Privacy Policy
Effective date: June 8 2025
Summary
Dynastic Capital LLC (“Dynastic,” “we,” “us,” or “our”) must (i) give clients clear notice of its information-sharing practices and an annual opportunity to limit certain sharing under the Gramm-Leach-Bliley Act (GLBA) and, where applicable, SEC Regulation S-P, (ii) safeguard customer records and disclose incidents, (iii) respect additional rights for California and other state residents, (iv) honour children’s privacy rules, and (v) extend General Data Protection Regulation protections to EU/EEA visitors.
Who We Are
Dynastic Capital LLC is a private investment-management firm focused on alternative and opportunistic credit strategies. This Privacy Policy explains how we collect, use, share, and safeguard “Personal Information” obtained through client onboarding, fund subscriptions, and your use of http://www.dynastic.capital.
Scope of This Policy
This notice applies to current, former, and prospective clients as well as website visitors. It covers Personal Information in any format—paper or electronic—and supplements any confidentiality provisions in our advisory agreements.
Information We Collect
| Category | Examples | Sources |
|---|---|---|
| Identifiers | Name, postal address, e-mail, phone, Social Security / Tax ID, IP address | Account forms, documents you provide, site analytics |
| Financial & Transaction Data | Assets, income, bank details, investment history, wire instructions | Custodians, administrators, brokers |
| Demographics | Date of birth, citizenship, marital status | Subscription documents |
| Internet Activity | Log files, cookies, pages viewed, clicks | Our website & third-party analytics tools |
How We Collect Information
- Directly from you (applications, e-mails, in-person meetings).
- Automatically when you visit our site (cookies, pixel tags, log files).
- From service providers and counterparties (fund administrators, custodians, placement agents) as necessary to open or service your account.
How We Use Information
We use Personal Information to:
- Verify identity and suitability for our funds.
- Execute and settle transactions you authorize.
- Provide account statements, tax documents, and performance reports.
- Operate, maintain, and secure our website and IT systems.
- Satisfy legal, regulatory, and audit obligations (e.g., KYC/AML, examinations by applicable authorities).
Information We Share
| Recipient | Purpose | Opt-Out? |
|---|---|---|
| Affiliates (under common control) | Portfolio accounting, consolidated client service | Yes—marketing only |
| Non-affiliate service providers (fund administrator, custodian, audit firm, legal counsel, IT vendors) | To perform contracted services on our behalf, subject to confidentiality agreements | No |
| Regulators and courts | To comply with subpoenas, examinations, or law-enforcement requests | No |
| Prospective transaction counterparties | In connection with a merger, reorganization, or asset sale, subject to NDAs | No |
We do not sell Personal Information and we do not allow unaffiliated third-party marketing.
Your Choices
- GLBA/Reg S-P Opt-Out – You may limit sharing with affiliates for marketing by e-mailing privacy@dynastic.capital.
- California Rights – California residents may request: (i) the categories and specific pieces of Personal Information we hold; (ii) deletion (with statutory exceptions); (iii) correction; and (iv) to opt out of “sale or sharing” as defined by CCPA/CPRA. Submit requests via the above contacts or our web form. We will verify your identity and respond within 45 days. We will not discriminate for exercising these rights.
- EU/EEA Rights – If GDPR applies, you may request access, rectification, erasure, data portability, or restriction of processing, and you may object to processing or lodge a complaint with your supervisory authority.
Cookies & Online Tracking
We use first- and third-party cookies and similar technologies for site security, aggregated analytics, and to remember user preferences. Most browsers allow you to block or delete cookies; doing so may affect site functionality.
Data Security
Dynastic maintains written information-security and incident-response programs that include administrative, technical, and physical safeguards, consistent with industry standards (including guidelines under SEC Regulation S-P and the FTC Safeguards Rule). Controls are reviewed at least annually and updated to address emerging threats.
Data Retention
We retain Personal Information for the longer of (i) the client relationship plus seven years (to satisfy applicable books-and-records obligations) or (ii) as required by law or litigation hold.
Children’s Privacy
Our services and website are not directed to children under 13, and we knowingly collect no information from them. We comply with the Children’s Online Privacy Protection Act (“COPPA”). Parents who believe we may have inadvertently collected a child’s data should contact us for deletion.
International Data Transfers
Personal Information collected in the United States may be stored and processed in any country where we or our service providers operate. We rely on appropriate transfer mechanisms (e.g., Standard Contractual Clauses) to protect EU personal data.
Changes to This Policy
We may amend this Privacy Policy from time to time. If we make material changes, we will post an updated notice and, where required, notify clients directly or obtain consent.