Privacy Statement

Aperture Investors, LLC and its affiliates (collectively, “Aperture”, “we”, “us” or “our”) take your privacy and the security of your personal information seriously. This Privacy Statement is meant to help you understand what personal information we collect on you, how we use, share and protect such information and the rights and choices you have with regard to your personal information when you visit our website, when you communicate with us, or where you otherwise use our services (“Services”).

This Privacy Statement applies to information we collect about clients, business contacts, job applicants, website users or individuals when acting as representatives (e.g., employees, contractors) of entities with which we do business.

Please read this Privacy Statement carefully. In the event that you have any questions or concerns about this Privacy Statement, please contact us at the contact details set forth at the end of this Privacy Statement.

A. What Personal Information Do We Collect About You?

Personal information you provide: when you use our Services:

  • Contact and identification details, such as your first and last name, profession, company name, email address, telephone number, country and/or region, and any other contact data that you may provide when you contact us through the website, via email, or otherwise.
  • Communications that we exchange with you, including when you participate in any interactive features of the Services (such as by sending us a message or request through our “Contact” page, filling out a form, communicating with us via third-party social media sites, requesting customer support, or otherwise communicating with us).
  • Marketing data, such as your preferences for receiving our marketing communications, and details about your engagement with them.
  • Job applicants: we may collect personal information from you when you enquire or apply for a vacancy with us, such as your name, contact details, curriculum vitae (such as, qualifications, previous employment history and profession activities), results of background checks (such as, references, qualifications, and to the extent permitted by law, criminal background checks (unspent convictions)).
  • Other data not specifically listed here, which we will use as described in this Privacy Statement or as otherwise disclosed at the time of collection.

Information we obtain from other sources: We may also obtain information about you from other sources. We maintain pages on social media platforms, such as X, Facebook, LinkedIn, Instagram, and other third-party platforms. When you visit or interact with our pages on those platforms, the platform provider’s privacy policy will apply to your interactions and their collection, use, and processing of your personal information. You or the platforms may provide us with your information through the platform, and we will treat such information in accordance with this Privacy Statement.

Automatic data collection. We and our service providers may automatically log information about you, your computer or mobile device, and your interaction over time with the Services, our communications and other online services, such as:

  • Device data, such as your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, device type (e.g., phone, tablet), IP address, radio/network information (e.g., WiFi, LTE, 3G), and general location information such as city, state, or geographic area.
  • Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the website, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access.

For more information, please see our Cookie Policy.

B. How Do We Use Your Personal Information?

We collect and process your personal information where we have a valid legal basis to do so. Depending on how you interact with us, we will process your personal information for the following purposes:

  • Provide and maintain the Services. To perform a contract with you, or when it is in our legitimate business interests to do so, we will use personal information to operate, provide and maintain our Services, including to create and manage your account so you can log in, build a profile, and interact with us to benefit from our Services.
  • Improve, monitor and personalize the Services. It is in our legitimate interests to improve and keep our Services safe, which includes protecting the security of our Services, and preventing and detecting security threats, fraud or other criminal or malicious activities.
  • Communicate with you about the Services, including by sending you announcements, updates, security alerts, and support and administrative messages. To perform our contractual obligations to you, or when it is in our legitimate interests to do so, we will use your personal information to send you announcements, updates, security alerts, support and administrative messages, responses to your requests, questions, and feedback, and communicate with you about our Services, including by sending technical notices, updates, security alerts, support and administrative messages, and to respond to your comments, questions, and customer service requests.
  • Job applications. We use the personal information you provide to us in the context of a job application to process your application and to assess your suitability for a job with us.
  • Research and development. We use personal information to help us better understand how people use our Services and how we can develop, analyze and improve them where it is in our legitimate interests to do so. This includes monitoring and analyzing trends, usage, and activities in connection with our Services. As part of these activities, we may create aggregated, de-identified or other anonymous data from personal information we collect. We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve the Services, and promote the Services.
  • Direct marketing. We may send you direct marketing communications as permitted by law via email, telephone and other means. Unless where consent is required, we do so where it is in our legitimate interests to market to you. You may opt out of our marketing communications by following the opt out instructions in each communication.
  • Compliance and protection. We use your personal information to comply with our legal obligations and to defend us against legal claims or disputes where it is in our legitimate business interests to do so, including to:
    • Comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.
    • Audit our internal processes for compliance with legal and contractual requirements and internal policies.
    • Enforce the terms and conditions that govern our Services.
    • Where we have a legitimate interest, to prevent, identify, investigate, and deter fraudulent, harmful, unauthorized, unethical, or illegal activity, including cyberattacks and identity theft.
    • Where we have a legitimate interest, to protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims).

