alts.co

Privacy Policy

Last updated: 25 May 2026

1. Introduction

This Privacy Policy describes how Alt Assets Manager, LLC ("we", "us", "our") collects, uses, and protects personal information when you use our website and platform at alts.co (the "Platform"). By using the Platform, you consent to the practices described in this policy.

2. Information we collect

Information you provide directly

When you use the Platform, you may provide us with the following categories of personal information:

  • Contact information: name, email address, phone number, and mailing address.
  • Accreditation and qualification information: employment status, income, net worth, and other information relevant to your accredited investor status under SEC Rule 501 of Regulation D.
  • Identity verification information: government-issued identification, date of birth, and other information required to verify your identity.
  • Investment-related information: investment preferences, allocation amounts, and banking details required to process capital transfers.
  • Communications: any messages, enquiries, or correspondence you send to us.

Information collected automatically

When you access the Platform, we may automatically collect:

  • Device and browser information: IP address, browser type and version, operating system, and device identifiers.
  • Usage data: pages viewed, time spent on pages, navigation paths, and referring URLs.
  • Cookies and similar technologies: see Section 7 below.

Information from third parties

We may receive information about you from third-party service providers, including:

  • Form and survey providers: responses submitted through qualification forms.
  • Electronic signature providers: signature status and timestamps for non-disclosure agreements and subscription documents.
  • Identity verification providers: results of accreditation and identity checks.

Mobile Information and SMS Messaging

If you opt in to receive SMS messages from Launch Film Finance (Alt Assets Inc), we collect your mobile phone number and your record of consent (date, time, IP address, and the consent text you agreed to). We use this information solely to deliver the SMS messages you have requested, including account notifications, agreement-signature reminders, distribution updates, and notices of new investment opportunities, and to keep an auditable record of consent as required by applicable regulations. SMS is never used to log in or authenticate your identity.

No mobile information will be shared with third parties or affiliates for marketing or promotional purposes. Information sharing with subcontractors in support of the SMS programme, such as our messaging service provider Twilio Inc., is permitted solely to deliver the messages you have requested. All other categories of personal information described in this Privacy Policy exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

You may opt out of SMS messages at any time by replying STOP to any message you receive from us. You may request help by replying HELP. Opting out of SMS will not affect your ability to use film.alts.co or your investor account.

3. How we use your information

We use your personal information for the following purposes:

  • Platform access and account management: to create and manage your account, authenticate your identity via one-time passwords, and provide access to the Platform.
  • Qualification and compliance: to verify your accredited investor status as required under SEC Rule 506(c) of Regulation D, and to maintain records as required by applicable securities laws.
  • Investment processing: to facilitate your participation in co-investment opportunities, including document execution, capital calls, and distributions.
  • Communication: to send you transactional messages (e.g., one-time passwords, deal notifications, and investment updates) and to respond to your enquiries.
  • Legal and regulatory compliance: to comply with applicable laws, regulations, and legal processes, including anti-money laundering and know-your-customer requirements.
  • Platform improvement: to analyse usage patterns and improve the functionality and security of the Platform.

4. Legal basis for processing

Where applicable (including under GDPR for users in the European Economic Area and United Kingdom), we process your personal information on the following legal bases:

  • Contract: processing necessary to perform our agreement with you or to take steps at your request prior to entering into an agreement.
  • Legal obligation: processing necessary to comply with securities regulations, anti-money laundering laws, and other applicable legal requirements.
  • Legitimate interests: processing necessary for our legitimate interests in operating and improving the Platform, provided those interests are not overridden by your rights and freedoms.
  • Consent: where you have provided explicit consent, such as for receiving marketing communications. You may withdraw consent at any time.

5. How we share your information

We do not sell your personal information. We may share your information with the following categories of recipients:

  • Service providers: third-party providers that perform services on our behalf, including form collection, electronic signatures, email delivery, data storage and management, and hosting. These providers are contractually obligated to use your information only as necessary to provide their services.
  • Legal and regulatory authorities: when required by law, regulation, legal process, or governmental request, or when we believe disclosure is necessary to protect our rights, your safety, or the safety of others.
  • Professional advisers: legal, accounting, and other professional advisers in connection with the operation of our business.
  • Business transfers: in connection with any merger, acquisition, reorganisation, or sale of assets, your information may be transferred to the acquiring entity.

