Privacy Policy

Last updated: 04 June 2026

This Privacy Policy explains how Alter SPVs may collect, use, disclose, retain, and protect personal information in connection with this website, investor relations, startup submissions, institutional partnership inquiries, special purpose vehicle review, tokenized interest administration, wallet verification, compliance workflows, and related communications.

This policy is intended to be read together with the Legal Disclosures, Terms of Use, Risk Notice and Offering Disclaimer. If you do not agree with this Privacy Policy, you should not use this website or submit personal information to Alter SPVs.

1. Scope of This Policy

This Privacy Policy applies to personal information processed by or on behalf of Alter SPVs through alterspv.com, email communications, inquiry forms, document requests, investor onboarding, wallet verification, compliance review, tokenized SPV administration, and related business communications.

This policy does not apply to third-party websites, wallets, blockchain explorers, custodians, compliance providers, document platforms, email providers, analytics providers, or other third-party services that maintain their own privacy practices.

2. Who We Are

Alter SPVs provides information relating to private market access infrastructure, dedicated SPV structures, tokenized interest administration, and related portfolio or investor communications. Depending on the context, Alter SPVs may act as a website operator, business contact, prospective transaction counterparty, SPV administrator, compliance coordinator, investor relations contact, or service recipient.

Where a specific SPV, issuer, administrator, manager, compliance provider, custodian, or other entity is identified in definitive documentation, that documentation may contain additional privacy notices, data processing terms, or jurisdiction-specific disclosures.

3. Information We May Collect

We may collect personal information that you provide directly, that is generated through your use of the website, that is provided by service providers or counterparties, or that is available from public or blockchain sources.

Categories of information may include name, title, employer, business address, email address, phone number, messaging handle, jurisdiction, residency, citizenship, professional role, investor type, accreditation or sophistication status, entity information, beneficial ownership information, source of funds, source of wealth, tax status, wallet address, blockchain transaction information, inquiry details, documents submitted, communications, device data, cookie data, and website usage data.

Where legally required or appropriate for compliance, we may collect sensitive or regulated information, including identity documents, date of birth, government identifiers, sanctions screening information, politically exposed person status, AML/KYC review results, financial information, tax documentation, proof of address, corporate documents, and related verification materials.

4. Information You Choose to Provide

You may provide information when you contact us, submit an inquiry, request SPV information, ask about investor relations, submit a startup opportunity, apply for partnership review, communicate by email, respond to diligence questions, join a data room, complete onboarding materials, or provide wallet information.

You should not provide personal information about another person unless you have lawful authority to do so and have provided any required notice or obtained any required consent.

5. Website, Device and Usage Information

When you use this website, we or our service providers may collect technical information such as IP address, browser type, device type, operating system, referring URL, pages visited, time spent, approximate location derived from IP address, cookie identifiers, and interaction data.

This information helps us operate the website, understand traffic, detect abuse, improve content, maintain security, support analytics, and manage cookie consent preferences.

6. Cookies and Similar Technologies

This website may use cookies, pixels, tags, local storage, analytics tools, consent management tools, and similar technologies. These technologies may be used for site functionality, security, performance, analytics, preference management, and marketing or communication measurement where permitted.

You can control cookies through your browser settings and any cookie consent tools presented on the website. Blocking some cookies may affect site functionality, embedded services, analytics, or preference storage.

7. Blockchain and Wallet Data

If you provide a wallet address, interact with tokenized interests, request wallet verification, or participate in blockchain-related activity, we may process wallet addresses, transaction hashes, trustline information, issuer records, ledger balances, timestamps, public blockchain data, and related metadata.

Public blockchain data may be visible to anyone, may be copied by third parties, may be permanent or difficult to delete, and may be linked with other information to identify a person. Alter SPVs cannot erase public blockchain records controlled by decentralized networks or third-party infrastructure.

8. KYC, AML, Sanctions and Compliance Data

For investor onboarding, transfer review, document access, SPV participation, token administration, regulatory compliance, or risk management, we may collect and process information needed for KYC, AML, sanctions, fraud prevention, source-of-funds, source-of-wealth, tax, accreditation, suitability, residency, and beneficial ownership checks.

We may use third-party compliance providers, legal advisers, administrators, custodians, payment providers, screening vendors, and verification platforms to support these checks. Such providers may process information under their own terms, legal obligations, and privacy policies where applicable.

9. Sources of Information

We may receive information from you, your employer, your representatives, portfolio companies, SPVs, administrators, legal advisers, compliance providers, KYC/AML vendors, wallet verification tools, blockchain infrastructure providers, public records, sanctions lists, corporate registries, data rooms, email systems, analytics providers, and publicly available sources.

10. How We Use Information

We may use personal information to respond to inquiries, manage investor relations, review eligibility, evaluate startup or partnership submissions, administer SPV-related communications, prepare or review documentation, conduct KYC/AML checks, comply with legal obligations, verify wallets, manage tokenized interest records, prevent fraud, maintain security, improve website operations, send updates, manage document access, support reporting, and protect legal rights.

We may also use information for business administration, accounting, audit, dispute resolution, regulatory responses, sanctions compliance, tax reporting, transaction review, transfer review, service provider coordination, and enforcement of applicable terms or definitive documentation.

11. Legal Bases Where Applicable

Where data protection law requires a legal basis, we may process personal information based on one or more of the following: consent, contract preparation or performance, compliance with legal obligations, legitimate business interests, protection of rights or security, compliance with regulatory or sanctions requirements, and establishment or defense of legal claims.

Where we rely on legitimate interests, those interests may include operating the website, responding to business inquiries, reviewing potential SPV participation, preventing fraud, protecting systems, maintaining records, administering private market structures, and communicating with business contacts.

