Privacy Policy
Version 6/30/2026
How Custom Capital protects investor information.
1. Information We Collect
We may collect the following categories of information when you interact with Custom Capitalsm:
- Identity data: name, date of birth, government-issued ID, social security or tax ID.
- Financial data: net worth, income, accreditation documentation, bank account details.
- Contact data: email address, phone number, mobile phone number (if voluntarily provided for SMS communications), mailing address.
- Technical data: IP address, device identifiers, browser information.
- Communications: webinar registrations, Zoom meetings, phone/SMS interactions.
2. How We Use Your Information
We process personal data for the following purposes:
- Investor verification & compliance (KYC/AML, accredited status).
- Transaction processing (subscriptions, fund transfers, distributions).
- Legal obligations (recordkeeping, tax reporting, regulatory filings).
- Investor communications (webinars, email updates, marketing with consent).
- Risk management & fraud prevention.
3. How We Share Your Information
We may share your information with:
- Service providers: KYC vendors, custodians, escrow banks, fund administrators.
- Regulators & legal authorities: where required by law or regulation.
- Affiliates: for compliance, operations, and investor servicing.
- Third-party marketing partners: only with your prior opt-in consent.
- Qualified intermediary (§1031 exchange) referral partners — but only if you have indicated interest in a §1031 like-kind exchange and have specifically opted in to our sharing your contact information with a qualified intermediary partner. See Section 3.A
We do not sell personal data.
3.A §1031 Exchange Referral Partners
If you tell us you’re interested in a §1031 like-kind exchange and you opt in, we may share your contact information — your name, email, and state, and (only if you provide it and consent) your phone number — with the specific qualified intermediary partner we identify to you at the time you opt in so they can contact you about exchange services. We do not receive any fee, commission, reciprocal lead credit, or other thing of value for this referral. You can see our
current list of qualified intermediary partners at customcapital.com/partners. You can opt out at any time by emailing privacy@customcapital.com or by using the partner’s own opt-out; if you ask us, we will tell the partner to stop contacting you.
4. Security Measures
We implement reasonable technical and organizational measures to protect your data, including:
- Encryption of sensitive data in transit and at rest.
- Access controls (role-based, least-privilege).
- Audit logging and monitoring.
- Vendor due diligence with data protection agreements.
5. Data Retention
- KYC/AML records: retained for at least 5–7 years after transaction closure.
- Financial records: retained as required by applicable law, including tax law, to meet legal, tax, or contractual obligations, but in no event longer than 7 years.
- Marketing data: retained until you opt out or request deletion.
- General inquiries: deleted after resolution unless legally required.
6. Your Rights
Depending on your jurisdiction, you may have the right to:- Access the data we hold about you.
- Correct inaccurate or incomplete data.
- Request deletion of certain personal data.
- Restrict or object to specific types of processing.
- Data portability (where legally applicable).
- Withdraw consent for marketing at any time.
7. Cookies & Tracking
- We use cookies to improve site functionality, remember login preferences, and analyze site usage.
- You can control cookies through your browser settings.
- Analytics data is aggregated and not linked to identifiable individuals.
8. Analytics
We will not sell, distribute or lease your personal information to third parties unless we have your permission or are required by law. We may use your personal information to send you promotional information about third parties which we think you may find interesting if you tell us that you wish this to happen. Unless there are extenuating circumstances we retain this information for not longer than 2 years. If you believe that any information we are holding on you is incorrect or incomplete, please write to or email us as soon as possible. We will promptly correct any information found to be incorrect.9. Anonymization Methods
Generalization / Aggregation
- Reduce data precision to avoid identifiability.
- Example: Store “35–40 years old” instead of exact age, or “Investor in California” instead of full street address.
- Often used in analytics/remarketing to reduce risk of re-identification.
- Re-marketing is limited to not more than 2 years.
Noise Addition / Differential Policy
- Add statistical “noise” to datasets so individual records can’t be pinpointed.
- Used by Apple, Google, and the U.S. Census Bureau.
- Example: Add ±5% random variation to reported numbers in aggregate investor surveys.
10. Marketing & Communications
We may send marketing messages via email, SMS, or phone only if you consent.
You may opt out of marketing communications at any time by clicking “unsubscribe” or replying “STOP” to SMS.
Opting out does not affect transaction-related communications.
If you opted in to the §1031 referral partner sharing described in Section 3.A, the qualified intermediary partner may also contact you using the information you authorized. You can stop those messages using the partner’s own opt-out, or by emailing privacy@customcapital.com and we will notify the partner.
11. SMS Communications & Mobile Data
If you opt in to receive SMS/text messages from Custom Capital, you may receive informational or marketing messages related to your relationship with us, including meeting reminders, service updates, or account-related communications. Message frequency may vary. Message and data rates may apply.
