Last Updated 1, April 2026

Privacy Policy

How DataPower Capital collects, uses, and protects your information

At a glance

DataPower Capital Management, LLC (“DPC,” “we,” or “us”) is a venture capital firm that manages investments through single-asset special purpose vehicles (SPVs). We collect and use your personal information only as needed to manage your investment, comply with regulations, and communicate with you about fund activities.

We collect only what’s necessary to manage your investment and satisfy regulatory requirements.
We never sell your personal information to third parties.
We share data with service providers (such as our fund administrator) only as needed to operate our funds.
You have rights over your data, including access, correction, and deletion, subject to legal and regulatory obligations.
We use industry-standard security to protect your information.
We disclose when we use AI tools in our operations.

Scope & applicability

This Privacy Policy applies to all nonpublic personal information (“NPI”) and personal data collected, received, maintained, or processed by DataPower Capital Management, LLC, and its affiliated entities, including each single-asset SPV we manage.

This Policy governs the information of limited partners (“LPs”), prospective investors, co-investors, portfolio company contacts, website visitors, and any other individuals whose personal information we process in connection with our investment advisory and fund management activities.

Information we collect

We collect the following categories of information in connection with our business activities:

Identity and contact information

Full legal name, mailing address, email address, telephone number, date of birth, citizenship, and government-issued identification numbers as required for investor onboarding, KYC/AML compliance, and tax reporting.

Financial and investment information

Accredited investor qualifications, investment amounts and commitment levels, capital account balances, distribution history, and tax information such as K-1 documents.

Entity and beneficial ownership information

For entity investors: formation documents, beneficial ownership information, authorized signatory details, and entity classification information as required under the Corporate Transparency Act and applicable AML/KYC regulations.

Digital interaction data

When you access our LP portal or website, we may collect login credentials (stored in encrypted form), access logs, IP addresses, browser type, and session data.

Communications

Records of communications between investors and the Firm, including emails and investor relations correspondence, retained as required by SEC recordkeeping obligations.

How we use your information

We use your information for the following purposes:

Fund administration: Processing subscriptions, managing capital calls and distributions, maintaining capital accounts, and generating tax documents.
Regulatory compliance: Fulfilling obligations under SEC regulations, AML/KYC laws, the Corporate Transparency Act, IRS tax reporting, and applicable state securities laws.
Investor relations: Communicating fund performance, distributing reports, providing portal access, and sharing co-investment and new deal opportunities.
Legal and audit: Responding to legal process, cooperating with regulatory examinations, and conducting internal audits.
Security and fraud prevention: Monitoring for unauthorized access, detecting suspicious activity, and protecting the integrity of our systems and investor data.

Third-party sharing

We share NPI with the following categories of service providers, each bound by contractual confidentiality and data protection obligations:

Service provider category	Purpose
Fund administrator	Subscription processing, capital account management, K-1 generation
Banking partner	Fund-level banking operations and wire transfers
Legal counsel	Fund formation, regulatory compliance, and dispute resolution
Auditors and accountants	Annual audits and tax preparation
Technology providers	LP portal operation, CRM, and investor communications

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We may also disclose NPI without investor consent when required by law, regulation, or legal process, including SEC or FINRA examinations, court orders or subpoenas, AML/CTF compliance requirements, and tax authority reporting obligations.

We do not sell your personal information. We do not sell, rent, or trade the personal information of our investors to any third party for marketing or commercial purposes. This applies to all categories of personal information.

Data security

We maintain a comprehensive information security program designed to protect the confidentiality, integrity, and availability of your personal information. Our safeguards include:

Administrative controls: Designated compliance officer responsible for privacy oversight, annual privacy and cybersecurity training for all personnel, and a documented incident response plan.
Technical controls: Encryption of data at rest and in transit, multi-factor authentication for all systems containing NPI, role-based access controls, continuous monitoring and intrusion detection, and regular vulnerability assessments.
Physical controls: Secured storage for physical documents, clean desk policies, and secure disposal through cross-cut shredding.
Vendor oversight: Privacy and security assessments of all third-party service providers with contractual data protection requirements.