C. How We Disclose Your Personal Information

We do not sell your personal information. We may disclose personal information to the following parties:

  • Affiliates. We may disclose your personal information between and among Aperture and our current and future parents, affiliates, subsidiaries, and other companies under common control and ownership for purposes consistent with this Privacy Statement.
  • Service providers. We may disclose your personal information to third-party companies and individuals that provide services on our behalf or help us operate our Services (e.g. marketing, information technology, customer support, email delivery, and website analytics services).
  • Professional advisors. We may disclose your personal information to professional advisors, such as lawyers, auditors, bankers, advisors and insurers, where necessary in the course of the professional services that they render to us.
  • Authorities and others. We may disclose your personal information to law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.
  • Business transferees. We may share personal information as part of a proposed or completed corporate transaction, such as a merger, acquisition, reorganization, financing, asset sale, or similar transaction, or in the event of bankruptcy or related proceedings. Any such disclosure would be subject to appropriate confidentiality protections.
  • Legal compliance. If we believe your actions are inconsistent with our user agreements or policies, if we believe you have violated the law, or to protect the rights, property, and safety of Aperture or others.
  • With your instruction or permission. We may disclose personal information to relevant third parties, where you give us permission to do so in the course of your relationship with us from time to time.
  • De-identified information. We may also share aggregated or de-identified information that cannot reasonably be used to identify you.

D. Transferring Your Personal Information to Other Countries

Due to the global nature of our business, we may transfer personal information to other Aperture affiliates, suppliers and other recipients located in different countries, including to countries outside of the European Economic Area (“EEA”) and UK, such as the United States. Certain of these countries are not considered by the European Commission and/or the United Kingdom Government to provide an adequate level of data protection.

Where we transfer your personal information to recipients in countries not considered to provide an adequate level of data protection, we will ensure we take steps to ensure your personal information are protected and safeguarded, in particular by relying on an EU Commission or UK government adequacy decision or on contractual protections for the transfer of personal information. For more information about how we transfer personal information internationally, please contact us as set out in the “How to Contact Us” section below.

E. How Long Do We Keep Your Personal Information?

Where required under applicable laws, we retain personal information only for as long as is necessary to fulfil the purposes for which it was collected and processed, in accordance with our retention policies, and in accordance with applicable laws and regulatory obligations or until you withdraw your consent (where applicable). To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of personal information, the purposes for which we use personal information and whether we can achieve those purposes through other means, and the applicable legal and regulatory requirements.

F. How Do We Protect Your Personal Information?

We have implemented technical, administrative, organizational, and physical security measures to protect your personal information from unauthorized or unlawful processing and against accidental loss or destruction of, or damage to, your personal information in accordance with our internal security procedures covering its storage, access and destruction. We review our security procedures in order to consider appropriate new technology and methods on a periodic basis. Except as otherwise required by law, rule or regulation, only authorized persons will be allowed to view your personal information. Personal information may be stored on our own technology systems or those of our vendors or in paper files. Please understand, however, that no security system is impenetrable. We can neither guarantee the security of our systems or the systems of the third parties with which we may share your personal information, nor can we guarantee that the information you supply will not be intercepted while being transmitted over the Internet.

G. Changes to this Privacy Statement

We reserve the right to change our Privacy Statement from time to time as necessary, including due to changes in the law or to our data processing practices or activities. This Privacy Statement is effective as of the last updated date stated at the top of this Privacy Statement.

H. Your Rights and Choices

Personal information requests. Depending on your location and the nature of your interactions with our Services, you may request the following in relation to your personal information:

  • Information about how we have collected and used your personal information. We have made this information available to you without having to request it by including it in this Privacy Statement.
  • Access to a copy of the personal information that we have collected about you. Where applicable, we will provide the information in a portable, machine-readable, readily-usable format.
  • Correction of your personal information that is inaccurate or out of date.
  • Deletion of your personal information when it is no longer needed for providing the Services or for other lawful purposes.
  • Additional rights, such as the ability to object to the processing of your personal information and to request that we restrict how your personal information is processed.

