1. Scope
This Privacy Policy applies to information collected through www.develobrite.com and any related subdomains (the "Site"), from communications you send us (email, telephone, mail), and in the course of providing investment management, investor relations, and portfolio services to investors, prospective investors, portfolio companies, and business counterparties (collectively, the "Services").
2. Information We Collect
We collect information you provide directly, information we collect automatically, and information from third parties:
- Identity and contact data — name, title, employer, business address, email, phone.
- Investor eligibility data — accreditation, qualified-purchaser status, tax identification, source of funds, KYC and AML information.
- Financial data — banking details, wire instructions, capital commitment, capital call and distribution history.
- Correspondence — records of communications with Develobrite personnel.
- Diligence and portfolio company data — as reasonably necessary in connection with prospective or actual investments.
- Automatically collected data — IP address, browser type, device information, pages viewed, referral source, and other analytics data collected via cookies and similar technologies (see Section 8).
- Third-party data — from your employer, KYC/AML vendors, credit bureaus, government registries, professional networks, and other lawful sources.
3. How We Use Your Information
We use personal information to: (a) evaluate investor eligibility and provide investment management services; (b) comply with legal, regulatory, tax, KYC, AML, and sanctions obligations; (c) communicate with you about the Develobrite Funds, portfolio companies, market perspectives, and events; (d) evaluate and execute prospective portfolio company transactions; (e) operate, secure, and improve the Site; (f) enforce our legal rights and defend against claims; and (g) other purposes with your consent.
4. Legal Bases for Processing
Where required by applicable law (including the EU General Data Protection Regulation and UK GDPR), we process personal data on the basis of: performance of a contract; compliance with a legal obligation; our legitimate interests (including operating and marketing our business, managing risk, and enforcing our rights) where not overridden by your rights; and, where required, your consent.
5. Sharing and Disclosure
We may share personal information with:
- Service providers that support our operations (fund administrators, auditors, legal counsel, tax advisors, custodians, banks, IT and analytics providers) subject to appropriate confidentiality and data-protection obligations.
- Fund entities and general partners within the Develobrite platform where necessary for investment management.
- Regulatory authorities and courts where required by law or legal process.
- Prospective purchasers in connection with due diligence for a corporate transaction involving Develobrite or its affiliates, subject to confidentiality.
- Portfolio companies and their advisors where necessary in connection with an investment.
We do not sell personal information for monetary consideration.
6. GLBA Notice (Financial Privacy)
As a financial services firm, Develobrite is subject to the U.S. Gramm-Leach-Bliley Act. We collect nonpublic personal information from investors as described above and disclose it only to affiliates and non-affiliated third parties as permitted by law (including for administration, servicing, legal compliance, and joint marketing under contractual confidentiality). We maintain physical, electronic, and procedural safeguards designed to protect nonpublic personal information. You may not opt out of disclosures that are legally permitted or required.
7. Your Rights
All users: You may request access to, correction of, or deletion of the personal information we hold about you, subject to legal and regulatory retention requirements.
California residents (CCPA/CPRA): You have the right to know what personal information we collect, to request deletion, to correct inaccurate information, to opt out of "sale" or "sharing" of personal information (we do not sell personal information as defined by CCPA), and to limit use of sensitive personal information. To exercise these rights, contact [email protected]. We will not discriminate against you for exercising your rights.
EU/UK residents (GDPR/UK GDPR): In addition to the rights above, you have the right to data portability, the right to object to processing based on legitimate interests, the right to restrict processing, and the right to lodge a complaint with a supervisory authority. Where we rely on consent, you have the right to withdraw it at any time.
Other jurisdictions: Residents of other jurisdictions with applicable data-protection laws (including Virginia, Colorado, Connecticut, Utah, Texas, and others) may have similar rights. Contact us to exercise them.
8. Cookies and Analytics
The Site uses cookies and similar technologies for authentication, site operation, security, analytics, and — where you have consented (if required by law) — measurement of marketing effectiveness. You can manage cookies through your browser settings. Blocking essential cookies may affect Site functionality.
9. Data Retention
We retain personal information for as long as necessary to fulfill the purposes for which it was collected, to comply with legal and regulatory obligations (which for financial services can extend for many years), to resolve disputes, and to enforce our agreements.
10. International Transfers
Personal information may be transferred to, and processed in, the United States and other jurisdictions that may not offer the same level of data protection as your home country. Where required, we implement appropriate safeguards, including Standard Contractual Clauses and equivalent mechanisms.
11. Security
We maintain administrative, technical, and physical safeguards designed to protect personal information from unauthorized access, disclosure, alteration, or destruction. No security program is perfect; if a security incident affects your personal information, we will notify you as required by applicable law.
12. Children
The Site is not directed to children under 16, and we do not knowingly collect personal information from children.
13. Third-Party Links
The Site may link to third-party sites. Their privacy practices are not covered by this policy. Please review the privacy policies of any third-party sites you visit.
14. Contact
Privacy officer: [email protected]
Compliance: [email protected]
Address: Develobrite Capital Management, LLC — Attn: Privacy Officer — 1910 Pacific Avenue, Suite 2000, Dallas, TX 75201
15. Changes
We may update this Privacy Policy from time to time. Material changes will be indicated by an updated "Last updated" date. Where required by law, we will provide additional notice or seek consent.