Privacy Policy

1. Introduction

This Privacy Policy explains how Solvent Capital Partners LLC (“Solvent Capital Partners,” “we,” “us,” or “our”) collects, uses, discloses, and safeguards personal data in connection with Keystone (the “Platform”), an investor intelligence platform that aggregates, verifies, and surfaces information about institutional and private investors. Solvent Capital Partners LLC is the data controller responsible for the personal data processed through the Platform.

By accessing or using the Platform, you acknowledge that you have read and understood this Privacy Policy. This Privacy Policy should be read together with our Terms of Service, which govern your use of the Platform. Capitalised terms used but not defined here have the meanings given to them in the Terms of Service.

2. Scope of This Policy

This Privacy Policy applies to two distinct categories of data subjects: (a) individuals who register for, subscribe to, or otherwise use the Platform (“Users”); and (b) individuals whose professional information appears in investor profiles surfaced by the Platform (“Profiled Investors”). The personal data we collect, the lawful bases on which we process it, and the rights available to each category differ, and are described in the sections that follow.

3. Personal Data We Collect from Users

3.1 Account Information

When you create an account, we collect your name, email address, password (in hashed form), business affiliation, role or title, and any other information you choose to provide as part of registration or your profile.

3.2 Billing Information

Subscription payments are processed by our third-party payment processor. We do not store full payment-card numbers on our systems. We retain limited billing metadata such as the payment processor’s transaction identifier, the last four digits of the card, the card brand, the billing country, the plan and amount charged, and the date of each transaction, for accounting, fraud prevention, and tax purposes.

3.3 Usage, Device, and Log Data

When you interact with the Platform, we automatically collect information including IP address, browser type and version, operating system, device identifiers, referring URL, pages and features accessed, search queries, timestamps, and similar diagnostic and analytics information.

3.4 Communications and Support

If you contact us by email, in-app messaging, or any other channel, we collect the content of your communications and any information you choose to include, together with our responses, in order to provide support and to improve our services.

3.5 User Content

We process the data, files, search queries, saved filters, notes, exports, and other content that you upload to or generate within the Platform (“User Content”) in order to operate the Platform on your behalf, in accordance with the Terms of Service.

4. Personal Data We Collect About Profiled Investors

Keystone is an investor intelligence platform. As part of operating the Platform, we collect, organise, verify, and make available professional information about individuals associated with institutional and private investment firms. Categories of personal data we may collect about Profiled Investors include name, professional contact information (such as work email and work telephone number), firm affiliation, role or title, professional biography, deployment activity, check-size data, fund affiliations, sector and stage focus, and other publicly observable professional attributes.

This information is collected without direct interaction with the data subject, from the sources described in Section 5 below. We process it for the legitimate-interest purposes described in Sections 6 and 7. Profiled Investors have specific rights to object to and request removal from the Platform, which are set out in Section 14.

5. Sources of Personal Data

We collect personal data from the following categories of sources: (a) directly from Users who register, communicate with us, or use the Platform; (b) automatically from the Users’ devices and browsers as they interact with the Platform; (c) from our payment processor, in the case of billing metadata; and (d) for Profiled Investors, from public filings (including, where applicable, regulatory filings such as SEC Form D, Form ADV, Form 13F, and equivalent filings made to other regulators), regulatory disclosures, verified professional profiles, deal databases, and our own proprietary enrichment processes.

We invest significant resources in verifying contact information and tracking deployment activity, but the underlying sources are subject to change without notice and the data we hold may, at any given moment, be incomplete, out of date, or inaccurate.

6. How We Use Personal Data

We process personal data for the following purposes: (a) to provide, operate, secure, and maintain the Platform; (b) to register Users, manage accounts, and authenticate sessions; (c) to process subscription payments and manage billing; (d) to detect, prevent, and respond to fraud, abuse, security incidents, and violations of the Terms of Service; (e) to monitor, analyse, and improve the performance, features, and user experience of the Platform; (f) to provide customer support and respond to enquiries; (g) to comply with applicable legal, regulatory, and tax obligations and to enforce our agreements; (h) to send service-related communications such as account, billing, and policy update notices; (i) to send marketing or promotional communications to Users who have not opted out, in accordance with applicable law; and (j) to build, maintain, and keep current the investor intelligence dataset that Profiled Investors form a part of.