You may opt out at any time by replying STOP. For assistance, reply HELP or contact us directly.
We do not sell, rent, or share your mobile information, SMS consent, or mobile opt-in data with third parties or affiliates for their general marketing or promotional purposes, with one exception:
if you specifically opt in to be contacted by a specifically identified §1031 qualified intermediary partner described in Section 3.A, we will share your phone number and the related consent record with that partner solely so they can contact you about the §1031 exchange services you requested. We do not otherwise sell, rent, or share your mobile or SMS opt-in data for any third party’s unrelated marketing.
12. Surveys & Contests
From time to time our site may request information via surveys or contests. Participation is completely voluntary and you may choose whether to participate. Information requested may include contact information (such as name and shipping address) and demographic information (such as zip code, age level). Contact information will be used to notify winners and award prizes. We minimize collection to only what is necessary and do not use survey data for profiling or resale.13. Third-party Links
Our website may contain links to third-party websites or services. We are not responsible for the privacy practices or content of those third parties. We encourage you to review their privacy policies before providing personal information.14. What Third Parties We Receive Data From
We may collect, and allow third parties to collect, information about how you use and interact with our Site and Services. For example, we may use Google Analytics, Google AdWords, and Facebook Advertising to gain insights and improve the functionality of our website. These records are retained for not less than 2 years. All investor data is anonymized. This does not include SMS opt-in data or mobile phone numbers collected for messaging purposes.15. Data Breach Procedures
In accordance with law, we will notify you if there is a breach of your personal information and inform you of what steps you need to take to protect yourself.16. TCPA (Telephone Consumer Protection Act) Consents
- Express Written Consent. By using our website and submitting your contact information, you provide express written consent to receive communications from us at the email and telephone numbers entered, via live, automated or prerecorded email, text, or call.
- E-Mails, Texts, and Calls. These communications may include website updates, information about products and services, and telemarketing messages.
- Automation. Carrier’s standard rates and charges may apply. In the event of an opt-out failure please contact us at privacy@customcapital.com.
- No Purchase Necessary. Agreeing to these communications is not a condition of purchasing any property, goods, or services from us.
- Revoking Consent and Opting Out. You may revoke consent by replying “STOP” to texts or using the “unsubscribe” link in emails.
- §1031 Referral Partners. If you opt in to be contacted by a §1031 qualified intermediary partner (see Section 3.A), we will identify the specific partner — or the specific category of partners — to you at the time you opt in, so you know who is authorized to contact you. For calls or texts that may be telemarketing or use automated or prerecorded technology, your opt-in will authorize the named partner, identify your phone number, state that consent is not required as a condition of any purchase, and be kept as a time-stamped electronic record.
17. CCPA (California Consumer Privacy Act)
Under the CCPA, California consumers have the right to:- Request that a business disclose the categories and specific pieces of personal data collected.
- Request that a business delete any personal data collected.
- Request that a business not sell the consumer’s personal data.
18. Other States – Universal Statement
Residents of certain U.S. states (including California, Colorado, Connecticut, Utah, Virginia, and others) may have rights regarding their personal information, such as the right to access, delete, or opt-out of certain processing. To exercise these rights, contact us at privacy@customcapital.com.19. Additional Communications Provisions (Canada)
Canadian residents agree to provisions related to compliance with CASL, PIPEDA, and Canadian provincial law including Alberta’s PIPA and Quebec’s privacy act. You agree to the provisions in our Privacy Policy; communications will continue until you revoke consent or opt out; and your personal information may be transmitted to, used in, and stored in the United States.20. GDPR (General Data Protection Regulation)
We want you to be aware of all your data protection rights. Every user is entitled to the following:- The right to access — request copies of your personal data.
- The right to rectification — request that we correct inaccurate or incomplete data.
- The right to erasure — request deletion of your personal data, under certain conditions.
- The right to restrict processing — under certain conditions.
- The right to object to processing — under certain conditions.
- The right to data portability — request transfer of your data to another organization.
21. International Data Transfers
If you are outside the United States, your data may be transferred to and processed in the U.S. where privacy laws may differ. Safeguards such as Standard Contractual Clauses or equivalent protections are used. We will notify you if transfer mechanisms change materially.22. Children’s Privacy
We do not knowingly collect data from individuals under 18. If we learn that such information has been collected, we will delete it promptly.23. Policy Changes
We will provide additional notice of significant updates. We will post the date our Privacy Policy was last updated at the top of the policy. We will provide direct notice in the event of a material changeContact Us
For privacy inquiries, requests, or concerns, please reach out to our privacy team.privacy@customcapital.com
By interacting with our platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, use, and sharing of your information as described.
