Privacy Policy

• Us offline or through any other means (except for investor onboarding materials and at in-person events), including on any other website operated by the Company or any third party (including our affiliates, subsidiaries and related investment entities); or 
• Any third party (including our affiliates, subsidiaries and related investment entities), including through any application or content (including advertising) that may link to or be accessible from or through the Website, except this policy does apply to information collected (whether through this Website or through applications or content linked through this Website) by our provider Aduro Advisors and their subcontractors or a successor thereto (collectively, our “Fund Administrator”).

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website and to not participate as an investor. By accessing or using this Website or requesting to participate as an investor, you agree to this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this Website or your request for consideration as an investor for a new investment offering after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates. 

‍Children Under the Age of 13Our Website is not intended for children under 13 years of age. No one under age 13 may provide any information to or on the Website. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on this Website or through any of its features, register on the Website, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at info@bwcap.com.

Information We Collect About You and How We Collect It
‍We collect several types of information from and about users of our Website and as part of investor onboarding, including information:

• Identifiers, such as name, alias, postal address, unique personal identifier, online identifiers, Internet Protocol address, email address, account name, signatures, physical characteristics or description, telephone number, or other similar identifiers.
• Financial Information, including bank account number, credit card number, debit card number, or any other financial information that does not allow access or withdrawal of funds. 
• Characteristics of Protected Classifications under state or federal law, such as age, gender, and marital status.
• Commercial Information, such as records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
• Internet or Other Network Information, such as browsing history, search history, information regarding your interactions with our websites or advertisements.
• Geolocation Data, such as device location that is more granular than a city or town.
• Inferences drawn from any of the Personal Information listed above to create a profile or summary about, for example, an individual’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. This category includes Sensitive Data Inferences, which are inferences made by us based on Personal Information, alone or in combination with other data, to indicate your Sensitive Personal Information.

We collect this information:

• Directly from you when you provide it to us.
• Through the use of background check providers, where you have consented to us performing, or having performed, the applicable background check.
• Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.

Information You Provide to Us  
‍The information we collect on or through our Website or as part of investor onboarding may include:

• Information that you provide by filling in forms on our Website. This includes information provided at the time of registering to use our Website or filling out our “contact us” form. We may also ask you for information when you report a problem with our Website.
• Information that you provide by filling in forms as part of the investor onboarding process, whether in “hard copy” or digitally through the Website or a website operated by or on behalf of our Fund Administrator.
• Records and copies of your correspondence (including email addresses), if you contact us or our Fund Administrator.

Information We Collect Through Automatic Data Collection Technologies  
‍As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• Details of your visits to our Website, which may include traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
• Information about your computer and internet connection, including your IP address, operating system, and browser type.

We use the information we collect through automatic data collection technologies to help us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

• Estimate our audience size and usage patterns.
• Store information about your preferences, allowing us to customize our Website according to your individual interests.
• Speed up your searches.
• Recognize you when you return to our Website.

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website. For information about managing your privacy and security settings for cookies, see Choices About How We Use and Disclose Your Information.
• Web Beacons. Pages of our Website and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity). 

Third-Party Use of Cookies and Other Tracking Technologies
‍Some content or applications, including advertisements, on the Website are served by third parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising, potential investment opportunities or other targeted content. 

If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.

How We Use Your Information
‍We may use information that we collect about you or that you provide to us, including any personal information:

• To present our Website and its contents to you.
• To provide you with information, products, or services that you request from us, including determining your eligibility for such information, products or services.
• To fulfill any other purpose for which you provide it.
• To provide you with notices about your account, such as notices of capital calls, distribution notices, and other fund-related notices.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
• To notify you about changes to our Website or any products or services we offer or provide though it.
• To allow you to participate in interactive features on our Website.
• To track your interactions with us and our products or services, including your potential suitability for future investment offerings.
• To market our investment offerings and other services.
• To fulfill our obligations under applicable laws, including our “know your customer” and anti-money laundering obligations.
• On an aggregated basis which does not identify you, for any lawful purpose.
• In any other way we may describe when you provide the information.
• For any other purpose with your consent.

We may also use your information to contact you about our own goods and services that may be of interest to you, such as future investment opportunities. If you do not want us to use your information in this way, please email us at info@bwcap.com and request to be removed from consideration for future offerings. For more information, see Choices About How We Use and Disclose Your Information.

We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. If you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

Disclosure of Your Information
‍We may disclose aggregated information about our users, and information that does not identify any individual, without restriction. 

We may disclose personal information that we collect or you provide as described in this privacy policy:

• To our subsidiaries, affiliates, and other related investment entities that we may manage or otherwise operate.
• To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them, including but not limited to our Fund Administrator.
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by the Company about our Website users or current and potential investors is among the assets transferred.
• To fulfill the purpose for which you provide it.
• For any other purpose disclosed by us when you provide the information.
• With your consent.

We may also disclose your personal information:

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• To enforce or apply our Terms of Use and other agreements, including for billing and collection purposes.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Broadwater Capital, our customers or investors, or others.

Choices About How We Use and Disclose Your Information
‍We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information: 

• Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
• Disclosure of Your Information for Third-Party Advertising. If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by contacting us via the Contact Information specified below.
• Promotional Offers from the Company. If you do not wish to have your contact information used by the Company to promote our own or third parties’ products or services, you can opt-out by contacting us via the Contact Information specified below. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions.
• Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, you can opt-out by contacting us via the Contact Information specified below 

We do not control third parties’ collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website.

‍Changes to Our Privacy Policy
‍It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users’ personal information, we will post the updated version of this privacy policy on this page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.

‍Contact Information
‍To ask questions or comment about this privacy policy and our privacy practices, contact us at: info@bwcap.com.