Privacy Policy

Tech-Enabled Capital is a trade name used by Impact Fund LLC, a Wyoming limited liability company (“Tech-Enabled Capital,” “TEC,” “we,” “us,” or “our”). This Privacy Policy explains how we collect, use, disclose and otherwise process personal information when you visit our websites, communicate with us, request a company review, interact with our business, apply for a role, or use public-facing online services that link to this Policy (collectively, the “Site”).

This Policy applies to personal information for which TEC determines the purposes and means of processing. It does not govern personal information that TEC processes on behalf of an enterprise customer through our licensed technology and related services (“Customer Data”). Customer Data is governed by the applicable customer agreement and, where applicable, our Data Processing Addendum.

Depending on how you interact with us, we may collect the following.

Information you provide.

• Contact information, such as name, business email address, telephone number, mailing address and company.
• Professional information, such as title, role, employer, industry, company size and business interests.
• Inquiry and review information, including information submitted when requesting a confidential company review or discussing a potential engagement.
• Commercial and relationship information, including proposals, agreements, billing contacts, transactions and information concerning our business relationship.
• Communications, including emails, messages, call or meeting information, and other correspondence.
• Account information, if we provide a client portal or authenticated service.
• Recruiting information, including résumé or CV information and application materials.
• Other information you choose to provide.

Do not submit highly sensitive or specially regulated information through a general website form unless we specifically request it through an approved channel.

Information collected automatically. When you use the Site, we and service providers may automatically receive information such as IP address; browser and device type; operating system; referring and exit pages; pages viewed and links clicked; approximate location derived from IP address; timestamps; cookie or similar identifiers; and security, diagnostic and performance information. See our Cookie Policy.

Information from other sources. We may receive business contact information from customers, referrals, service providers, professional networks, public sources, business databases, marketing partners or other third parties where permitted by law.

We may process personal information to:

• operate, maintain, secure and improve the Site;
• respond to inquiries and requests;
• evaluate whether a company may be a fit for our technology;
• prepare for, enter into and administer business relationships;
• provide customer support and relationship management;
• authenticate users and protect accounts;
• detect, investigate and prevent fraud, abuse, security incidents and unlawful activity;
• analyze Site usage and performance;
• develop and improve our business, technology and internal operations;
• send service-related and administrative communications;
• send marketing or business-development communications where permitted by law;
• comply with legal obligations, enforce agreements, and establish, exercise or defend legal claims;
• evaluate candidates and administer recruiting; and
• carry out other purposes disclosed at collection or with consent.

Where applicable law requires a legal basis, we generally rely on one or more of: performance of a contract or steps requested before entering a contract; legitimate interests; compliance with legal obligations; and consent.

Our licensed technology may connect to systems selected by an enterprise customer and process information from those systems on the customer’s behalf.

For Customer Data:

• the customer determines the purposes for which its personal information is processed;
• TEC acts as a processor, service provider, contractor or subprocessor to the extent required by applicable law and the applicable agreement;
• processing is governed by the customer agreement and DPA;
• customer-specific source data remains the customer’s data; and
• TEC does not acquire ownership of a customer’s underlying company records merely because our technology processes them.

TEC’s reusable software, architecture, methods, generalized know-how, connectors, evaluations, model-routing logic, automation frameworks and other platform intellectual property are separate from Customer Data and are governed by the applicable customer agreement.

TEC is model-agnostic and may use different cloud, infrastructure, model, communications, security, analytics and other service providers depending on the workload and deployment.

When a third party processes Customer Data on our behalf, its role is governed by our DPA and applicable contractual controls. Under that DPA we identify a customer’s material subprocessors to them in writing before processing begins, and again on request — naming each provider’s purpose, its processing locations and the scope of data it handles.

That identification is made per engagement rather than published as a single list, because the providers differ by customer, workload, deployment, geography and configuration. A provider is identified only where it actually processes that customer’s data in the relevant production service.

Unless expressly authorized by the applicable customer agreement, TEC will not intentionally use identifiable Customer Data to train a generalized third-party AI model for that third party’s independent benefit.

We may disclose personal information to:

• Service providers and subprocessors providing hosting, infrastructure, AI or model inference, security, communications, analytics, payment, professional or operational services.
• Professional advisers, such as lawyers, accountants, auditors, insurers and consultants.
• Affiliates and corporate entities where necessary to operate our business.
• Business counterparties in connection with financing, merger, acquisition, sale, restructuring, diligence or a similar corporate transaction, subject to appropriate confidentiality protections.
• Authorities or other parties when disclosure is required or permitted by law, necessary to protect rights or safety, or appropriate to investigate fraud, security issues or violations.
• Other parties at your direction or with your consent.

We do not sell Customer Data.