We will not share confidential investment materials or your accreditation information with other investors or unrelated third parties.

6. Data retention

We retain your personal information for as long as necessary to fulfil the purposes described in this policy, or as required by applicable law. Specifically:

  • Qualification and accreditation records: retained for the duration of any active investment and for a minimum of five years thereafter, or as required by applicable securities regulations.
  • Transaction records: retained as required by applicable tax and securities laws.
  • Account information: retained for as long as your account remains active and for a reasonable period thereafter.
  • Communications: retained for as long as necessary to resolve any enquiry or dispute.

You may request deletion of your personal information at any time (see Section 9), subject to our legal and regulatory retention obligations.

7. Cookies and tracking technologies

The Platform uses essential cookies required for the Platform to function, including session management and authentication.

We do not currently use third-party advertising cookies or cross-site tracking technologies. If this changes, we will update this policy and provide you with appropriate notice and choice.

8. Data security

We implement appropriate technical and organisational measures to protect your personal information against unauthorised access, alteration, disclosure, or destruction. These measures include encryption of data in transit, access controls, and regular security reviews.

No method of transmission over the internet or electronic storage is completely secure. While we strive to protect your information, we cannot guarantee its absolute security.

9. Your rights

Depending on your jurisdiction, you may have the following rights regarding your personal information:

  • Access: the right to request a copy of the personal information we hold about you.
  • Correction: the right to request correction of inaccurate or incomplete information.
  • Deletion: the right to request deletion of your personal information, subject to legal and regulatory retention requirements.
  • Restriction: the right to request restriction of processing of your personal information.
  • Portability: the right to receive your personal information in a structured, commonly used, and machine-readable format.
  • Objection: the right to object to processing of your personal information based on legitimate interests.
  • Withdrawal of consent: where processing is based on consent, the right to withdraw consent at any time.

To exercise any of these rights, contact us at hello@alts.co. We will respond to your request within 30 days, or as required by applicable law.

California residents

If you are a California resident, you may have additional rights under the California Consumer Privacy Act (CCPA), including the right to know what personal information we collect, disclose, and sell (we do not sell personal information), and the right to opt out of the sale of personal information.

10. International data transfers

Your personal information may be transferred to and processed in countries other than your country of residence, including the United States. Where required by applicable law, we will ensure appropriate safeguards are in place to protect your information, such as standard contractual clauses or other approved transfer mechanisms.

11. Children

The Platform is not directed at individuals under the age of 18. We do not knowingly collect personal information from children. If we become aware that we have collected personal information from a child, we will take steps to delete it promptly.

12. Changes to this policy

We may update this Privacy Policy from time to time. If we make material changes, we will notify you by updating the "Last updated" date at the top of this page. We encourage you to review this policy periodically.

13. SMS communications

We may send you SMS text messages for the following purposes, where you have provided your mobile number and given consent:

  • Transactional SMS: account notifications, agreement-signature reminders, and time-sensitive account updates.
  • Account and investment notifications: account updates, distribution updates, and alerts about new investment opportunities.

You provide consent by entering your mobile number and ticking the optional consent checkbox on our public SMS opt-in page at https://film.alts.co/sms-opt-in. This page is publicly accessible and does not require an account or login. Consent is optional and is not a condition of using film.alts.co or your investor account.

Message frequency varies. Message and data rates may apply. You may opt out at any time by replying STOP to any message, and reply HELP for help. To re-subscribe, reply START or complete the opt-in form again at https://film.alts.co/sms-opt-in.

14. Sub-processors

We use the following third-party sub-processors to provide the Platform. Each is contractually bound to protect your data:

  • Airtable — Data storage and management (investor records, deal data, and operational data)
  • Resend — Transactional email delivery (login codes, deal notifications, confirmations)
  • Persona — Identity verification (KYC) and accreditation checks
  • BoldSign — Electronic signatures for NDAs, co-investment agreements, and capital account documents
  • Twilio — SMS delivery for account and deal notifications

This list is updated whenever we add or remove a sub-processor. Material changes will be reflected in the "Last updated" date at the top of this page.

15. Contact

If you have questions or concerns about this Privacy Policy or our data practices, contact us at:

Alt Assets Manager, LLC
600 Congress Ave, Suite 1400, Austin, TX 78701
hello@alts.co