To exercise the above rights, contact us as set out in the “How to Contact Us” section below. Prior to responding to your requests, we may verify your identity by matching any requested identifying information you provide against the information we have about you. Where you are requested to consent to the processing of your personal information by Aperture, you have the right to withdraw your consent at any time.

In some instances, your rights and choices may be limited, such as where fulfilling your request would impair: the rights of others, our ability to provide a service you have requested, or our ability to comply with our legal obligations and enforce our legal rights.

Right to complain. Depending on where you reside, such as if you reside in the EEA or UK, you may have the right to complain to a data protection regulator where you live or work, or where you feel a violation has occurred. Click here to find your local supervisory authority in the EEA. In the UK, the competent authority is the Information Commissioner’s Office.

I. California Collection Notice

If you are a California resident, California law requires us to provide you with some additional information regarding how Aperture collects, uses, shares, and sells your “personal information” (as defined in the California Consumer Privacy Act (“CCPA”)). See our California Addendum for additional information.

Please note the CCPA’s scope excludes personal information covered by certain financial services-specific privacy laws, including the Gramm-Leach-Bliley Act (GLBA) and California Financial Information Privacy Act (FIPA).

Shine the Light Disclosure: The California “Shine the Light” law gives residents of California the right under certain circumstances to request information from us regarding the manner in which we share certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes. We do not share your personal information with third parties for their own direct marketing purposes.

J. Other Sites and Services

Our Services may contain links to websites and other online services operated by third parties. In addition, our content may be included on web pages or online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control third party websites or online services, and we are not responsible for their actions. Other websites and services follow different rules regarding the collection, use and disclosure of your personal information. We encourage you to read the privacy policies of the other websites and online services you use.

K. Children’s Privacy

The Services are not intended for use by children under 18 years of age. If we learn that we have collected personal information through the Services from a child under 18 without the consent of the child’s parent or guardian as required by law, we will delete it as soon as possible.

L. How To Contact Us

Responsible entity: For the purposes of European Union and UK data protection laws, Aperture Investors, LLC, Aperture Investors UK, Ltd and Aperture Investors France are controllers of your personal information.

If you have any questions concerning our privacy practices described in this Privacy Statement, or require a copy of our privacy policy in an alternative accessible format, please contact us at [email protected] or call 1-212-521-5180.

Last updated: October 20, 2026

California Addendum

This California Addendum supplements the Privacy Statement and applies only to personal information that relates to California residents and is regulated by the California Consumer Privacy Act (“CCPA”). This California Addendum does not apply to information relating to investors that is regulated by the Gramm-Leach-Bliley Act (“GLBA”) or California Financial Information Privacy Act (“FIPA”).

CCPA Categories of Personal Information

We collect the following categories of personal information:

Data Category Collected Collected? Primary Purposes of Processing Key Disclosures Can You Limit Sharing?
Identifiers, such as name, email address, and IP address
Yes
To provide and maintain the Services.
To improve, monitor and personalize the Services.
To communicate with you about the Services.
For compliance and protection.
Service providers
No
Personal information categories listed in the California Customer Records Statute (e.g., name, contact details)
Yes
To provide and maintain the Services.
To improve, monitor and personalize the Services.
To communicate with you about the Services.
For compliance and protection.
Service providers
No
Commercial information, including but not limited to records of products or services purchased
Yes
To provide and maintain the Services.
To improve, monitor and personalize the Services.
To communicate with you about the Services.
For compliance and protection.
Service providers
No
Professional or employment-related information
Yes
To provide and maintain the Services.
To improve, monitor and personalize the Services.
To communicate with you about the Services.
For compliance and protection.
To process job applications.
Service providers
No
Internet or other electronic network activity information, including but not limited to browsing history and search history
Yes
To provide and maintain the Services.
To improve, monitor and personalize the Services.
To communicate with you about the Services.
For compliance and protection.
Service providers
No
Inferences drawn from information to create a profile about your behavior, preferences, etc.
Yes
To provide and maintain the Services.
To improve, monitor and personalize the Services.
To communicate with you about the Services.
For compliance and protection.
Service providers
No
X
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