Privacy Policy

This Privacy Policy applies to information collected through wasswacorporation.com and related pages, forms, tools, and online services operated by WASSWA Capital Management, LLC, referred to in this policy as “WASSWA,” “we,” “us,” or “our.”

This policy does not govern information collected through services that publish their own privacy notices, nor does it govern the independent privacy practices of portfolio companies, prospective transaction counterparties, or third-party websites.

Information you provide

We may collect information that you choose to provide, including:

• Contact information, such as your name, email address, telephone number, company, title, and website.
• Business-submission information, such as a description of a company, opportunity, operating challenge, or reason for contacting WASSWA.
• Chatbot messages and prompts submitted through WASSWA Intelligence.
• Recruitment information, such as a résumé, professional history, qualifications, and other application materials.
• Any other information included in correspondence, attachments, meeting requests, or communications with our team.

Information collected automatically

When you use the Site, our hosting, security, performance, and analytics technologies may automatically collect technical information such as your IP address, browser type, device type, operating system, referring page, pages viewed, timestamps, approximate location derived from IP address, and cookie or similar identifiers.

Information from other sources

We may receive information from professional advisors, business partners, public sources, service providers, referral sources, or transaction participants when permitted by law and relevant to our business activities.

We may use information to:

• Operate, maintain, secure, and improve the Site and its functionality.
• Respond to questions, inquiries, meeting requests, and business submissions.
• Conduct preliminary review of potential investments, acquisitions, partnerships, or operating opportunities.
• Communicate with founders, executives, advisors, intermediaries, investors, service providers, applicants, and other business contacts.
• Process job applications and manage recruiting activities.
• Detect, prevent, investigate, and respond to fraud, misuse, security incidents, and technical problems.
• Comply with legal obligations, enforce agreements, protect rights, and support corporate transactions.
• Analyze Site usage and improve content, design, performance, and user experience.

Where applicable law requires a legal basis, we rely on consent, performance of or steps toward a contract, compliance with legal obligations, and our legitimate interests in operating and protecting our business, evaluating opportunities, and communicating with relevant parties.

The WASSWA Intelligence chatbot uses Google’s Gemini API to generate responses. When you send a chatbot message, the text of your message, recent conversation context, system instructions, and related technical request data are transmitted to Google for processing and response generation.

When the chatbot operates through Google’s unpaid Gemini API services, Google states that submitted content and generated responses may be used to provide, improve, and develop Google products and machine-learning technologies, and that human reviewers may process API input and output. Google instructs users not to submit sensitive, confidential, or personal information to unpaid services.

AI-generated responses may be incomplete, inaccurate, or inappropriate for a particular situation. The chatbot does not make investment decisions, determine qualification, provide professional advice, or create a binding commitment by WASSWA.

The business inquiry form available inside the chatbot is separate from the AI conversation. Information submitted through that form is transmitted to WASSWA through the website’s email system and is not included in the Gemini prompt by the chatbot plugin.

The Site may use cookies, local storage, pixels, log files, and similar technologies to provide essential functionality, remember preferences, protect the Site, measure performance, and understand how visitors interact with content.

You can control many cookies through your browser settings. Blocking certain cookies may affect Site functionality. Where required by applicable law, we will request consent before using non-essential cookies or provide another legally required preference mechanism.

We may disclose information to:

• Hosting, cloud, email, cybersecurity, website, analytics, AI, communications, and other service providers that support our operations.
• Professional advisors, including attorneys, accountants, consultants, financing sources, and diligence providers.
• Affiliates, prospective or existing transaction participants, financing parties, counterparties, and their advisors when reasonably necessary for a legitimate business process and subject to appropriate safeguards.
• Government authorities, regulators, courts, or other parties when required by law or reasonably necessary to protect rights, safety, security, or property.
• A buyer, successor, or other relevant party in connection with a merger, acquisition, financing, restructuring, sale of assets, or similar corporate transaction.
• Other parties when you direct us to disclose information or provide consent.

WASSWA does not knowingly sell personal information for monetary consideration. If our practices materially change in a manner that creates a legally required opt-out right, we will update this policy and provide an appropriate request mechanism.

We retain information for as long as reasonably necessary for the purposes described in this policy, including to respond to communications, evaluate opportunities, maintain business records, support security, resolve disputes, enforce agreements, and comply with legal, regulatory, accounting, and reporting obligations.

Retention periods vary based on the type of information, the nature of our relationship, operational needs, legal requirements, and whether the information is relevant to an actual or potential transaction or dispute. We may retain de-identified or aggregated information where permitted by law.

We use administrative, technical, and organizational safeguards designed to protect information against unauthorized access, loss, misuse, alteration, or disclosure. No internet transmission, email system, website, or storage method is completely secure, and we cannot guarantee absolute security.

Visitors should avoid submitting highly sensitive information through ordinary website forms, email, or the AI chatbot unless WASSWA has provided an approved method for secure transmission.

Depending on your location and applicable law, you may have the right to request access to personal information, correction of inaccurate information, deletion, restriction of processing, portability, withdrawal of consent, objection to certain processing, or information about categories of data and recipients.

To submit a request, use our contact page and identify the message as a “Privacy Request.” We may request information reasonably necessary to verify your identity and authority. We will not discriminate against you for exercising an applicable privacy right.

You may unsubscribe from marketing communications by using the unsubscribe mechanism in the message or contacting us. Administrative, transactional, or relationship-based communications may continue where appropriate.

United States state privacy laws

Residents of California and certain other U.S. states may have rights to know or access, correct, delete, obtain a portable copy, and opt out of certain sales, sharing, targeted advertising, or profiling where those activities and laws apply. The categories of information we may collect, our sources, purposes, and categories of recipients are described throughout this policy.

European Economic Area, United Kingdom, and Switzerland

Where relevant data-protection law applies, individuals may have rights to access, correct, erase, restrict, port, or object to processing, withdraw consent, and lodge a complaint with a competent supervisory authority. Information may be processed in the United States or other jurisdictions that may have different data-protection laws. Where required, transfers will be supported by an approved legal mechanism or other lawful basis.

Automated decision-making

The public WASSWA Intelligence chatbot provides informational responses only. It is not used by itself to make legally or similarly significant decisions about investments, transactions, employment, or individual eligibility.

The Site is intended for business and professional audiences and is not directed to children under 13. We do not knowingly collect personal information from children under 13 through the Site. A parent or guardian who believes a child has provided personal information may contact us to request review and deletion.

We may update this Privacy Policy to reflect changes in our practices, technology, services, or legal obligations. The revised policy will be posted on this page with an updated effective date. Material changes may also be communicated through an additional notice where appropriate.