Privacy Policy

CloudWorx Capital LLC ("CloudWorx Capital," "we," "us," or "our") is committed to protecting your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website at cloudworxai.org (the "Site"), contact us through any means, or interact with our investment activities. Please read this policy carefully. If you disagree with its terms, please discontinue use of the Site.

We reserve the right to make changes to this Privacy Policy at any time and for any reason. We will alert you about any changes by updating the "Last updated" date of this Privacy Policy. You are encouraged to periodically review this Privacy Policy to stay informed of updates.

1. Information We Collect

1.1 Personal Information You Provide Directly

We may collect personal information that you voluntarily provide when you:

• Complete and submit our contact or investment inquiry forms
• Subscribe to our newsletter or research publications
• Correspond with us by email, phone, or other means
• Attend events or conferences where we are present
• Submit a pitch deck or business plan for evaluation

The personal information we collect in these contexts may include:

• Identity data: First name, last name, job title, company name
• Contact data: Email address, telephone number, postal address
• Professional data: LinkedIn profile, professional background, company stage and sector
• Financial data: In connection with formal investor or founder relationships, we may collect information about your financial position or your company's financial condition as required by law or our investment process
• Communications data: The content of messages, inquiries, and correspondence you send us

1.2 Information We Collect Automatically

When you visit our Site, we may automatically collect certain technical information about your device and browsing activity, including:

• Log data: Your IP address, browser type and version, operating system, referring URLs, pages visited, time and date of your visit, time spent on pages
• Device data: Device type, device identifiers, screen resolution, language preference
• Usage data: How you interact with the Site, including which links you click and which pages you view
• Cookie data: Please see our Cookie Policy for detailed information on how we use cookies and similar tracking technologies

1.3 Information From Third Parties

We may receive personal information about you from third parties in certain circumstances:

• Portfolio companies: Our portfolio companies may share information with us about their employees, customers, or counterparties in connection with our investment oversight activities
• Professional references: With your knowledge and consent, we may receive professional reference information about you from third parties you have identified
• Public sources: We may collect information about founders, executives, and potential investment targets from publicly available sources including professional networks, publications, and company filings
• Analytics providers: We may receive aggregated and anonymized analytics data from third-party analytics services

2. How We Use Your Information

We use the personal information we collect for the following purposes:

2.1 To Provide and Manage Our Services

• Respond to your inquiries and communications promptly and accurately
• Process and evaluate investment opportunity submissions
• Manage our relationships with portfolio companies, limited partners, and business partners
• Administer your account or relationship with us

2.2 For Business Operations

• Conduct due diligence in connection with potential and existing investments
• Maintain our deal flow database and investment records
• Prepare and distribute investor reports and communications
• Manage our internal operations, including financial management and compliance activities

2.3 For Marketing and Communications

• Send you newsletters, research publications, and updates about our investment activities, subject to your communication preferences
• Invite you to events, conferences, and other activities relevant to our work
• Conduct surveys and gather feedback to improve our services

2.4 To Improve Our Site and Operations

• Analyze how visitors use our Site to improve its content and functionality
• Monitor and improve the security and performance of our Site
• Diagnose technical problems and prevent fraudulent activity

2.5 To Comply With Legal Obligations

• Comply with applicable laws, regulations, and regulatory guidance
• Respond to lawful requests from public authorities, including law enforcement
• Enforce our legal rights and protect against legal claims
• Satisfy financial recordkeeping and anti-money-laundering obligations

3. Legal Basis for Processing (For EEA/UK Residents)

If you are located in the European Economic Area or the United Kingdom, we process your personal data based on one or more of the following legal grounds:

• Legitimate interests: Processing is necessary for our legitimate business interests, including managing our investment activities, communicating with founders and investors, and operating our Site
• Contractual necessity: Processing is necessary to perform a contract with you or to take steps at your request before entering a contract
• Legal obligation: Processing is necessary to comply with our legal and regulatory obligations
• Consent: Where required by law, we will obtain your explicit consent before processing your personal data for specific purposes, such as sending marketing communications

4. Information Sharing and Disclosure

We do not sell, rent, or trade your personal information to third parties for their marketing purposes. We may share your information in the following circumstances:

4.1 Service Providers

We may share your information with trusted third-party service providers who assist us in operating our website and business, including:

• Cloud hosting and infrastructure providers
• Customer relationship management (CRM) software providers
• Email service providers and marketing platforms
• Analytics and website performance services
• Legal, accounting, and professional advisory firms

All service providers are bound by confidentiality obligations and are authorized to use your personal information only as necessary to provide services to us.

4.2 Legal Requirements

We may disclose your information when we believe disclosure is appropriate to:

• Comply with applicable laws, regulations, legal processes, or government requests
• Protect the rights, property, or safety of CloudWorx Capital, our investors, portfolio companies, or the public
• Detect, prevent, or address fraud, security, or technical issues

4.3 Business Transfers

In connection with a merger, acquisition, sale of assets, or other business reorganization, your information may be transferred as part of that transaction. We will notify you via the email address on file or by prominent notice on our Site if such a transfer occurs, and we will inform you of any choices you may have regarding your personal information.

