Privacy Policy

1. Introduction

Invest LLC ("we", "us", "our") operates a private investment club. This policy explains what personal information we collect, why we collect it, who we share it with, how long we keep it, and what rights you have in relation to it.

Data controller: Invest LLC, a limited liability company organised under the laws of the State of California

Address: 10880 Wilshire 94024 Los Angeles

Privacy contact: hannane@investllc.co

This policy applies to our website and member platform. It does not apply to third-party websites, nor to the independent professionals in our expert network, who process your information under their own policies.

2. Information we collect

2.1 Information you provide when you create a free account:

Full name

Email address

Country of residence

How you heard about Invest LLC

What draws you to Invest LLC (optional)

2.2 Additional information you provide when you apply for paid membership:

The capacity in which you would invest (as an individual, jointly, through a company, family office, trust, or pension)

Whether you have previously invested in private, illiquid assets

The amount you anticipate investing

Your intended timeframe for deploying capital

The sectors you are interested in

Your investor status declaration, and the basis on which you qualify

2.3 Payment information. Where you purchase a paid membership, our payment processor collects and processes your payment details. We receive confirmation of payment and a record of your subscription history. We do not store complete payment card numbers.

2.4 Banking information. Where you make an investment, we collect the bank account details necessary to pay distributions and returns of capital to you.

2.5 Investment records. Where you make an investment, we hold records of the amounts subscribed, the vehicles in which you hold a position, distributions paid to you, and any tax documentation required in connection with that investment.

2.6 Verification information. Where required in connection with an investment or by applicable law, we may collect identity documents, proof of address, and information as to the source of funds.

2.7 Communications. We retain a record of correspondence between you and Invest LLC, including emails, notes of calls, questions submitted in relation to content, and event registrations.

2.8 Technical information collected automatically:

Device type, browser type, and operating system

IP address

Pages viewed, content accessed, and progress through educational material

Login times and session activity

The source from which you arrived at the Platform

3. Why we use your information, and our legal basis

Where you are located in the European Economic Area or the United Kingdom, the General Data Protection Regulation requires us to identify a lawful basis for each purpose for which we process your information.

Purpose

Lawful basis

Creating and administering your account

Performance of a contract

Providing member content, events, and services

Performance of a contract

Processing payment and managing your subscription

Performance of a contract

Determining which opportunities may lawfully be shown to you

Legal obligation; legitimate interests

Administering any investment you make, including paying distributions

Performance of a contract

Verifying identity and source of funds where required

Compliance with a legal obligation

Maintaining records required under securities and tax law

Compliance with a legal obligation

Understanding how the Platform and its content are used, and improving them

Our legitimate interests

Sending the member briefing and service communications

Performance of a contract; legitimate interests

Sending marketing communications to non-members

Consent

Detecting fraud and maintaining the security of the Platform

Our legitimate interests

Where we rely on legitimate interests, we have assessed whether those interests are outweighed by your rights and freedoms. You may object to such processing at any time (see Section 8).

4. Who we share your information with

We do not sell your personal information, and we do not share it for cross-context behavioural advertising.

We share personal information with:

Service providers acting on our instructions — including payment processing, email delivery, website and platform hosting, video delivery, and analytics. These providers may use the information only to provide their service to us.

Our professional advisers — lawyers, accountants, and auditors, where necessary.

Investment vehicles and their administrators — where you make an investment, the entity in which you invest and any party administering it.

Independent professionals in our expert network — only where you ask us to make an introduction, and only such information as is necessary to make it.

Regulators, courts, and public authorities — where required by law, court order, or a legitimate regulatory request.

A successor entity — in connection with a reorganisation, merger, or sale of the business, subject to this policy continuing to apply.

We may also share aggregated or anonymised information that does not identify you.

5. International transfers

Invest LLC is established in the United States. If you are located in the European Economic Area or the United Kingdom, your personal information will be transferred to and processed in the United States.

