as necessary to fulfil the purpose for which it was collected, or for additional periods where legal/regulatory obligations mandate that we retain your personal information or where it is necessary for the purposes of our other legitimate interests. The applicable retention period will depend on various factors, such as any legal or regulatory requirements to maintain records to which we or our service providers are subject. When deciding how long to retain your personal information, 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 and whether we can achieve those purposes through other means. We may also retain your personal information to investigate or defend against potential legal claims in accordance with the limitation periods of countries where legal action may be brought.
How We Gather Personal Information:
We obtain personal information directly from you, including personal information that you provide to us when you make use of the Website, and when you apply for, access and use our and our business associates’ financial products and services - whether in person, by telephone or electronically. We may verify this personal information or collect additional personal information from third parties, including consumer reporting agencies or other public sources.
We may also obtain some of your information indirectly, from a variety of sources, such as your joint account holder(s), and / or our service providers, such as vendors providing anti-money laundering and sanctions checking databases.
Disclosure of Personal Information:
We may disclose your personal information to certain recipients, including as detailed below:
a) Other affiliates: We may share your personal information with our affiliates for direct marketing purposes, such as offers of products and services to you by us or our affiliates. If you are a new client and are not resident in the European Union, we can begin sharing your personal information with our affiliates for direct marketing purposes 30 days from the date of this Notice. We may also disclose personal information about your transactions and experiences with us to our affiliates for their everyday business purposes.
We do not share your personal information with non-affiliates for them to market their own services to you. For example, we do not sell customer lists and we will not sell your name to a catalogue company or telemarketer. Moreover, it is our policy to require all third parties that are to receive any personal information to sign confidentiality agreements.
b) Transfers to service providers: We may disclose personal information to other companies or third party service providers (e.g., attorneys, accountants, auditors or other professional advisors) (i) to enable them to provide business services for us, such as performing computer related or data
maintenance or processing services for us, (ii) to facilitate the processing of transactions requested by you, (iii) to assist us in offering our or other companies’ products and services to you, or (iv) for reporting purposes.
c) Disclosures to third parties: We may share your personal information with other third parties such as governmental agencies and regulators (e.g., tax authorities), law enforcement, social insurance carriers or to third parties in the event Eagle Capital is involved in a merger, restructuring, reorganization or business transfer, including any (or any proposed) assignee, transferee, or successor in title to the whole or any relevant part of our business, and their respective officers, employees, agents and advisers. Such transfers are made in order to comply with our legal obligations, including the prevention of fraud or other financial crime, and for our legitimate interests or those of a third party to ensure the effective operation of our business. You can ask for further information in relation to these third parties by contacting us.
d) Other disclosures: We may share your personal information if the disclosure is required by law or regulation, or court or administrative order having force of law, or is required to be made to any of our regulators, or as necessary for us to establish, exercise or defend against a legal claim.
In any case where we share your personal information with a third party data controller (including, as appropriate, counterparties to transactions on your account), the use by that third party of the personal information will be subject to the third party’s own privacy policies.
How We Protect Personal Information: We limit access to your personal information to only those employees, agents and contractors who are authorized to access your data when there is an appropriate reason to do so, such as to administer or offer our products or services. We also maintain physical, electronic and procedural safeguards designed to protect your personal information. Despite the security measures that we have put in place, no such measures can guarantee security or protect against unauthorized activity.
Cookies: Cookies are small text files that are stored on your device (computer, tablet, or mobile phone) when you visit a website. Cookies can store information about your preferences and other information which you need when you visit our website. Eagle Capital utilizes Google Analytics as well as session cookies in order to gather certain information and enhance your user experience on our Website. For more information, please see our Cookie Policy.
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. We do not currently recognize or respond to browser-initiated DNT signals.
Additional Information for Residents of the United Kingdom (UK) and European Economic Area (EEA): To the extent that you are resident in the UK or European Union, we will also comply with the following additional requirements under the General Data Protection Regulation (GDPR) when processing your personal information:
1. International Transfers:
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 UK or 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.
2. Your Rights.
You have certain rights under the GDPR and other applicable data protection laws in respect of the personal information we hold and which you may exercise. These rights are:
- to request access to your personal information;
- to request rectification of inaccurate or incomplete personal information;
- to request erasure of your personal information;
- to restrict the processing of your personal information;
- to object to our use of your personal information;
- where relevant, to request the portability of your personal information;
- where you have given consent to the processing of your personal information, to withdraw your consent; and
- to lodge a complaint with the competent supervisory authority.