4.4 With Your Consent

We may share your information with third parties when you have given us your explicit consent to do so.

5. Data Retention

We retain personal information for as long as necessary to fulfill the purposes described in this policy, unless a longer retention period is required or permitted by applicable law. Our general retention standards are as follows:

Category of Data	Retention Period	Basis
Investment inquiry and deal flow records	7 years from last interaction	Regulatory recordkeeping requirements
Portfolio company records	Duration of investment + 10 years	Financial recordkeeping obligations
General contact and correspondence	3 years from last interaction	Legitimate business interests
Website analytics data	26 months	Analytical purposes
Marketing consent records	Until withdrawn + 3 years	Legal compliance

When we no longer have a legitimate need to retain your personal information, we will delete or anonymize it. If deletion is not immediately possible (for example, because the information is stored in backup archives), we will securely store the information and isolate it from further processing until deletion is possible.

6. Your Privacy Rights

Depending on your jurisdiction, you may have some or all of the following rights regarding your personal information:

• Right of access: You may request a copy of the personal information we hold about you
• Right to rectification: You may request that we correct inaccurate or incomplete personal information about you
• Right to erasure: You may request that we delete your personal information in certain circumstances
• Right to restrict processing: You may request that we restrict the processing of your personal information in certain circumstances
• Right to data portability: You may request a copy of your personal information in a structured, commonly used, machine-readable format
• Right to object: You may object to our processing of your personal information based on our legitimate interests
• Right to withdraw consent: Where we process your information based on your consent, you may withdraw that consent at any time

To exercise any of these rights, please contact us at our contact page or by email at privacy@cloudworxai.org. We will respond to your request within 30 days. We may need to verify your identity before processing your request.

7. California Privacy Rights

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA). These rights include:

• The right to know what personal information we have collected, used, disclosed, or sold about you
• The right to delete personal information we have collected from you, subject to certain exceptions
• The right to opt-out of the sale or sharing of your personal information
• The right to correct inaccurate personal information
• The right to non-discrimination for exercising your privacy rights

We do not sell personal information as defined under California law. To submit a CCPA request, please contact us at privacy@cloudworxai.org or through our contact page.

8. New York Residents

CloudWorx Capital is headquartered in New York. We comply with applicable New York State privacy laws, including the New York SHIELD Act. We have implemented reasonable administrative, technical, and physical safeguards designed to protect your personal information against unauthorized access, disclosure, alteration, or destruction.

9. International Data Transfers

CloudWorx Capital is based in the United States. If you are located outside the United States and choose to provide personal information to us, your information will be transferred to and processed in the United States. The data protection laws of the United States may not provide the same level of protection as those in your country. By using our Site or providing us with your information, you consent to this transfer.

For transfers from the European Economic Area or the United Kingdom, we implement appropriate safeguards as required by applicable data protection law, which may include standard contractual clauses approved by the relevant data protection authorities.

10. Security

We implement commercially reasonable technical and organizational measures designed to protect your personal information against unauthorized access, disclosure, alteration, or destruction. These measures include:

• Encryption of data in transit using TLS/SSL protocols
• Access controls limiting who within our organization can access personal information
• Regular security assessments of our systems and practices
• Employee training on data protection and security practices

No method of transmission over the internet or method of electronic storage is completely secure. While we use commercially reasonable means to protect your personal information, we cannot guarantee its absolute security. In the event of a data breach that is likely to result in a high risk to your rights and freedoms, we will notify you as required by applicable law.

11. Third-Party Websites

Our Site may contain links to third-party websites and services. This Privacy Policy does not apply to those external websites. We are not responsible for the privacy practices of third-party websites and encourage you to review the privacy policies of any website you visit. Links to third-party websites do not constitute our endorsement of those websites or their content.

12. Children's Privacy

Our Site is not directed to children under the age of 16. We do not knowingly collect personal information from children under 16. If you believe we have inadvertently collected personal information from a child under 16, please contact us immediately at privacy@cloudworxai.org and we will promptly delete such information.

13. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will post the updated Privacy Policy on this page and update the "Last updated" date at the top of the policy. For significant changes, we may also provide more prominent notice, such as an email notification to individuals who have provided contact information. Your continued use of our Site after any changes constitutes your acceptance of the updated Privacy Policy.

14. Contact Us

If you have questions, concerns, or complaints about this Privacy Policy or our privacy practices, or if you wish to exercise any of your privacy rights, please contact us:

CloudWorx Capital LLC
847 Madison Avenue, Suite 1200
New York, NY 10065
Email: privacy@cloudworxai.org
General inquiries: Contact page

If you are located in the European Economic Area and have concerns about our data processing activities that we have been unable to resolve, you have the right to lodge a complaint with your local data protection authority.

This Privacy Policy was last reviewed and updated on March 1, 2025. Please check back periodically for any updates.