Privacy Policy
Effective Date: January 1, 2026 · Last Updated: May 21, 2026 · Version 1.0
Table of Contents
This Privacy Policy describes how Apex Capital Fund LLC ("Apex Capital," "we," "us," or "our"), headquartered at One World Trade Center, New York, NY 10007, collects, uses, and protects your personal information. By accessing our website or services, you agree to the practices described herein.
01 Information We Collect
We collect information to provide, improve, and personalize our investment management services. The types of information we collect include:
Information You Provide Directly
Identity & Contact: Full name, email address, phone number, mailing address, date of birth, and government-issued identification documents.
Financial Information: Accredited investor status documentation, net worth declarations, annual income, bank account details, and investment history as required for KYC/AML compliance.
Communications: Messages, inquiries, and correspondence you submit via our contact forms or email.
Consent Records: Records of your SMS and marketing consent choices as required by applicable law.
Information We Collect Automatically
Device & Usage Data: IP address, browser type and version, operating system, referring URLs, pages visited, time spent on site, and click data.
Cookies & Tracking Technologies: Session cookies, persistent cookies, pixel tags, and similar technologies. See our Cookie Policy for details.
Blockchain Data: Wallet addresses and on-chain transaction data associated with our token-based investment products on Ethereum Mainnet, Arbitrum, Base, or Avalanche Evergreen networks.
Information from Third Parties
KYC/AML verification providers and identity verification services.
Financial data aggregators and credit reporting agencies as permitted by law.
Blockchain analytics providers for compliance monitoring.
02 How We Use Your Information
We use the information we collect for the following purposes:
Investment Services: To process your investment applications, manage your account, process distributions via smart contract, and provide investor reports.
Compliance & Legal Obligations: To conduct KYC/AML screening, verify accredited investor status, comply with SEC and FINRA regulations, and satisfy tax reporting requirements (including FATCA and Form 1099).
Communications: To send account notifications, transaction confirmations, performance reports, and responses to your inquiries.
Marketing (With Consent): To send newsletters, fund updates, and promotional materials if you have opted in. You may opt out at any time.
SMS Communications: To send transactional and promotional text messages where you have provided explicit consent. Text STOP to opt out at any time.
Security & Fraud Prevention: To detect, investigate, and prevent fraudulent transactions and unauthorized access.
Service Improvement: To analyze usage patterns, improve website functionality, and enhance the investor experience.
03 Information Sharing
Apex Capital Fund does not sell, rent, or trade your personal information to third parties for their marketing purposes. We may share your information only in the following circumstances:
Service Providers: With trusted third-party vendors who assist in operating our business (custodians, auditors, legal counsel, KYC providers, cloud infrastructure providers), subject to confidentiality agreements.
Regulatory & Legal Compliance: With regulators (SEC, FINRA, IRS), law enforcement, or courts as required by applicable law, subpoena, or court order.
Business Transfers: In connection with a merger, acquisition, or sale of all or substantially all of our assets, with appropriate confidentiality protections.
Investor Consent: In any other circumstance with your explicit prior consent.
All third-party service providers who access your data are contractually bound to use it only for the purposes we specify and to implement appropriate security measures.
04 Data Security
We implement institutional-grade security measures to protect your personal information, including:
AES-256 encryption for data at rest and TLS 1.3 for data in transit.
Multi-factor authentication for all investor portal access.
Regular third-party security audits and penetration testing.
Strict access controls and role-based permissions for staff.
Smart contract audits by reputable third-party security firms.
Incident response and breach notification procedures compliant with applicable state and federal requirements.
While we take every reasonable precaution, no method of electronic transmission or storage is 100% secure. In the event of a data breach that affects your rights or freedoms, we will notify you as required by law.
05 Your Rights & Choices
Depending on your jurisdiction, you may have the following rights with respect to your personal information:
Access: Request a copy of the personal information we hold about you.
Correction: Request correction of inaccurate or incomplete data.
Deletion: Request deletion of your personal data, subject to legal retention requirements.
Portability: Receive your data in a structured, machine-readable format.
Opt-Out: Opt out of marketing communications at any time via the unsubscribe link in any email or by texting STOP to any SMS message.
Restriction: Request that we restrict processing of your data in certain circumstances.
California Residents (CCPA): You have the right to know, delete, and opt out of the sale of personal information. We do not sell personal information.
EU/UK Residents (GDPR/UK GDPR): You have the right to lodge a complaint with your local supervisory authority.
To exercise any of these rights, please contact us at [email protected]. We will respond within 30 days.
06 Cookies & Tracking
We use cookies and similar tracking technologies to enhance your experience on our website. For detailed information about the types of cookies we use, how we use them, and how to manage your preferences, please refer to our Cookie Policy.
07 International Data Transfers
Apex Capital Fund is headquartered in the United States. If you access our services from outside the United States, your information may be transferred to, stored, and processed in the U.S. and other countries where our service providers operate.
For transfers from the European Economic Area (EEA), United Kingdom, or Switzerland, we rely on appropriate safeguards including Standard Contractual Clauses (SCCs) approved by the European Commission. By using our services, you acknowledge these transfers.
08 Data Retention
We retain your personal information for as long as necessary to fulfill the purposes described in this policy, and as required by applicable law:
Investor Records: Retained for a minimum of 7 years following the end of your investment relationship, as required by SEC and FINRA regulations.
KYC/AML Records: Retained for at least 5 years after the termination of a business relationship, per FinCEN requirements.
Marketing Data: Retained until you opt out and for a reasonable period thereafter.
Website Usage Data: Retained for up to 26 months.
Upon expiration of the applicable retention period, we securely delete or anonymize your information.
09 Children's Privacy
Our services are intended exclusively for accredited investors who are adults (18 years of age or older). We do not knowingly collect personal information from individuals under the age of 18. If we become aware that we have inadvertently collected information from a minor, we will delete it promptly. If you believe a minor has submitted information to us, please contact us at [email protected].
10 Contact Us
For privacy-related inquiries, requests, or concerns, please contact our Privacy Officer:
Mailing Address
Apex Capital Fund LLC
One World Trade Center
New York, NY 10007
[email protected]
We may update this Privacy Policy from time to time. Material changes will be communicated via email to registered investors and by posting a notice on our website. Your continued use of our services after such updates constitutes acceptance of the revised policy.
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Contact Information
Office Location
Apex Capital Investments, LLC
4230 Lafayette Center Dr., Suite A
Chantilly, VA 20151
Apex Capital is built for investors who understand that digital asset markets are structurally inefficient, who have a 3-year time horizon aligned with our lock-up, and who want professional active management rather than passive exposure to crypto volatility.
© 2026 Apex Capital Fund. All rights reserved.