Your rights will in each case be subject to the restrictions set out in applicable data protection laws, including the GDPR. Further information on these rights, and the circumstances in which they may arise in connection with our processing of your personal information, can be obtained by contacting us using the contact information below.
3. Automated Decision Making
We do not use automated processing, including profiling, to make decisions that will have either legal or material effects on the individuals from whom we collect and process personal information.
Additional Information for Residents of California: To the extent that you are a resident of California, this section supplements the above Privacy Policy with respect to specific obligations and rights granted under the California Consumer Privacy Act of 2018 as amended and expanded by the California Privacy Rights Act of 2020 (together, the “CCPA”) to natural person California residents and provides information regarding how such California residents can exercise their rights under the CCPA. 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.
1. Categories of Personal Information We Collect and Disclose:.
Within the last twelve (12) months, we have collected the categories and types of personal information set forth in the “Personal Information We Collect” section of this Privacy Policy and from the sources identified in the “How We Gather Personal Information” section. We have disclosed such personal information to the parties identified in the “Disclosure of Personal Information”
2. Your Rights
Subject to certain exceptions and limitations, you may have certain rights under the CCPA in respect of the personal information we hold and which you may exercise. These rights are:
Deletion Rights: You have the right to request that we delete any of your personal information that we retain, subject to certain exceptions, including, but not limited to, our compliance with U.S., state, local and non-U.S. laws, rules and regulations.
Disclosure and Access Rights: You have the right to request that we disclose to you certain information regarding our collection, use, disclosure and sale of personal information specific to you over the last twelve (12) months. Such information includes:
- The categories of personal information we collected about you;
- The categories of sources from which the personal information is collected;
- Our business or commercial purpose for collecting such personal information;
- Categories of third parties with whom we share the personal information;
- The specific pieces of personal information we have collected about you; and
- Whether we disclosed your personal information to a third party, and if so, the categories of personal information that each recipient obtained.
Additional Rights: Under the CCPA, you may also have the right to:
- Request the correction of any inaccurate personal information maintained by us about you.
- Request that we limit the use and disclosure of your sensitive personal information in certain circumstances.
- Choose to opt-out of the sale of personal information or the sharing of personal information for cross-context behavioral advertising. Currently, however, we do not sell or share personal information as defined under the CCPA.
Your rights will in each case be subject to the restrictions set out in the CCPA. To exercise these rights or for further information on these rights, and the circumstances in which they may arise in connection with our processing of your personal information, please contact us using the contact information below.
We will not discriminate against any consumer who exercises the rights set forth in this privacy notice.
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.
3. Verifying Your Identity
If you make a request related to personal information about you, we will need to verify your identity. For example, we may request that you match specific pieces of information you have provided to us previously to ensure that you are the individual whose personal information is the subject of the request.
4. Authorized Agent
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.
Accessibility Information: For consumers with disabilities who need to access this policy in an alternative format, please contact compliance@eaglecap.com.
Updates to Personal Information: We will use reasonable efforts to keep your personal information up to date. However, you will need to notify us without undue delay in the event of any change in your personal circumstances, or if you believe any of the information we hold about you is inaccurate or incorrect, so that we can keep the personal information up to date.
Third-Party Links
The Website may contain links to third-party websites, products and services. These third-party websites and services have separate and independent privacy policies, which we encourage you to read. We have no responsibility or liability for the content and activities of such linked sites.
Children’s Privacy
The Website is not directed toward children under the age of 18. We do not promote our products or services online to minors, and we do not intentionally knowingly collect, sell, or share any personally identifiable information from any person under 18. If we become aware of having collected personal information from children under the age of 18 without valid consent, including as applicable from their respective parents or guardians, we will delete is as soon as practicable.
Further Information: We reserve the right to change this Privacy Policy at any time. Upon any material change to this Privacy Policy, we will provide an updated notice to you. Changes to this Privacy Policy are effective when they are posted on our website.
Contact Us:
In order to make a query, raise a concern, exercise your data protection rights or for any other reason related to this Privacy Policy, please contact us using the below contact details:
Telephone
+1 (212) 293-4040 (for CCPA related inquiries, please call +1 (877) 313-0155)
Address
65 East 55th Street, 26th Fl New York, NY 10222