Website Privacy Policy
Last updated: November 25th, 2025
1. INTRODUCTION
Aspen Private Capital, LLC (“Aspen Private Capital,” “we,” “us,” or “our”) respects your privacy. This Privacy Policy, along with any GLBA Privacy Notice provided to our customers, explains how Aspen Private Capital collects, processes, and uses your Personal Data when you visit or use our website, https://www.aspenprivatecapital.com/ (“Website”), use our services, or otherwise communicate with us.
For purposes of this Privacy Policy, “Personal Data” means any information that directly or indirectly identifies or relates to an individual and is in the possession or under the control of Aspen Private Capital (or its representatives or service providers). Such Personal Data may include, without limitation, name, age, government identification numbers, Social Security number, email address, address, telephone number, location data, financial data (such as checking account information, wire transfer instructions, account balances and payment history), or online identifiers.
This Privacy Policy does not apply to information collected through third-party websites or services that you may access through the Website. Linked sites may have their own privacy notices or policies, which you should review. Aspen Private Capital is not responsible for the content of third-party links or websites, and your use of such third-party websites is at your own risk.
Mobile information will not be shared with third parties or affiliates for marketing or promotional purposes. Regardless of your consent to receive text messages, any related data, including your phone number and consent information, will be kept confidential and will not be disclosed to third parties, ensuring that your opt-in data is excluded from external marketing activities.
By using the Website or our services, you agree to the terms of this Privacy Policy.
2. THE TYPES OF PERSONAL DATA WE COLLECT
Aspen Private Capital may collect and process the following categories of Personal Data about you from the sources identified below:
Website Data. When you browse the Website, we may collect information submitted through the Website (including, but not limited to, name, age, date of birth, email address, address, and telephone number).
Identity Verification Data. We may collect identity verification information, such as images of your government-issued ID, passport, national ID card, or driver’s license, as permitted by applicable laws, or other authentication information.
Communications Data. We may collect Personal Data that you provide when you contact Aspen Private Capital for any reason, such as to express interest in obtaining additional information about our services, ask questions, use the contact information listed on the “Contact Us” webpage, sign up for emails, or attend an event. Such information may include contact information such as name, job title, company name, phone number, location, and email address.
Financial Information. We will collect and use financial information that you provide in subscription documents or otherwise during the course of using our services. This information may include checking account information, wire transfer instructions, account balances, and payment history.
Reputation & Background Check Data. If you are a service provider or a business partner, or a representative of one, we may collect Personal Data from you and from third parties that includes contact details, business practices, creditworthiness, reputation and business history, and job titles or roles. We may also use this information to check against government sanctions lists and for other “Know Your Customer” purposes.
Data Aspen Private Capital Generates. We may generate Personal Data about you when we interact with you or perform services for you. This may include information about your relationship with us or the services we provide.
Please note that if you do not provide certain Personal Data when requested (and where relevant, provide your consent), we may not be able to provide you with access to all areas of the Website or our services.
3. HOW WE COLLECT YOUR PERSONAL DATA
Aspen Private Capital may collect Personal Data in the following ways:
Directly from you, including through your use of the Website, when you send us an email, complete subscription documents, visit our premises, or otherwise contact or communicate with us;
From our affiliates and business partners;
From a third party acting on your behalf, such as an intermediary, investment advisor, lawyer, or service provider;
From publicly available sources; and
From other organizations, such as fund administrators and other service providers.
4. HOW WE USE YOUR PERSONAL DATA
Your Personal Data may be collected, stored, disclosed, and processed by Aspen Private Capital for the following purposes.
5. DISCLOSURE OF YOUR PERSONAL DATA TO THIRD PARTIES
Aspen Private Capital may share, disclose, or provide access to your Personal Data among its affiliates, business units, and third-party agents, service providers, and contractors outside of Aspen Private Capital for the following purposes:
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6. TRANSFERS OF PERSONAL DATA
Aspen Private Capital is based in the United States, and the Website is intended for users in, and operated from, the United States. If you reside outside the United States and use our Website or otherwise provide information to us, you acknowledge that your information will be transferred to and processed in the United States, which may not provide the same privacy protections as the laws in your jurisdiction.
7. HOW WE SAFEGUARD YOUR PERSONAL DATA
Aspen Private Capital has implemented commercially reasonable controls to protect Personal Data, taking into account the sensitivity of the data. Although we exercise reasonable care in providing secure transmission and storage of Personal Data provided through the Website, no method of transmission over the Internet, and no means of electronic storage, is absolutely secure. Accordingly, we cannot and do not guarantee the absolute security of your Personal Data.
8. RETENTION AND DESTRUCTION OF PERSONAL DATA
The period for which Aspen Private Capital will hold your Personal Data will vary and will be determined by:
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9. CHILDREN’S PERSONAL DATA
The Website is intended for use by individuals over the age of 18. We do not knowingly solicit or collect Personal Data from children under 18.
10. PROCESSING OF PERSONAL DATA FOR MARKETING PURPOSES
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11. MODIFICATIONS TO THIS PRIVACY POLICY
We reserve the right to modify this Privacy Policy at any time by posting the revised version on the Website and updating the last modified date. We encourage you to review the Privacy Policy whenever you access the Website or interact with us to stay informed about our privacy practices.
12. CALIFORNIA SHINE THE LIGHT NOTICE
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13. YOUR PRIVACY RIGHTS
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14. QUESTIONS AND CONCERNS
If you have any questions or concerns about Aspen Private Capital’s handling of your Personal Data or about this Privacy Policy, please contact us using the information below.
15. HOW TO CONTACT US
Email: legal@aspenprivatecapital.com
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