Last Updated: June 2025
We provide this Privacy Notice (“Privacy Notice”) in compliance with Regulation S-P under the Gramm-Leach-Bliley Act (the “Privacy Rules”). This Notice explains how Thesis Capital LLC and its affiliates (“Thesis Capital,” “we,” “our,” or “us”) collect, use, and protect personal information about or in connection with our investors.
In connection with forming and operating our private investment funds (each, a “Fund” and collectively, the “Funds”), Thesis Capital collects and maintains personal information about our investors from the following sources:
Thesis Capital is committed to protecting your privacy and maintaining the confidentiality of your personal information. We may disclose information about you only as permitted or required by law and as necessary for the effective management and administration of the Funds. This includes disclosure:
Access to personal information is restricted to employees who need it to perform their duties. Thesis Capital maintains physical, electronic, and procedural safeguards to protect this information from unauthorized access or disclosure. The same protections apply to both current and former investors.
We reserve the right to amend this Privacy Notice at any time. Updates will be posted on this Site. The examples in this Notice are illustrative and not exhaustive. This Notice is intended to comply with applicable U.S. federal privacy laws and certain other jurisdictions’ requirements where applicable.
Depending on your jurisdiction, you may have additional rights under other privacy laws. If you are a resident of California, please refer to the California Privacy Notice. If the EU or UK General Data Protection Regulation (“GDPR”) applies to you, please refer to the GDPR Privacy Notice.
This California Privacy Notice supplements the Privacy Notice above and applies only to California residents, as defined by the California Consumer Privacy Act of 2018 (“CCPA”), as amended. It explains your rights under the CCPA and how to exercise them. To the extent there is any conflict between the CCPA and the Gramm-Leach-Bliley Act or Regulation S-P, the federal requirements will govern.
We may collect or have collected within the past twelve (12) months the following categories of personal information:
| Category | Examples | Collected |
|---|---|---|
| A. Identifiers | Name, contact details, address, email, IP address, tax ID, driver’s license, passport. | Yes |
| B. Customer Records | Bank account numbers, transaction data, income and asset information, AML/KYC documentation. | Yes |
| C. Protected Classifications | Date of birth, citizenship, nationality. | Yes |
| D. Commercial Information | Investment activity, ownership percentage, capital commitments, source of funds. | Yes |
| E. Biometric Information | Not collected. | No |
| F. Internet Activity | Cookies, browsing activity, portal access logs. | Yes |
| G. Geolocation Data | Physical or IP-based location. | Yes |
| H. Sensory Data | Not collected. | No |
| I. Employment Data | Employment history or professional information. | Yes |
| J. Education Records | Not collected. | No |
| K. Inferences | Not collected or analyzed. | No |
| L. Sensitive Personal Information | Social Security, passport, financial account credentials, geolocation. | Yes |
We collect personal information for business or commercial purposes such as:
We do not sell personal information or share it for cross-context behavioral advertising. We may disclose information to third parties for business purposes, including administrators, custodians, auditors, consultants, legal advisors, and cloud service providers.
To exercise these rights, contact us at privacy@thesiscapital.com or call our office at +1 (713) 555-0000. We will verify your request through reasonable procedures consistent with applicable law. Authorized agents may act on your behalf with proper written consent.
This GDPR Privacy Notice applies to individuals located in the European Economic Area (EEA) or the United Kingdom whose personal data is processed by Thesis Capital under the EU or UK General Data Protection Regulation (“GDPR”).
For the purposes of this Notice, Thesis Capital LLC and its relevant affiliates are data controllers of the personal data they collect and process in connection with the Funds. This means Thesis Capital determines how and why your personal data is used.
We may collect the following categories of personal data:
We process personal data as necessary for:
We may disclose your data to affiliates, fund administrators, advisors, auditors, regulatory authorities, or IT service providers. Personal data may be transferred to jurisdictions outside your country of residence. We implement safeguards, such as standard contractual clauses, to protect your data in accordance with applicable law.
We retain personal data only as long as necessary to fulfill the purposes described above or as required by law. Thesis Capital uses technical and organizational measures designed to protect your information against unauthorized access, alteration, or disclosure.
Under the GDPR, you may have the following rights:
To exercise your GDPR rights or make a privacy inquiry, contact us at info@thesiscapital.com.
For any questions regarding this Privacy Policy or your rights under applicable law, please contact:
Thesis Capital LLC
Attn: Compliance Department
11959 Pebble Rock Drive
Houston, Texas 77077
Email: info@thesiscapital.com
End of Privacy Policy
