Capital United, LLC ("Capital United," "CapU," "we," "us," or "our") respects your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard information when you visit capunited.com (the "Website") or otherwise interact with us as a prospective or existing investor. Capital United is a state-registered investment adviser (CRD #285616), with its principal office in Puerto Rico and additional registrations in Florida, Oregon, and Wisconsin; the firm is also subject to Regulation S-P ("Reg S-P") and the Gramm-Leach-Bliley Act, which impose additional obligations regarding nonpublic personal information of our clients.

Scope & Introduction

This Privacy Policy applies to information collected through our Website, through email and phone communications, and through written correspondence with Capital United. It does not apply to third-party websites, applications, or services that may link to or from our Website, even if operated by our affiliates.

If you become a client of Capital United by entering into an investment advisory agreement or subscribing to a fund we advise, additional notices and disclosures — including our formal Reg S-P Privacy Notice and Form ADV Part 2 — will be provided at the time of onboarding and on an annual basis thereafter. The firm's current Form ADV and disclosure history are publicly available via the SEC's Investment Adviser Public Disclosure (IAPD) website at adviserinfo.sec.gov/firm/summary/285616.

Information We Collect

Information You Provide Directly

When you contact us, request information, or express interest in our fund strategies, we may collect:

  • Name, email address, and phone number
  • Employer, job title, and business address (if provided)
  • Investor type (e.g., accredited investor status, qualified purchaser status) and, for verification, documentation reasonably required to confirm such status
  • Communications you send us, including email content, meeting notes, and inquiry details
  • Any information voluntarily submitted through our contact forms or Existing Investor Portal

Information Collected Automatically

Our Website is built on the WordPress platform. When you visit, the following limited technical information may be automatically collected to serve the Website and measure aggregate usage:

  • IP address and approximate geographic location (country/region level)
  • Browser type, operating system, device type, and screen resolution
  • Pages visited, timestamps, referring URL, and basic usage patterns
  • Session cookies necessary for Website functionality

Google Analytics

We use Google Analytics, a web analytics service provided by Google LLC, to understand how visitors use our Website in aggregate. Google Analytics uses cookies and similar technologies to collect information such as the pages you view, the time you spend on each page, the links you click, and your general geographic location. This information is used to produce statistical reports on Website activity and to help us improve the Website.

The information generated by Google Analytics is transmitted to and stored by Google on servers that may be located outside your country of residence. Google may use this information on our behalf to evaluate your use of the Website, compile reports on Website activity, and provide other services relating to Website activity and internet usage. Google's privacy practices are described at policies.google.com/privacy.

You can opt out of Google Analytics tracking at any time by installing the official Google Analytics Opt-Out Browser Add-on, or by disabling cookies in your browser settings.

Note: Beyond Google Analytics and standard WordPress platform cookies, Capital United does not use Facebook Pixel, LinkedIn Insight, retargeting pixels, or other third-party advertising trackers on this Website. We do not build advertising profiles or engage in cross-context behavioral advertising.

Information from Third Parties

For investors subscribing to our 506(c) offering (Cap-U Fuel Innovation 100), we may receive accreditation verification confirmations from independent verification providers (such as licensed attorneys, certified public accountants, or registered broker-dealers). These providers collect documentation directly from you under their own privacy terms; we receive only the verification confirmation, not underlying financial documents, unless you choose to share them with us directly.

How We Use Information

We use the information we collect for the following purposes:

  • Responding to inquiries — replying to questions about our firm, our fund strategies, and our 506(c) offering
  • Investor communications — providing information about Capital United, subject to your verified accredited-investor status where applicable
  • Accreditation verification — confirming that prospective investors meet the accredited investor definition under Rule 501 of Regulation D before providing access to 506(c) offering materials
  • Servicing existing investors — administering investor accounts, processing subscriptions and distributions, and providing reporting
  • Legal and regulatory compliance — complying with applicable securities laws, anti-money laundering rules, KYC/AML verification, tax reporting, and responses to regulatory requests
  • Website operation and security — maintaining the Website, detecting fraud or unauthorized access, and protecting our systems

We do not sell, rent, or lease your personal information to third parties for their marketing purposes, and we do not use your information for advertising profiling.

How We Share Information

We may share information in the following limited circumstances:

Service Providers

We share information with third-party service providers who perform services on our behalf under confidentiality obligations, including:

  • WordPress & hosting provider — Website platform and hosting services
  • Google LLC (Google Analytics) — aggregate website usage analytics
  • Email providers — transmission of communications
  • Accreditation verification providers — confirming accredited investor status
  • Fund administrators, custodians, and transfer agents — for investors who subscribe to a fund
  • Auditors, tax preparers, and legal counsel — in connection with fund administration and compliance

Affiliates

We may share information with affiliates of Capital United, including EB5 United (a separate legal entity), for operational, administrative, and compliance purposes. Such sharing is limited to what is reasonably necessary and is subject to confidentiality obligations.

