This Privacy Policy explains how ICA Advisors LLC, doing business as Innovating Capital (“Innovating Capital,” “we,” “us” or “our”) collects, uses and shares personal information in connection with innovating.capital (the “Site”) and when you correspond with us.
If you are an investor or prospective investor in a fund or other vehicle managed or advised by Innovating Capital or its affiliates (a “Fund”), our separate Investor Privacy Notice, provided with that Fund’s documents, also applies and governs if the two conflict.
1. Information we collect
Information you give us
The Site has no forms or accounts. If you email us, for example at info@innovating.capital or ir@innovating.capital, we receive your name, email address and anything else you choose to include, such as your company, role, phone number and the content of your message and any attachments.
Information collected automatically
When you visit the Site, our hosting provider automatically records standard technical information such as your IP address, browser type, device and operating system, the pages you request, the referring page and the date and time of your visit. We use this information to deliver and secure the Site.
Cookies and analytics
The Site does not use cookies, analytics, advertising or other tracking technologies. Because the Site does not track you, it does not respond differently to Do Not Track or Global Privacy Control signals.
Information from other sources
In the ordinary course of business we may receive information about you from other sources, such as people who introduce you to us, your company and publicly available professional sources.
2. How we use information
We use personal information to:
- respond to your enquiries and communicate with you;
- evaluate and manage potential and existing investments, partnerships and other business relationships;
- operate, maintain and secure the Site;
- comply with legal, regulatory and recordkeeping obligations, including those that apply to investment advisers; and
- establish, exercise or defend legal claims.
We do not use information collected through the Site for automated decision-making that produces legal or similarly significant effects.
Legal bases (EEA and UK)
Where the EU or UK General Data Protection Regulation applies, we rely on our legitimate interests in running our business and responding to you, compliance with our legal obligations, steps taken at your request before entering into a contract or performance of a contract, and, where required, your consent.
3. How we share information
We do not sell personal information, and we do not share it for cross-context behavioral advertising. We may disclose it to:
- service providers that host the Site or provide email, IT and other services on our behalf, under obligations to protect it;
- our affiliates and the Funds, where relevant to your enquiry;
- our professional advisers, such as lawyers, accountants and auditors;
- regulators, courts, law enforcement and other authorities, where required by law or to protect our rights; and
- a buyer or successor in connection with a merger, financing, acquisition or other corporate transaction.
4. International transfers
We are based in the United States, and personal information we receive is processed there. Data-protection laws in the United States may differ from those where you live. Where the law requires, we use appropriate safeguards for transfers, such as standard contractual clauses.
5. Retention
We keep personal information for as long as we need it for the purposes above, including to meet legal, regulatory and recordkeeping requirements, and then delete or de-identify it.
6. Security
We use reasonable administrative, technical and physical safeguards to protect personal information. No method of transmission or storage is completely secure, so please do not email us sensitive information such as government identification or financial account numbers.
7. Your choices and rights
Depending on where you live, you may have the right to know about and access the personal information we hold about you, to correct or delete it, to object to or restrict certain processing, to receive a portable copy and to withdraw consent where we rely on it. You can ask us to stop emailing you at any time.
To make a request, email info@innovating.capital. We may need to verify your identity before responding, and we will respond within the time the law requires. We will not discriminate against you for exercising your rights. If you are in the European Economic Area or the United Kingdom, you may also complain to your local data-protection authority.
8. Children
The Site is not directed to children, and we do not knowingly collect personal information from anyone under 18. If you believe a child has given us personal information, contact us and we will delete it.
9. Other websites
The Site may link to third-party websites and services, such as LinkedIn and X, which have their own privacy policies. We are not responsible for their practices.
10. Changes to this Privacy Policy
We may update this Privacy Policy from time to time. The “Last updated” date at the top shows when it last changed. Where the law requires, we will give you additional notice.
11. Contact
ICA Advisors LLC d/b/a Innovating Capital · Attn: Chief Compliance Officer · 20 West 22nd Street, Suites 1609–1610, New York, NY 10010 · info@innovating.capital