12. How We Share Information

We may disclose personal information to affiliates, SPV entities, administrators, managers, legal advisers, tax advisers, auditors, compliance providers, KYC/AML vendors, sanctions screening providers, custodians, banks, payment providers, technology providers, cloud hosting providers, email providers, analytics providers, wallet infrastructure providers, blockchain service providers, portfolio companies where appropriate, regulators, courts, law enforcement, and other parties where necessary or permitted.

We may also disclose information in connection with a restructuring, financing, merger, acquisition, asset transfer, corporate transaction, dispute, investigation, regulatory request, enforcement of terms, or protection of rights, property, safety, and security.

13. No Sale of Personal Information

Alter SPVs does not intend to sell personal information in the ordinary meaning of the word. We also do not intend to share personal information for cross-context behavioral advertising. If our practices change or if a law treats certain analytics, advertising, or third-party cookie activity as a sale or sharing, we will provide any required notice and choice mechanism.

14. Marketing and Communications

We may send business, investor relations, legal, operational, compliance, or informational communications where permitted. You may request that we stop sending non-essential marketing communications, but we may still send transactional, legal, compliance, security, administrative, or relationship-related messages.

15. Data Retention

We retain personal information for as long as reasonably necessary for the purposes described in this policy, including inquiry review, investor relations, SPV administration, legal and regulatory compliance, tax and accounting records, audit, dispute resolution, sanctions and AML obligations, documentation, security, and legitimate business needs.

Retention periods may vary depending on the type of data, jurisdiction, legal obligations, contractual requirements, regulatory expectations, limitation periods, and whether information relates to SPV participation, compliance review, tokenized interest administration, or legal claims.

16. Security

We use reasonable administrative, technical, and organizational measures designed to protect personal information. These measures may include access controls, vendor diligence, internal policies, secure communication practices, retention controls, monitoring, and other safeguards appropriate to the nature of the information.

No website, email system, wallet, blockchain network, cloud provider, communication channel, or internet-based process can be guaranteed completely secure. You are responsible for protecting your own devices, email accounts, wallet credentials, passwords, private keys, seed phrases, and authentication methods.

17. International Transfers

Alter SPVs may process, store, or transfer personal information across jurisdictions, including where service providers, administrators, counterparties, cloud providers, compliance vendors, legal advisers, or other recipients are located. These jurisdictions may have data protection laws that differ from the laws where you reside.

Where required, we may use contractual, organizational, technical, or other safeguards designed to support lawful cross-border processing and transfer of personal information.

18. Your Privacy Rights

Depending on your jurisdiction and applicable law, you may have rights to request access, correction, deletion, restriction, objection, portability, withdrawal of consent, limitation of processing, opt-out of certain disclosures, or information about how personal information is used and shared.

These rights may be subject to exceptions, including legal retention obligations, KYC/AML requirements, sanctions obligations, tax and accounting rules, dispute needs, security requirements, confidential information, privilege, portfolio company rights, third-party rights, and technical limitations relating to blockchain records.

19. California Privacy Notice

If California privacy law applies to you, you may have rights to know, access, correct, delete, limit certain uses of sensitive personal information, opt out of sale or sharing, and be free from discrimination for exercising privacy rights. Alter SPVs does not intend to sell personal information or share it for cross-context behavioral advertising.

California rights may be limited where information is processed in a business-to-business, investment, compliance, legal, security, or regulatory context, or where an exception applies. To submit a request, contact hello@alterspv.com.

20. EEA, UK and Similar Jurisdictions

If EU, EEA, UK, Swiss, UAE, or similar data protection laws apply, you may have rights regarding access, correction, deletion, restriction, objection, portability, withdrawal of consent, and complaints to a supervisory authority. The availability of these rights depends on the applicable law, our role, the data involved, and any legal exceptions.

Where required, we process personal information under applicable legal bases and support appropriate safeguards for international transfers. This website is not intended to override additional privacy terms in SPV, onboarding, compliance, or definitive documentation.

21. Children

This website and any SPV-related communications are intended for adults and business users. We do not knowingly collect personal information from children. If you believe a child has provided personal information to us, contact hello@alterspv.com.

22. Automated Processing

Compliance providers, analytics providers, fraud tools, screening databases, or wallet verification tools may use automated or semi-automated processes to support risk review, sanctions screening, identity verification, analytics, security, or operational workflows. Alter SPVs may use such outputs to support human review and administrative decisions where appropriate.

We do not use this website alone to make final investment, eligibility, allocation, transfer, or onboarding decisions without additional review and documentation where required.

23. Public Information and De-Identified Data

We may use aggregated, anonymized, or de-identified information for analytics, reporting, research, security, business planning, or public communications. We will not attempt to re-identify de-identified information except where permitted by law for security, compliance, or validation purposes.

24. Third-Party Links and Services

This website may link to third-party websites, wallets, blockchain explorers, disclosure pages, data rooms, social media platforms, or service providers. Alter SPVs is not responsible for third-party privacy practices, security, availability, content, or terms. You should review each third party's privacy policy before using their services.

25. Email and Form Communications

Information submitted through email, website forms, or prefilled email drafts may be processed by email providers, hosting providers, and communication tools. Email and web communications may not be fully secure. Do not send sensitive information unless requested through an appropriate channel.

Some forms on this website may prepare or route communications rather than automatically submit information to a database. Where you choose to send an email or submit information, we may process that information for the purposes described in this policy.

26. Updates to This Privacy Policy

We may update this Privacy Policy from time to time. The updated version will be effective when posted unless otherwise stated. Continued use of the website after an update means you acknowledge the revised policy.

27. Contact

For privacy requests, questions, complaints, or notices, contact hello@alterspv.com. We may need to verify your identity, authority, jurisdiction, and relationship with Alter SPVs before responding to a request.