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.

Scope & Applicability

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.

Categories of Personal Information Collected

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

Purposes of Collection

We collect the categories of personal information listed above for the following business purposes:

  • Responding to inquiries about our firm, fund strategies, and the Cap-U Fuel Innovation 100 offering
  • Verifying accredited-investor or qualified-purchaser status for access to 506(c) offering materials
  • Servicing existing clients and administering fund subscriptions, distributions, and reporting
  • Complying with legal and regulatory requirements, including anti-money laundering (AML), know-your-customer (KYC), tax, and SEC/state securities obligations
  • Operating, securing, and improving the Website
  • Preventing fraud and detecting unauthorized access

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.

Sources of Information

We collect personal information from the following sources:

  • Directly from you — through forms, email, phone, or other communications
  • Automatically — through cookies, server logs, and web analytics (Google Analytics)
  • From third-party service providers — such as accreditation-verification providers who confirm investor status
  • From affiliates — such as EB5 United, where operationally necessary
  • From public records and regulatory sources — for compliance and verification

Disclosure of Personal Information to Third Parties

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:

  • Service providers — Website hosting, email transmission, Google Analytics, accreditation-verification providers, fund administrators, transfer agents, custodians, auditors, tax preparers, and legal counsel
  • Affiliates — including EB5 United, where operationally necessary
  • Regulators and legal authorities — where required by law or regulation

No Sale; No Sharing for Cross-Context Behavioral Advertising

Capital United does not "sell" personal information and does not "share" personal information for cross-context behavioral advertising, as those terms are defined under CCPA/CPRA. We do not operate a do-not-sell/share opt-out because no sale or sharing occurs. We have not knowingly sold or shared the personal information of minors under 16.

Retention Periods

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.

Your California Rights

Subject to applicable exceptions (including recordkeeping obligations imposed by federal securities laws), California residents have the following rights:

  • Right to know — request disclosure of the categories and specific pieces of personal information we have collected about you, the categories of sources, the business purposes, and the categories of third parties with whom we share that information
  • Right to delete — request deletion of personal information we have collected from you, subject to regulatory exceptions
  • Right to correct — request correction of inaccurate personal information
  • Right to limit use of sensitive personal information — request that we limit use of sensitive personal information to purposes specified under CCPA/CPRA
  • Right to opt out of sale or sharing — we do not sell or share personal information for cross-context behavioral advertising, so no opt-out is necessary
  • Right to non-discrimination — you will not be discriminated against for exercising any of these rights
  • Right to authorize an agent — you may designate an authorized agent to make requests on your behalf (we will require written verification of authorization)

Sensitive Personal Information

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).

Exercising Your Rights

To exercise any of the rights described above, please submit a request using one of the following methods:

  • Email: contact@capunited.com with the subject line "CCPA Request"
  • Mail: Capital United, LLC — Attention: Chief Compliance Officer, 258 San Agustin, Apartment G, Puerta de Tierra, San Juan, PR 00901

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.

Contact

For questions about this Notice or about how we handle personal information of California residents:

Privacy Inquiries — California

Capital United, LLC

Attention: Chief Compliance Officer

258 San Agustin, Apartment G, Puerta de Tierra, San Juan, PR 00901

Email: contact@capunited.com