Two Waters Capital

We Respect Your Privacy

Effective October 13, 2026

We greatly value the trust and confidence you place in Two Waters Capital LLC ("TWC," "we," "us," or "our"), and we are committed to protecting your personal data. This Privacy Policy describes how we collect, process, use, share and secure the personal information you provide through 2waterscapital.com, our investor portal, our webinars and events, and our communications. It also describes your choices regarding use, access, and correction of your personal information.

Personal Data

This policy applies to personal data we may collect, process, and handle. For purposes of this statement, "personal data" means information that is about, or pertains to, a specific individual, and that can be linked either directly or indirectly to that individual.

Information We Collect

We collect and process personal data from the following groups:

  1. Website visitors and prospective investors who complete a form, register for a webinar, book a call, or request information. This may include name, email address, phone number, state of residence, accredited investor status, and investment interests.
  2. Investors in our funds, as necessary to verify identity and accredited investor status, process subscriptions, make distributions, issue tax documents, and meet legal and regulatory requirements. This may include contact details, date of birth, taxpayer identification number, financial information used for accreditation, and banking details for distributions.
  3. Employees and independent contractors, in the context of the employment or contractor relationship.

We also collect certain information automatically when you visit our website, as described under Cookies and Advertising below.

How We Use Your Information

We use personal data to respond to your inquiries; deliver webinars, educational content, and fund updates; verify accredited investor status as required for our offerings; process subscriptions, distributions, and tax reporting; operate and improve our website; and comply with applicable law.

Notice and Choice

We notify individuals about the personal data we collect from them, how we use it, and how to contact us with privacy concerns. Personal data is collected and processed with the express and informed consent of the relevant individuals, or pursuant to mandatory legal requirements, including those imposed by the U.S. Securities and Exchange Commission and federal anti-money laundering rules.

We provide such notice through this policy, our subscription agreements and offering documents, instructions on our data collection forms, and direct communication with individuals. Consent for personal data to be collected, used, or disclosed in certain ways may be required in order for an individual to invest in or receive information about our funds.

Text Messaging

If you provide your mobile number and opt in, Two Waters Capital may send you text messages about webinars, appointments, and investment updates. Message frequency varies. Message and data rates may apply. Reply STOP to opt out at any time, or HELP for help. Consent to receive text messages is not a condition of investing.

No mobile information will be shared with third parties or affiliates for marketing or promotional purposes. Text messaging opt-in data and consent will not be shared with any third parties.

Cookies and Advertising

Our website uses cookies, analytics tools, and advertising pixels, including those provided by Google and Meta, to understand how visitors use the site and to measure and deliver our advertising. These tools may collect your IP address, browser type, pages viewed, and referring website. You can disable cookies through your browser settings, though some features of the site may not function properly as a result.

Some browsers offer a "Do Not Track" setting. Because no uniform standard for these signals exists, our website does not currently respond to them.

We do not sell your personal data.

Disclosures and Transfers

We do not disclose an individual's personal data to third parties, except when one or more of the following conditions is true:

  1. We have the individual's permission to make the disclosure.
  2. The disclosure is necessary to process a subscription, verify identity or accredited investor status, administer a fund, make distributions, or prepare tax documents.
  3. The disclosure is required by lawful request by public authorities, including to meet national security, regulatory, or law enforcement requirements.
  4. The disclosure is required by law or mandatory professional standards.
  5. The disclosure is reasonably related to the sale or other disposition of all or part of our business.
  6. The information in question is publicly available.
  7. The disclosure is reasonably necessary for the establishment of legal claims.
  8. The disclosure is to persons or entities providing services on our or the individual's behalf, such as fund administrators, investor portal providers, accredited investor verification services, accountants, and legal counsel (each a "transferee"), consistent with the purpose for which the information was obtained, where the transferee is subject to law providing an adequate level of privacy protection or has agreed to provide one.

We may transfer personal data from one jurisdiction to another. Privacy laws vary by jurisdiction, and some may provide less or different legal protection than others.

Securities Offerings

Nothing on this website is an offer to sell, or a solicitation of an offer to buy, any security. Offers are made only through a fund's private placement memorandum and subscription documents, and only to accredited investors whose status has been verified.

If you do not provide the information requested for identity or accredited investor verification, or if your identity or status cannot be adequately verified in accordance with federal requirements, Two Waters Capital reserves the right to decline your subscription.

Data Security, Integrity and Access

We employ physical, electronic, and managerial measures, including education and training of our personnel, designed to reasonably protect personal information from loss, misuse, unauthorized access, disclosure, alteration, or destruction. Personal data collected through our website is protected in transit by standard encryption. However, we cannot guarantee the security of information on or transmitted via the Internet.

We process personal data only for the limited and specific purpose for which it was originally collected or authorized by the individual. To the extent necessary for such purposes, we take reasonable steps so that personal data is accurate, complete, current, and reliable for its intended use.

An individual has the right to access personal data we hold about them, and may contact us using the information below to correct, amend, or delete information where it is inaccurate. You will need to provide sufficient identifying information, such as name, address, and date of birth, and we may request additional information as a security precaution. We may limit or deny access where providing it would be unreasonably burdensome or expensive, or where the rights of other persons would be violated.

We respond to all requests from individuals wishing to exercise their data protection rights in accordance with applicable law. We reserve the right to keep any information in our archives that we deem necessary to comply with our legal and regulatory obligations, resolve disputes, and enforce our agreements.

Data Rights

Your rights under data protection laws are complex. We have summarized them here, but not all details can be included. You should consult the relevant laws and regulatory guidance for a full explanation.

You have the right to consent to whether we collect and process your personal data. Where we do process or share personal data, you have the right to know the purposes of the processing, the categories of personal data concerned, and any recipients.

You have the right to have inaccurate personal data corrected and, taking into account the purposes of the processing, to have incomplete personal data completed. To the extent not inconsistent with our legal and regulatory obligations, you may have the right to the erasure of your personal data.

You may have the right to restrict or object to the processing of your personal data, subject to legal and regulatory requirements. If you object, we will cease processing unless we can demonstrate compelling legitimate grounds that override your interests, or the processing is for the establishment, exercise, or defense of legal claims. Where our legal basis for processing is consent, you may withdraw that consent at any time, without affecting the lawfulness of processing before the withdrawal.

You may exercise any of these rights by written notice to us at [email protected].

Children's Privacy

Our website and offerings are not directed to individuals under 18, and we do not knowingly collect personal data from them.

Accountability and Enforcement

You may file a complaint about our processing of your personal data using the contact information below. We will take appropriate steps to address any adverse effects and to promote future compliance. Personnel who violate our privacy policies will be subject to disciplinary action or termination.

Amendment

We may amend this policy from time to time by posting a revised policy on this website. If we amend the policy, the new policy will apply to personal data previously collected only insofar as the rights of the individuals affected are not reduced.

Contact Information

For further information, questions, access requests, or any other privacy issues, please contact:

  • Attention: Investor Relations Manager
  • Company: Two Waters Capital LLC
  • Mailing address: 315 W Ponce De Leon Ave, Suite 475, Decatur, GA 30030
  • Email: [email protected]
  • Phone: (404) 500-6876