Last Updated: May 5, 2025

1. Introduction

A&E Investment, LLC (“we” or “us”) is committed to respecting your privacy. This Privacy Policy explains how we collect, use, and share your personal information when you visit our website at [familyoffice.com] or otherwise interact with us online (collectively, our “Services”). It also describes your rights and choices regarding your information. This policy applies to information we collect from website visitors, newsletter subscribers, or any other individuals who interact with our online content. If you do not agree with our practices, please do not use our Services. By using our website, you consent to the data practices described in this Privacy Policy (to the extent permitted by applicable law).

2. Personal Data We Collect

We collect various types of Personal Data (information that can identify you or that relates to you as an identifiable individual):

• Information You Provide to Us: When you actively interact with us, for example by filling out a contact form, subscribing to our newsletter, or emailing us, you may give us personal information. This includes:
  • Contact Details: such as your name, email address, phone number, mailing address, or company/affiliation.
  • Professional Information: such as your job title or the name of your organization, if you include that in communications.
  • Messages: any personal information you include in messages to us (for example, the content of an inquiry or pitch).
    We will use this information to respond to or action your request (see “How We Use Personal Data” below).
• Information We Collect Automatically: Like many websites, we automatically collect certain data when you visit our Site:
  • Usage and Device Information: This can include your IP address, browser type, device type, operating system, referring URLs, pages viewed, and the dates/times of your visits. This data helps us understand how our site is used and is collected through analytics tools and server logs.
  • Cookies and Similar Technologies: We use “cookies” and similar tracking technologies to enhance your experience and gather usage data. Cookies are small files stored on your device that help remember your preferences and recognize you on subsequent visits. For example, we might use cookies to remember that you’ve seen a notification banner so it doesn’t repeat, or to understand which blog posts are most popular. We also use cookies from third parties, like Google Analytics, to collect information on Site traffic and user interactions. This helps us improve our content. You can usually configure your browser to refuse cookies or alert you when cookies are being used. However, if you disable cookies, some features of our Site might not function properly.
  • Do Not Track: Some browsers have “Do Not Track” features. Currently, our Site does not respond to Do Not Track signals. We adhere to the data collection practices described here regardless of such signals, due to the lack of an industry standard on how to interpret them.
• Information from Other Sources: We generally collect information directly from you or your device, but if we ever receive personal data about you from other sources (for example, if you’re referred to us by a partner or if we glean publicly available information from your LinkedIn profile in the course of business), we will handle that information according to this Policy. We do not currently buy or rent personal data from data brokers.
• No Sensitive Personal Data: We do not intend to collect any sensitive personal data via our Site (such as social security numbers, financial account info, or health information). Please refrain from providing such data through our forms or communications.

3. How We Use Personal Data

We use the personal data we collect for the following purposes:

• To Provide and Maintain the Site: Ensuring the website functions correctly, loading content, and personalizing your experience where possible.
• To Communicate with You: If you contact us or sign up for communications, we use your contact details to respond to inquiries, send newsletters or updates you requested, or provide information about our events and investments. For example, if you subscribe to our newsletter, we will use your email to send you our periodic updates (you can unsubscribe at any time).
• To Improve Our Services: We analyze how users navigate the Site (using data like page views and traffic patterns) to improve layout, content, and overall user experience. This helps us make the site more useful for visitors.
• For Compliance and Protection: To comply with legal obligations (such as maintaining records, or responding to lawful requests by authorities), and to protect our rights and the rights of others. For instance, we may use data to prevent fraud, enforce these terms, or ensure security of our systems.
• To Consider Opportunities or Submissions: If you send us a pitch or business idea, we may use your information to evaluate that opportunity or respond. (However, see the Terms of Use regarding unsolicited confidential information.)
• Other Business Purposes: We may use data for other legitimate purposes, like internal record-keeping or to administer the Site, as long as such use is compatible with the reasons you provided it.

We will only use your personal data in ways that are compatible with the purposes for which we collected it, or for closely related purposes if allowed by law. If we need to use your data for an unrelated purpose, we will notify you and, if required, obtain your consent.