7. Legal Bases for Processing (GDPR and UK GDPR)

Where the General Data Protection Regulation or the UK General Data Protection Regulation applies, we rely on the following lawful bases. For Users: (a) performance of a contract, where processing is necessary to provide the Platform, manage your account, or fulfil our obligations under the Terms of Service; (b) legitimate interests, where processing is necessary for the security of the Platform, fraud prevention, product analytics, and the operation of our business, and is not overridden by your interests or fundamental rights; (c) consent, where you have given consent for a specific purpose, such as certain marketing communications or non-essential cookies; and (d) legal obligation, where processing is necessary to comply with applicable law.

For Profiled Investors, we rely on legitimate interests in (a) providing accurate market intelligence to capital raisers and other Users, (b) maintaining the integrity and usefulness of a professional investor dataset, and (c) operating Keystone as a commercial product. We have considered the privacy interests of Profiled Investors as part of a balancing test and have concluded that, because the data we process relates to the individual’s professional capacity, is largely sourced from public or regulatory filings, and is used in a manner consistent with the reasonable expectations of professionals in the investment industry, our legitimate interests are not overridden by the privacy interests of the data subject. Profiled Investors retain the right to object to this processing as described in Section 14.

8. Cookies and Similar Technologies

We use cookies and similar technologies to operate the Platform, remember your preferences, and understand how the Platform is used. The categories we use are: (a) strictly necessary cookies, which are required to deliver the Platform and cannot be disabled; (b) analytics cookies, which help us understand how Users interact with the Platform so that we can improve it; and (c) preference cookies, which remember choices you have made.

You can configure your browser to refuse cookies or to alert you when cookies are being sent. If you do so, some features of the Platform may not function properly. Where required by applicable law, we will request your consent before placing non-essential cookies.

9. Sharing and Disclosure

We do not sell personal data. We share personal data only in the following circumstances: (a) with service providers and sub-processors that process data on our behalf, such as cloud hosting, infrastructure, analytics, payment processing, transactional email, and customer support providers, each of which is bound by contractual confidentiality and data-protection obligations; (b) where required to comply with a legal obligation, court order, regulatory request, or to respond to a valid law-enforcement request; (c) in connection with a merger, acquisition, financing, reorganisation, or sale of assets, in which case the recipient will be required to honour the commitments made in this Privacy Policy; and (d) with your consent or at your direction.

10. International Data Transfers

Solvent Capital Partners LLC is established in the State of Delaware, United States. Personal data we process may be transferred to, stored in, and processed in countries other than the one in which you are resident, including the United States, the European Economic Area, and the United Kingdom. The data-protection laws of these jurisdictions may differ from those of your home jurisdiction.

Where personal data subject to the GDPR or UK GDPR is transferred outside the EEA or the United Kingdom to a recipient that is not subject to an adequacy decision, we rely on appropriate safeguards such as the Standard Contractual Clauses approved by the European Commission, the UK International Data Transfer Agreement, or other lawful transfer mechanisms. You may contact us to request a copy of the safeguards we have put in place.

11. Data Retention

We retain personal data only for as long as is necessary for the purposes described in this Privacy Policy or as required by applicable law. Specifically: (a) account data is retained for as long as the account is active and for a reasonable period thereafter to handle disputes, enforce our agreements, and comply with our legal obligations; (b) billing and tax records are retained for the period required by applicable tax, accounting, and anti-money-laundering laws; (c) security and audit logs are retained for a limited period sufficient to investigate incidents and meet our security obligations; and (d) information about Profiled Investors is retained for as long as the underlying source remains valid, the data is required to maintain the integrity of the dataset, and the data subject has not exercised their right to object or to have the data removed.

12. Data Security

We implement technical and organisational measures designed to protect personal data against unauthorised access, alteration, disclosure, loss, or destruction. These measures include encryption of data in transit and, where appropriate, at rest; role-based access controls and least-privilege principles; vendor due diligence; incident response procedures; and regular review of our security practices. No method of transmission over the internet or method of electronic storage is completely secure, however, and we cannot guarantee absolute security.