We do not sell personal information for money. If we use analytics, advertising or measurement technologies that disclose identifiers or online activity to third parties, some U.S. privacy laws may treat those disclosures as a “sale,” “sharing,” or targeted advertising even where no money changes hands. Where applicable, we provide legally required choices through cookie controls or a Your Privacy Choices mechanism.

To the extent permitted by applicable law and our customer agreements, we may create or use information that has been aggregated or de-identified so that it cannot reasonably be used to identify an individual or customer.

We may use such information for security, analytics, service improvement, reliability, research, benchmarking and development of generalized capabilities, provided that we maintain required de-identification safeguards and do not attempt to re-identify the information except as permitted by law.

This section does not authorize us to pool identifiable Customer Data across customers or use identifiable Customer Data to train generalized models.

We may use cookies, pixels, tags, local storage and similar technologies for strictly necessary functionality; security and fraud prevention; remembering preferences; measuring Site performance and usage; analytics; and advertising or campaign measurement, if enabled.

Where consent is required, non-essential technologies are not activated until the required consent is obtained. See our Cookie Policy for the current inventory of what this Site actually uses.

We do not sell personal information, do not share it for cross-context behavioral advertising, and run no targeted-advertising technology, so there is currently no processing for an opt-out preference signal such as Global Privacy Control to act on, and the Site does not read one. If we adopt a technology that constitutes sale, sharing or targeted advertising under applicable law, we will implement that signal and a Your Privacy Choices or equivalent mechanism before the technology is enabled.

TEC and its service providers may process information in countries other than the country where it was collected.

Where required, we use appropriate safeguards for international transfers, which may include adequacy decisions, contractual protections, the European Commission’s Standard Contractual Clauses, the UK International Data Transfer Addendum, or other legally recognized mechanisms.

Customer Data transfer terms are addressed in the applicable DPA.

We retain personal information only for as long as reasonably necessary for the purposes described in this Policy, including to provide and administer our services; maintain our relationship with you; comply with legal, tax, accounting and recordkeeping requirements; resolve disputes and enforce agreements; and prevent fraud or security incidents.

Retention varies based on the type and sensitivity of information, contractual requirements, legal obligations, and whether the information remains necessary for an active business purpose.

Customer Data retention and deletion are governed by the applicable customer agreement and DPA.

We use administrative, technical and organizational safeguards designed to protect personal information against unauthorized access, use, alteration, loss or disclosure.

No system can be guaranteed to be completely secure. Detailed security commitments for Customer Data, if any, are governed by the applicable customer agreement and DPA.

We do not represent that TEC holds a certification, audit status or regulatory designation unless we expressly state that it currently does.

Depending on your location and applicable law, you may have rights to:

• access or know about personal information we process;
• obtain a copy of certain personal information;
• correct inaccurate information;
• delete information;
• restrict or object to certain processing;
• withdraw consent where processing is based on consent;
• opt out of certain sale, sharing, targeted advertising or profiling;
• limit certain uses of sensitive personal information;
• request portability;
• appeal a privacy-request decision; and
• lodge a complaint with an applicable regulator.

To exercise a privacy right, contact privacy@techenabledcapital.com.

We may verify your identity and authority before completing a request. Authorized agents may submit requests where permitted by law. We will not unlawfully discriminate against you for exercising privacy rights.

California. If the California Consumer Privacy Act, as amended (“CCPA”), applies to TEC in a given context, California residents may have rights to know or access, delete, correct, opt out of sale or sharing, limit certain uses of sensitive personal information, and receive nondiscriminatory treatment. If sale or sharing occurs through enabled advertising or measurement technologies, we will provide the required opt-out mechanism and honor applicable opt-out preference signals.

EEA, United Kingdom and Switzerland. Where GDPR, UK GDPR or equivalent law applies, you may have rights including access, rectification, erasure, restriction, objection, portability, withdrawal of consent, and complaint to a supervisory authority, subject to applicable conditions and exceptions.

United Arab Emirates. Where the UAE Federal Personal Data Protection Law applies, data subjects may have rights relating to information, correction, restriction or cessation of processing, and other rights provided by applicable law.

You may unsubscribe from promotional email using the unsubscribe mechanism in the message or by contacting us.

Even if you opt out of marketing, we may continue sending transactional, relationship, security or administrative communications.

The Site is intended for business users and is not directed to children.

Do not submit personal information about children through the Site unless expressly requested and legally permitted in connection with an authorized business relationship.

The Site may link to third-party websites or services. Their privacy practices are governed by their own policies, and TEC is not responsible for their independent processing.

We may update this Privacy Policy periodically. If we make material changes, we may provide additional notice where required by law.

Impact Fund LLC
doing business as Tech-Enabled Capital
Privacy: privacy@techenabledcapital.com

If a jurisdiction requires a data protection representative or officer, applicable contact details will be provided here or in the relevant supplemental notice.