Privacy Policy

Delbrass Invest LLC
Effective Date: 04/15/2026
Last Updated:05/01/2026

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1. Overview

Delbrass Invest LLC (“Delbrass Invest,” “Company,” “we,” “our,” or “us”) is committed to maintaining the confidentiality, integrity, and security of personal information entrusted to us.

This Privacy Policy describes how we collect, use, disclose, and safeguard information in connection with our website, investor communications, and related services (collectively, the “Services”).

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2. Scope of Policy

This Policy applies to:

• Website visitors

• Prospective investors

• Clients and business partners

• Representatives of institutional counterparties

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3. Categories of Information Collected

3.1 Personal Identifiers

• Name, email address, phone number

• Mailing or business address

• Government-issued identification (if required for compliance)

3.2 Financial and Investment Information

• Investment experience and objectives

• Accredited investor status

• Transaction and account information

3.3 Technical and Usage Data

• IP address

• Device identifiers

• Browser type and interaction data

3.4 Compliance-Related Data

To comply with regulatory obligations, we may collect:

• Know Your Customer (KYC) information

• Anti-Money Laundering (AML) verification data

• Sanctions screening results

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4. Legal Bases for Processing

Where applicable, we process personal information under the following bases:

• Performance of a contract

• Compliance with legal and regulatory obligations

• Legitimate business interests

• Consent (where required)

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5. Use of Information

We use collected information for purposes including:

• Providing investment-related services and communications

• Conducting due diligence and investor onboarding

• Meeting regulatory requirements (KYC, AML, sanctions compliance)

• Risk management and fraud prevention

• Internal analytics and operational improvements

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6. Disclosure of Information

We do not sell personal information. We may disclose information to:

6.1 Service Providers

Third-party vendors providing:

• Fund administration

• Custody and banking services

• Legal, tax, and audit services

• Technology infrastructure

6.2 Regulatory Authorities

We may disclose information to governmental or regulatory bodies when required, including but not limited to the U.S. Securities and Exchange Commission and other applicable authorities.

6.3 Business Transactions

In connection with mergers, acquisitions, or restructuring activities.

6.4 Legal Protection

To enforce our rights, prevent fraud, or ensure the safety of our operations.

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7. Data Retention

We retain personal information only as long as necessary to:

• Fulfill the purposes outlined in this Policy

• Comply with legal, regulatory, and recordkeeping obligations

• Resolve disputes and enforce agreements

Retention periods may extend beyond the termination of client relationships where required by law.

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8. Data Security

We implement industry-standard safeguards, including:

• Encryption protocols

• Access controls and authentication systems

• Secure data storage environments

Despite these measures, no system can guarantee absolute security.

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9. Your Rights (U.S. and California Residents)

Subject to applicable law, individuals may have the right to:

• Access personal information we hold

• Request correction of inaccurate data

• Request deletion of personal data

• Opt out of certain data sharing practices

We will not discriminate against users for exercising privacy rights.

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10. Cookies and Tracking Technologies

We use cookies and similar technologies to:

• Analyze website traffic

• Improve functionality

• Enhance user experience

Users may control cookie preferences through browser settings.

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11. International Data Transfers

Information may be transferred to and processed in the United States or other jurisdictions where our service providers operate.

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12. Children’s Information

Our Services are not directed to individuals under the age of 18. We do not knowingly collect data from minors.

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13. Confidentiality and Investor Information

We treat investor-related information as confidential and apply heightened safeguards consistent with industry expectations for private investment firms.

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14. Changes to This Privacy Policy

We reserve the right to update this Policy at any time. Updates will be reflected by the “Last Updated” date.

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15. Contact Information

For questions regarding this Privacy Policy or data practices:

Delbrass Invest LLC
support@delbrass.com

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16. Important Disclosures

16.1 No Investment Advice

Content provided on this Website does not constitute an offer to sell or a solicitation of an offer to buy securities.

16.2 Regulatory Status

Delbrass Invest LLC may not be registered as an investment advisor with the U.S. Securities and Exchange Commission or any state securities authority unless explicitly stated.

16.3 Forward-Looking Statements

Certain statements may constitute forward-looking statements subject to risks and uncertainties.

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17. Digital Assets & Cryptocurrency Compliance Addendum

17.1 Scope

This section governs the collection, use, custody, and compliance treatment of digital assets (“Digital Assets”), including cryptocurrencies, tokens, and blockchain-based financial instruments, in connection with Delbrass Invest LLC’s operations.

17.2 Nature of Digital Assets

Digital Assets are treated as property under applicable U.S. regulatory guidance, including positions issued by the Internal Revenue Service. As such, transactions involving Digital Assets may have tax and reporting implications.

17.3 Wallets and Custody

Delbrass Invest LLC may utilize one or more of the following custody models:

• Self-Custody Wallets: Controlled directly by the Company using private keys

• Third-Party Custodians: Regulated or institutional providers

• Multi-Signature Wallets: Requiring multiple approvals for transaction execution

We implement internal controls designed to mitigate risks associated with unauthorized access, loss of private keys, and operational errors.

17.4 Blockchain Transparency

Transactions involving Digital Assets may be recorded on public blockchains. Such transactions are:

• Publicly visible

• Immutable

• Traceable via blockchain analytics tools

Users acknowledge that blockchain transactions may not be fully anonymous.

17.5 Compliance (KYC / AML / Sanctions)

We may collect and process personal and transactional data to comply with:

• Know Your Customer (KYC) obligations

• Anti-Money Laundering (AML) regulations

• Sanctions screening requirements

We may utilize third-party compliance providers to verify identities and monitor transactions.

17.6 Regulatory Considerations

Certain Digital Assets may be classified as securities under applicable laws enforced by the U.S. Securities and Exchange Commission.

Delbrass Invest LLC evaluates Digital Asset exposure with consideration to evolving regulatory frameworks, including but not limited to:

• Securities laws

• Commodity regulations

• State-level digital asset guidance

17.7 Risk Disclosure

Digital Assets involve significant risks, including but not limited to:

• Market volatility

• Regulatory uncertainty

• Liquidity constraints

• Cybersecurity threats

• Smart contract vulnerabilities

Users and investors should carefully evaluate these risks before engaging in any transaction involving Digital Assets.

17.8 Data Collection Specific to Digital Assets

In connection with Digital Asset transactions, we may collect:

• Wallet addresses

• Transaction hashes

• Blockchain metadata

• Exchange account details (if applicable)

This information may be used for compliance, auditing, and operational purposes.

17.9 No Custodial Guarantee

Unless explicitly stated in a separate agreement, Delbrass Invest LLC does not act as a qualified custodian and does not guarantee the security or recovery of Digital Assets in the event of:

• Loss of private keys

• Network failures

• Unauthorized access

• Third-party service failures

17.10 Tax Responsibility

Users and investors are solely responsible for:

• Reporting Digital Asset transactions

• Determining applicable tax obligations

• Seeking advice from qualified tax professionals

17.11 Jurisdictional Limitations

Digital Asset services may not be available in all jurisdictions. It is the responsibility of the user to ensure compliance with local laws before engaging with our Services.

17.12 Policy Integration

This Digital Assets & Cryptocurrency Compliance Addendum forms an integral part of the Delbrass Invest LLC Privacy Policy and should be read in conjunction with all other applicable disclosures and agreements.

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