Breach notification

In the event of a security incident involving unauthorized access to unencrypted NPI, we will:

Investigate promptly and engage forensic specialists as warranted.
Notify affected individuals without unreasonable delay and within the timeframes required by applicable state and federal law.
Notify regulators including the SEC, state attorneys general, and any other required regulatory bodies within mandated timeframes.
Provide remediation measures, which may include credit monitoring or identity theft protection services, depending on the nature and scope of the incident.

Your privacy rights

Subject to applicable law and our regulatory obligations, you may exercise the following rights:

Access: Request a copy of the personal information we hold about you. We will respond within 30 calendar days or the period required by applicable law.
Correction: Request correction of inaccurate or incomplete personal information.
Deletion: Request deletion of your personal information, subject to our legal and regulatory retention obligations.
Opt out: Opt out of the sharing of your NPI with non-affiliated third parties for purposes beyond those described in this Policy.

To exercise any of these rights, contact us at ir@datapower.vc. We will verify your identity before processing any request.

California residents

If you are a California resident, you have additional rights under the California Consumer Privacy Act and the California Privacy Rights Act (CCPA/CPRA):

Right to know what personal information is collected, used, and disclosed.
Right to opt out of the sale or sharing of personal information. Note: we do not sell personal information.
Right to limit the use of sensitive personal information to purposes necessary to provide our services.
Right to non-discrimination for exercising your privacy rights.

We do not use financial incentive programs tied to personal data.

International investors

For investors located in the European Economic Area or United Kingdom, we process personal data on the lawful bases of contractual necessity, legitimate interests, and legal obligation. You may additionally exercise rights to data portability, restriction of processing, and the right to lodge a complaint with a supervisory authority.

Cross-border data transfers from the EEA or UK to the United States are conducted pursuant to EU Standard Contractual Clauses or other approved transfer mechanisms.

AI & technology

We use artificial intelligence and automated tools in certain aspects of our operations. In the interest of transparency:

Deal analysis: We may use AI-assisted tools for market research and investment analysis. These tools process publicly available information and our own research — not LP personal data.
Communications: AI tools may assist in drafting reports and operational documents. All AI-assisted communications are reviewed by authorized personnel before distribution.
No automated decisions affecting LPs: We do not use automated decision-making or profiling to make decisions that produce legal or similarly significant effects on investors without human review.
No training on LP data: Your personal information is not used to train, fine-tune, or improve any AI or machine learning model without your explicit written consent.

Data retention

We retain personal information for as long as necessary to fulfill the purposes described in this Policy and to comply with our legal and regulatory obligations. General retention principles include:

Fund and subscription documents are retained for the life of the fund plus the period required by SEC and IRS regulations.
KYC/AML records are retained for the period required under the Bank Secrecy Act and USA PATRIOT Act.
Tax documents are retained for the period required by IRS record retention rules.
Investor communications are retained for the period required by SEC books and records rules.
Prospective investor data is retained for a limited period after last contact and deleted upon request.

When personal information is no longer needed, it is securely destroyed using methods appropriate to the data format.

Cookies & analytics

Our website and LP portal may use cookies and similar technologies to:

Maintain your session and authentication state when you are logged in.
Understand how visitors interact with our website to improve its functionality.
Remember your preferences across visits.

We do not use advertising cookies or share cookie data with third-party advertisers. You can control cookie preferences through your browser settings. Disabling cookies may limit your ability to use certain features of our LP portal.

Children’s privacy

Our services are directed exclusively to accredited investors and qualified purchasers. We do not knowingly collect personal information from individuals under the age of 18. If we become aware that we have inadvertently collected such information, we will promptly delete it.

Changes to this policy

We may amend this Policy at any time. When we make material changes:

We will provide advance written notice to affected investors at least 30 days before material changes take effect.
Updated versions will be posted on this page with a revised effective date.
A summary of material changes will accompany any updated Policy.

Contact us

For questions about this Privacy Policy, to exercise your privacy rights, or to report a privacy concern:

DataPower Capital Management, LLC
Attn: Chief Compliance Officer
767 Broadway, #1268, New York, NY 10003
Email: ir@datapower.vc

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