Disclosures and rights for California residents under the CCPA/CPRA.
This CCPA Notice at Collection supplements the Capital United Privacy Policy and is provided to California residents pursuant to the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 ("CCPA/CPRA"). It describes the categories of personal information we collect, the purposes for which we use that information, and the rights California residents have regarding that information.
This Notice applies to California residents who visit capunited.com or otherwise interact with Capital United, LLC ("Capital United," "CapU," "we," "us," or "our") as prospective or existing investors. It applies in addition to the protections afforded by federal financial-privacy laws, including the Gramm-Leach-Bliley Act and Regulation S-P under the Investment Advisers Act of 1940. Information collected and processed for the purpose of providing a financial product or service under those laws may be exempt from certain CCPA/CPRA provisions.
In the 12 months preceding the date of this Notice, we have collected the following categories of personal information about California residents:
| Category (CCPA §1798.140) | Examples | Collected |
|---|---|---|
| Identifiers | Name, email, phone, postal address, IP address | Yes |
| Customer records (Cal. Civ. Code §1798.80(e)) | Contact information, employer, financial-suitability information provided for accreditation verification | Yes — for prospects and clients |
| Commercial information | Records of investor communications, subscription history (for clients) | Yes — for clients |
| Internet / network activity | Pages visited, referring URL, device and browser data, cookie IDs | Yes |
| Geolocation | Approximate (country/region) location derived from IP address | Yes |
| Professional or employment information | Job title, employer, business address (if provided) | Yes — if provided |
| Inferences | Inferred investor interests based on interactions with us | Limited |
| Sensitive personal information | Government identifiers, financial account details (for onboarded clients only, subject to Reg S-P) | Only from clients, as required |
| Biometric / genetic / health | — | No |
| Precise geolocation | — | No |
| Audio / electronic / visual surveillance | — | No |
We collect the categories of personal information listed above for the following business purposes:
We do not use personal information for cross-context behavioral advertising, profiling for targeted advertising, or for any purpose materially incompatible with the purposes disclosed here without providing an updated notice.
We collect personal information from the following sources:
In the 12 months preceding this Notice, we have disclosed the categories of personal information listed above to the following categories of recipients, for the business purposes described:
We retain personal information for as long as reasonably necessary to fulfill the purposes for which it was collected and to comply with legal, regulatory, tax, accounting, and recordkeeping requirements. As a state-registered investment adviser, we are required to retain certain records for a minimum of five years under Rule 204-2 of the Investment Advisers Act of 1940. Additional retention may be required under applicable tax laws. When no longer required, personal information is securely deleted or de-identified.
Subject to applicable exceptions (including recordkeeping obligations imposed by federal securities laws), California residents have the following rights:
We collect sensitive personal information (such as government identifiers and financial-account details) only from onboarded clients, and only to the extent necessary to provide investment advisory services, process subscriptions and distributions, and comply with AML/KYC, tax, and securities laws. We do not use or disclose sensitive personal information for purposes beyond those permitted under CCPA/CPRA §1798.121(a).
To exercise any of the rights described above, please submit a request using one of the following methods:
We will acknowledge receipt of your request within 10 business days and respond substantively within 45 calendar days (with one 45-day extension if reasonably necessary, and with notice to you). To protect your information, we may take reasonable steps to verify your identity — typically by matching information you provide against information we already hold — before fulfilling a request. We cannot respond to requests where we are unable to verify that you are the person about whom the information was collected.
If you use an authorized agent, we will also require written proof that you authorized the agent to act on your behalf and, for certain requests, direct verification of your identity with us.
For questions about this Notice or about how we handle personal information of California residents:
Capital United, LLC
Attention: Chief Compliance Officer
258 San Agustin, Apartment G, Puerta de Tierra, San Juan, PR 00901
Email: contact@capunited.com