13. Your Rights as a User

Subject to applicable law and to verification of your identity, Users have the following rights with respect to their personal data: (a) the right of access; (b) the right of rectification of inaccurate or incomplete data; (c) the right of erasure; (d) the right to restrict processing; (e) the right to data portability; (f) the right to object to processing carried out on the basis of legitimate interests, including for direct marketing; (g) the right to withdraw consent at any time, where processing is based on consent, without affecting the lawfulness of prior processing; and (h) the right to lodge a complaint with a supervisory authority in the jurisdiction of your habitual residence, place of work, or place of an alleged infringement.

To exercise any of these rights, contact us using the details in Section 20. We will respond to verified requests within the timeframes required by applicable law and, in any event, without undue delay.

14. Rights of Profiled Investors

If you are an individual whose professional information appears in an investor profile on Keystone, you have the right to (a) access the personal data we hold about you; (b) request correction of inaccurate or incomplete information; (c) object to our processing of your personal data on legitimate-interest grounds; and (d) request that your profile be suppressed or removed from the Platform.

To exercise any of these rights, send an email to legal@keystone.markets identifying the profile in question and the right you are exercising. We may ask you to provide reasonable verification of your identity (for example, a work email address at the firm associated with the profile) before we action the request, in order to protect the data subject from impersonation. We will respond to verified requests within thirty (30) days. Where a request is granted, we will, as appropriate, correct the data, suppress it from search results and exports, or delete it, and we will use reasonable measures to prevent re-collection from the same source.

15. California Privacy Rights (CCPA / CPRA)

If you are a California resident, the California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively, the “CCPA”), provides you with additional rights regarding your personal information. The categories of personal information we collect, the sources from which we collect them, the business and commercial purposes for which we use them, and the categories of recipients with whom we share them are described in Sections 3 to 9 of this Privacy Policy.

Subject to certain exceptions, California residents have the right to: (a) know what personal information we collect, use, disclose, and (where applicable) sell or share about them; (b) request deletion of personal information; (c) request correction of inaccurate personal information; (d) opt out of the sale or sharing of personal information; and (e) limit the use and disclosure of sensitive personal information. Keystone does not sell personal information and does not share personal information for cross-context behavioural advertising. We will not discriminate against you for exercising any of your CCPA rights. To exercise these rights, contact us using the details in Section 20. You may use an authorised agent to submit a request on your behalf, in which case we may require written authorisation and verification of the agent’s identity.

16. Automated Decision-Making and Profiling

We do not make decisions producing legal or similarly significant effects on data subjects solely by automated means. The Platform applies relevance scoring, ranking, and search algorithms to surface information; these features are informational tools intended to assist Users in their own analysis, and they do not produce legal or similarly significant effects on Profiled Investors or on Users.

17. Children’s Privacy

The Platform is intended for business users and is not directed at individuals under the age of eighteen (18). We do not knowingly collect personal data from individuals under eighteen. If we become aware that we have collected personal data from a person under eighteen, we will take reasonable steps to delete that information.

18. Data Breach Notification

In the event of a personal data breach that is likely to result in a risk to the rights and freedoms of affected individuals, we will notify the relevant supervisory authorities and, where required by applicable law, the affected individuals, in accordance with the timeframes and procedures set out in the law that applies to the breach.

19. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our services, our business practices, or applicable law. When we make material changes, we will post the revised Privacy Policy on this page and update the “Last Revised” date at the top. For material changes that affect paid subscribers, we will use commercially reasonable efforts to provide additional notice, for example, by email or in-app notification, at least thirty (30) days before the changes take effect.

Your continued use of the Platform after the effective date of any updated Privacy Policy constitutes your acceptance of the updates. If you do not agree to the updated Privacy Policy, you must stop using the Platform.

20. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our processing of your personal data, or if you wish to exercise any of the rights described above, please contact us at:

Solvent Capital Partners LLC
legal@keystone.markets

We aim to respond to all legitimate inquiries within five (5) business days.