4. Legal Bases for Processing (GDPR Notice)

This section applies if you are located in the European Economic Area (EEA), United Kingdom (UK), or another region with similar laws. We process personal data only when we have a legal basis to do so. The legal bases we rely on are:

• Your Consent: For example, when you subscribe to our newsletter, we process your email address based on your consent. You have the right to withdraw consent at any time, though this won’t affect processing already done.
• Legitimate Interests: We may process data as necessary for our legitimate business interests, as long as those are not overridden by your data protection rights. For instance, analyzing Site usage to improve our services, or responding to your inquiries – these activities are in our interests and we believe they align with your expectations.
• Legal Obligation: If we are required to retain or disclose information to comply with a law or legal process, we will do so. For example, keeping records for tax purposes or responding to a court order falls under this basis.
• Performance of a Contract: Though unlikely via this public Site, if you were to enter a contract with us (for example, as a service provider or partner through the Site), we would process your data as necessary to fulfill that contract.

We will clarify in context if any other basis applies. Where GDPR or UK law applies, you have specific rights (see “Your Rights” below) and we honor those rights.

5. Disclosure of Personal Data (How We Share Information)

We value your privacy and handle your personal data with care. We do not sell your personal information to third parties for profit or share it for others’ marketing purposes. However, we do share information in certain circumstances:

• Service Providers: We may share personal data with trusted third-party companies that provide services on our behalf. These include, for example, website hosting providers, email/newsletter distribution services, analytics services, or IT support. These service providers are only given the information necessary to perform their functions, and they are contractually obligated to keep your information confidential and use it only for the services they provide to us.
• Affiliates: If [Family Office Name] has affiliate entities or is part of a larger family enterprise, we may share information within our family of companies. For instance, if we have a sister company or a fund management entity under the same ownership, we might share contact info or analytics with them. Any such affiliates will also follow this Privacy Policy (or provide you with notice and choice if their practices differ).
• Legal Compliance and Protection: We will disclose personal data when we believe it’s necessary to comply with applicable law, regulation, legal process, or an enforceable governmental reques. This includes responding to subpoenas or court orders, or to meet national security or law enforcement requirements. We may also share data if needed to enforce our Terms of Use, investigate or protect against fraudulent or illegal activity, or protect the rights, property, and safety of , our employees, our users, or others.
• Business Transfers: In the unlikely event that we undergo a business transaction, such as a merger, acquisition, or investment restructuring, personal data may be transferred to a successor or affiliate as part of that process. If that happens, we will ensure your information remains protected and inform you of any changes to how your data is used.
• With Your Consent: If we intend to share your information for any other purpose not covered above, we will explain the situation and obtain your consent where required. For example, if we were to publish a testimonial with your name, we’d ask permission.

Other than the scenarios above, we do not share your personal data with third parties. In particular, we do not give or sell your personal information to outside parties for their own marketing. If you have any questions about third parties we use, feel free to contact us.

6. Cookies and Analytics

As noted, we use cookies and analytics tools on our Site. Here are more details and your choices:

• Cookies: Small data files that allow our site and third parties (like analytics providers) to recognize your browser. We use cookies to remember your preferences (for example, to stay logged in to a secure area if applicable, or remember language settings) and to collect aggregate data about site traffic. Some cookies are session-based (they expire when you close your browser) and others are persistent (they stay on your device for a set period or until you delete them). We classify cookies used as:
  • Essential cookies – necessary for the website to function (for example, to load core features).
  • Analytics cookies – help us understand how visitors move around the site (e.g., Google Analytics cookies track pages visited and interactions). The information collected is typically aggregated and not personally identifying. Google Analytics may set cookies and generate information about your use of our Site, which is transmitted to Google’s servers. We use this information to compile reports and improve the site. You can opt out of Google Analytics by installing Google’s browser add-on.
  • Functional cookies – (if any) might remember choices you make to give a more personalized experience.
  By using our site, you agree to our use of cookies as described (unless you’ve adjusted your browser to reject cookies, which you can do at any time).
• Managing Cookies: Most web browsers allow you to control cookies through their settings. You can usually set your browser to refuse new cookies, delete existing cookies, or notify you when new cookies are set. Please note that if you disable or delete cookies, some parts of our Site may not work properly (for example, videos might not play, or preferences might be lost). For more information about cookies and how to manage them, you can visit websites like AllAboutCookies.org.
• Do Not Track: As mentioned, we currently do not respond to “Do Not Track” signals because no uniform standard exists. We continue to review new technologies and may update this policy if our practices change.

7. Data Security

We take reasonable measures to protect the security of your personal information. This includes using technical safeguards (like encryption, secure networks, and firewalls) and organizational measures (like limiting access to personal data to authorized personnel). However, please understand that no security measure or method of transmitting data over the Internet is 100% secure. We cannot guarantee absolute security of your data. You provide information at your own risk, and it’s important you also take precautions (for example, protect your account credentials if any, and close your browser after use on shared devices). If we become aware of a security breach that affects your personal data, we will notify you as required by applicable law.