Where we transfer personal information out of the EEA or the UK, we rely on the European Commission’s Standard Contractual Clauses (and, for United Kingdom transfers, the UK International Data Transfer Addendum) to ensure an appropriate level of protection. We have assessed the circumstances of those transfers and apply additional technical and organisational safeguards where appropriate.

You may request a copy of the safeguards we rely upon by writing to hannane@investllc.co.

6. How long we keep your information

Information

Retention period

Free account and profile information

For as long as your account is active, and for two years thereafter

Paid membership records

For as long as your membership is active, and for seven years thereafter

Investment records, subscription agreements, and tax documentation

For at least seven years following the conclusion of the relevant investment, as required by securities and tax law

Investor status declarations

For the duration of any related investment, and for the applicable statutory record-keeping period thereafter

Banking details used for distributions

For as long as you hold an investment through Invest LLC, and for seven years thereafter

Identity and source of funds records

As required by applicable anti-money-laundering law

Marketing preferences

Until consent is withdrawn, together with a record of the withdrawal

Technical and usage information

Twenty-four months

Certain records must be retained after your account is closed because securities, tax, and anti-money-laundering law require it.

7. Security

We apply technical and organisational measures appropriate to the sensitivity of the information we hold, including encryption in transit, access controls, and restriction of access to personnel who require it. Investment documentation and data room materials are held behind authenticated access.

No system is entirely secure. Where a personal data breach occurs that is likely to result in a risk to your rights and freedoms, we will notify the relevant supervisory authority within 72 hours where the General Data Protection Regulation requires it, and will notify you directly where required by applicable law.

8. Your rights

8.1 If you are located in the European Economic Area or the United Kingdom, you have the right to:

access the personal information we hold about you;

rectify information that is inaccurate or incomplete;

erase your information, where no legal obligation requires us to retain it;

restrict our processing of your information in certain circumstances;

receive your information in a structured, commonly used, machine-readable format;

object to processing carried out on the basis of legitimate interests, and to direct marketing at any time;

withdraw consent where we rely on it, without affecting the lawfulness of processing carried out beforehand; and

lodge a complaint with your local data protection supervisory authority.

8.2 If you are a resident of California:

Under the California Consumer Privacy Act, as amended by the California Privacy Rights Act, you have the right to know what personal information we collect and the purposes for which it is used, to request its deletion, to correct inaccurate information, to opt out of the sale or sharing of personal information (we do not sell or share personal information), to limit the use of sensitive personal information, and not to be discriminated against for exercising any of these rights.

8.3 Exercising your rights:

Please write to hannane@investllc.co. We will respond within thirty days where the General Data Protection Regulation applies, and within forty-five days where the California Consumer Privacy Act applies. We may need to verify your identity before acting on a request. There is no charge unless a request is manifestly unfounded or excessive.

9. Cookies and similar technologies

We use the following categories of cookies and similar technologies:

Strictly necessary — required for login, security, and the basic operation of the Platform. These cannot be disabled.

Functional — to remember your preferences and your progress through educational content.

Analytics — to understand which content is used and where the Platform can be improved.

We do not use advertising cookies or cross-site tracking technologies.

If you are located in the European Economic Area or the United Kingdom, we will ask for your consent before setting any non-essential cookie, and you may change your preferences at any time through the cookie settings link on the Platform.

10. Marketing communications

If you are a member, we send you the member briefing and communications relating to your membership and any investments you hold. You may opt out of non-essential communications at any time.

If you are not a member, we send marketing communications only where you have consented to receive them. Every such communication contains an unsubscribe link.

11. Children

The Platform is not directed at persons under the age of 18, and we do not knowingly collect personal information from children. If we become aware that we have done so, we will delete it.

12. Changes to this policy

We may update this policy from time to time. Where changes are material we will notify members by email or through the Platform before they take effect. The date shown at the top of this policy indicates the current version.

13. Contact

Privacy enquiries, or to exercise any of the rights described above: hannane@investllc.co

By post:

Invest LLC

10880 Wilshire blvd 94024 Los Angeles