Privacy Policy


Your privacy is very important to us. Federal law requires us to tell you how we collect, share and protect your personal information. In addition, Federal law gives you the right to limit some but not all sharing of such information. This Privacy Notice sets forth our policies with respect to non- public personal information of current, prospective and former investors in the Company, and may be changed at any time, provided a notice of such change is given to you.

You provide us with personal information, such as your street address, email address, Social Security or Employee Identification Number, assets and/or income information (i) in the subscription agreement, investor questionnaires and related documents, (ii) in correspondence and conversations with the Company’s and the Company’s representatives, and (iii) through transactions with the Company. We may also collect such information from third parties.

We do not disclose any of this non-public personal information about the subscribers to anyone, other than to our affiliates for ordinary business purposes, and to non-affiliated third parties (i) to the extent the procedures set forth in this Notice have been complied with and the subscriber has not opted out of disclosure; (ii) to the extent necessary to administer or effect a transaction that the subscriber has requested or authorized, including as necessary to facilitate investment in the Company; (iii) to service providers or joint marketers who agree to limit their use of such information; (iv) to the extent necessary to obtain financing for the Company; (v) with the consent or at the direction of the subscriber; (vi) to protect the confidentiality or security of our records; (vii) for required institutional risk control or for resolving subscriber disputes or inquiries; (viii) to persons holding a legal or beneficial interest relating to the subscriber; (ix) to persons acting in a fiduciary or representative capacity on behalf of the subscriber; and (x) to the extent required or specifically permitted by law or reasonably necessary to prevent fraud, unauthorized transactions or liability.

We may also release non-public personal information about you if you direct us to do so, if we are compelled to do so by law, or in connection with any government or self-regulatory organization request or investigation.

We may also disclose personal information such as your street address, email address, Social Security or Employee Identification Number, assets and/or income information to non- affiliated service providers (including marketers) who agree to limit their use of such information to the purposes for which that information was disclosed to the third party.

SMS/Text Usage
We may also use the information we obtain in connection with our SMS/text messaging in accordance with our Ashcroft Capital SMS Privacy Policy. We collect the following personal information about you in the context of our text messaging program: your name, mobile phone number, and texting preferences (opt-ins and opt-outs). We use this information to manage our text messaging program, including to send you text messages regarding our investment products. Your wireless carrier may collect data about your wireless device usage, and its practices are governed by its own policies. We take measures to protect your sensitive personal information but cannot guarantee its security in transit or storage.


You have the right to direct us not to disclose your non-public personal information to:
(i) our affiliates for their everyday business purposes (in the case of information about your creditworthiness); (ii) our affiliates for their purpose of marketing to you; and (iii) non- affiliated third parties for their purpose of marketing to you. You may exercise this right by emailing us at and instructing our CCO that you would like to opt out of disclosure.

We seek to carefully safeguard your private information, and, to that end, we restrict access to non- public personal information about you to those employees who need to know that information to provide products or services to you. We maintain physical, electronic and procedural safeguards to protect your non-public personal information.