Legal & Regulatory

We may disclose information where required by law, regulation, legal process, or governmental request, including disclosures to the SEC, FINRA, state securities regulators, the Internal Revenue Service, the Puerto Rico Department of Treasury, and other applicable authorities.

Business Transactions

If Capital United is involved in a merger, acquisition, reorganization, or sale of assets, information may be transferred as part of that transaction, subject to the protections of this Privacy Policy.

Reg S-P Notice Summary: We do not disclose nonpublic personal information about our clients or former clients to nonaffiliated third parties except as permitted or required by law. Our full Reg S-P Privacy Notice is provided to each client at the time of onboarding and annually thereafter.

Cookies & Tracking

Our Website uses the following categories of cookies:

  • Strictly necessary cookies — set by the WordPress platform, required for the Website to function (session cookies, security cookies, load-balancing)
  • Functional cookies — remember settings such as language or region
  • Analytics cookies (Google Analytics) — used to measure aggregate Website usage patterns. These cookies typically include _ga, _gid, and related identifiers. See our Google Analytics section above for details and opt-out instructions.

We do not use third-party advertising cookies, Facebook Pixel, LinkedIn Insight, retargeting cookies, or similar cross-context behavioral advertising technologies on this Website.

You can configure your browser to refuse cookies or to alert you when cookies are being sent. Refusing strictly necessary cookies may cause portions of the Website to malfunction. Disabling analytics cookies will stop Google Analytics collection without impacting Website functionality.

Data Security

We maintain administrative, technical, and physical safeguards reasonably designed to protect the information we collect against unauthorized access, alteration, disclosure, or destruction. These safeguards include:

  • Encryption of the Website via HTTPS/TLS
  • Access controls restricting information to personnel with a legitimate business need
  • Confidentiality obligations imposed on employees and third-party service providers
  • Regular review of security practices in accordance with Reg S-P and industry standards

Despite these safeguards, no method of transmission over the internet or electronic storage is completely secure. We cannot guarantee absolute security. If you have reason to believe your interaction with us is no longer secure, please contact us immediately using the information in Section 12.

Data Retention

We retain information for as long as necessary to fulfill the purposes outlined in this Policy, to comply with legal and regulatory obligations, or to resolve disputes. As a state-registered investment adviser, we are required to retain certain records for a minimum of five years (with the first two years in an easily accessible location) under Rule 204-2 of the Investment Advisers Act of 1940. Certain tax-related records may be retained longer under applicable tax laws.

When information is no longer required, we will securely delete or anonymize it.

Your Rights & Choices

All Users

You may:

  • Opt out of marketing communications at any time by clicking "unsubscribe" in any email or by contacting us directly
  • Request a copy, correction, or deletion of personal information we hold about you, subject to recordkeeping obligations imposed by securities laws
  • Request that we stop sharing your information with affiliates for marketing purposes

California Residents (CCPA/CPRA)

California residents have specific rights under the California Consumer Privacy Act, as amended by the California Privacy Rights Act, including:

  • The right to know what personal information we collect, use, and share
  • The right to request deletion of personal information (subject to regulatory exceptions)
  • The right to correct inaccurate personal information
  • The right to opt out of the sale or sharing of personal information — note: we do not sell or share personal information for cross-context behavioral advertising
  • The right to non-discrimination for exercising these rights

EU/UK Residents (GDPR/UK GDPR)

If you are in the European Economic Area or the United Kingdom, you have additional rights including access, rectification, erasure, restriction of processing, data portability, and the right to object to processing. Our legal basis for processing is typically (i) performance of a contract (for clients), (ii) compliance with legal obligations (for regulatory retention), (iii) legitimate interests (for responding to inquiries and operating the Website), or (iv) consent (where required).

How to Exercise Your Rights

To exercise any of these rights, contact us at contact@capunited.com. We will respond within the timeframe required by applicable law. We may require reasonable verification of your identity before fulfilling a request.

Children's Privacy

Our Website and services are intended for accredited investors and other adult audiences. We do not knowingly collect personal information from individuals under the age of 18. If you believe we have inadvertently collected such information, please contact us and we will delete it.

International Users

Capital United is based in Puerto Rico, United States. Our Website is built on WordPress and hosted through a U.S.-based hosting provider, and we use Google Analytics, which is provided by Google LLC. Data collected through the Website may be processed in the United States and other jurisdictions where our service providers operate. If you access the Website from outside the United States, your information may be transferred to, stored in, and processed in the United States or other countries that may have different data protection laws than your country of residence. By using the Website, you consent to such transfers where permitted by law.

Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. Material changes will be communicated by updating the "Last Updated" date at the top of this page and, where appropriate, by more prominent notice on the Website or direct communication to existing clients. We encourage you to review this Policy periodically.

Contact Us

If you have questions about this Privacy Policy, wish to exercise any of your rights, or need to report a privacy concern, please contact us:

Privacy Inquiries

Capital United, LLC

Attention: Chief Compliance Officer

San Juan, Puerto Rico

Email: contact@capunited.com

General: contact@capunited.com