8. Data Retention

We will retain your personal data only as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or allowed by law. For example:

• If you contact us with a question, we may retain your correspondence and our response for some time to help us in any future communication.
• If you subscribe to our newsletter, we will keep your email on our mailing list until you unsubscribe or ask us to delete it.
• Web server logs and analytics records are generally kept for a limited period (e.g., a few months) unless we need to retain them longer for security analysis.
• We may retain certain information to comply with legal obligations (for instance, records of communications or consents), or to resolve disputes or enforce agreements.

When we have no ongoing legitimate need or legal requirement to keep your personal data, we will delete it or anonymize it. If deletion is not feasible (for example, because the data is stored in backup archives), we will securely store it and isolate it from further processing until deletion is possible.

9. Your Rights and Choices

Depending on your jurisdiction, you may have certain rights regarding your personal data. We honor all individuals’ rights as applicable under law:

• Access and Correction: You have the right to request access to the personal data we hold about you and to ask that we correct any inaccuracies. We will provide you with a copy of your data or make corrections upon your request, as required by law.
• Deletion: You can ask us to delete the personal information we have about you. For example, if you no longer want us to hold your contact details, you can request erasure. We will delete your data on request, provided we do not have a legal obligation or compelling reason to keep it (we’ll let you know if that’s the case). California residents specifically have the right to request deletion of their personal info, with some exceptions.
• Opt-Out of Marketing: If at any time you prefer not to receive our newsletter or other marketing emails, you may unsubscribe via the link in the footer of those emails or by contacting us. We will honor your opt-out request. (Even if you opt out of marketing, we may still send you transactional or administrative messages, like responding to an email you sent us.)
• Object or Restrict Processing: In certain situations, you might have the right to object to or ask us to limit our processing of your data. For instance, EU individuals can object if they believe we have no legitimate grounds for processing, or request restriction if they contest the accuracy of their data.
• Data Portability: If you are in the EU/UK, you have the right to request a copy of certain information in a machine-readable format, or ask us to transfer it to a third party of your choice when feasible. (This typically applies to data you provided to us.)
• Non-Discrimination: If you exercise any of your rights (for example, a California resident requests deletion), we will not discriminate against you by denying the service or providing a different level of service. We treat all users equally, regardless of any privacy choices you make, as mandated by the CCPA.

To exercise any of these rights, please contact us at privacy@aeinvestments.com (or the contact information provided below). We will need to verify your identity to process certain requests, which may involve asking you to provide information or identification. We will respond to your request within the time frame required by law (for example, generally within 30 days for most requests, or 45 days under CCPA, with the possibility of a reasonable extension).

Additionally, if you are in the EEA, UK, or other regions with data protection authorities, you have the right to lodge a complaint with the supervisory authority in your country if you believe we have infringed your privacy rights. We encourage you to contact us first, so we can address your concerns directly.

10. International Users and Data Transfers

A&E Investment, LLC is based in the United States. If you are visiting our Site from outside the U.S., please be aware that your personal data may be transferred to, stored, and processed in the U.S. (or other jurisdictions where our service providers are located). We will take steps to ensure that your data is treated securely and in accordance with this Privacy Policy and applicable law. For example, for EU/UK individuals, we may rely on appropriate safeguards (such as Standard Contractual Clauses) when transferring data to the U.S. By using our Services, you understand that your information may be transferred to our facilities and those third parties with whom we share it, as described above.

11. Children’s Privacy

Our Services are not intended for children under the age of 13. We do not knowingly collect personal information from anyone under 13 years old. If you are under 13, please do not use this Site or send us any personal information. If we learn that we have inadvertently collected personal data from a child under 13, we will delete that information. For teens under 16 (and their equivalents under applicable law), if you are aware that such a minor has provided us personal data without proper consent, please alert us and we will remove the data. Parents or guardians with concerns can contact us at [privacy@familyoffice.com].

12. Updates to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or relevant laws. When we do, we will change the “Last Updated” date at the top of this Policy. If the changes are significant, we may also provide a more prominent notice (such as on our website’s homepage or via email, if appropriate). We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your information. Your continued use of our Site after we post any modifications will constitute acknowledgment of those changes.

13. Contact Us

Thank you for reading our Privacy Policy. If you have any questions, concerns, or requests regarding this Policy or how we handle your personal data, please reach out to us:

A&E Investment, LLC – Privacy Team
Email: privacy@aeinvestments.com

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