Privacy Policy

Last updated: October 16, 2026

Scope of this Privacy Policy

Theta Equity Partners, Inc. ("Theta", "we", "us" or "our") is responsible for the personal information described in this notice. This Policy explains how we collect, use, disclose and retain information through thetaclv.com and in follow-up communications about website inquiries, applications, events and subscriptions.

Customer datasets supplied to Theta for a client engagement are governed by the applicable engagement agreement and data-processing terms, rather than this website notice.

What data do we collect and how do we collect it?

Information you provide. When you contact us, request information, apply for a service, register through an available website form or subscribe to updates, we collect the information you choose to provide. This can include your name, business name, email address, telephone number, organization type, message, referral source and other details requested in the form. Required fields are identified on the form. Without the information needed to answer a request, we may be unable to respond or provide the requested information.

Website and device information. We and the providers supporting our website may receive information such as your IP address, browser and device characteristics, pages visited, referring page, interactions with website links and approximate location. Cookies and similar technologies may associate visits with a browser or device. Optional visitor analytics technologies are subject to the choices described in the Cookies section.

Professional information from other sources. HubSpot enrichment can supplement eligible business contacts with professional details, such as job title, employer and location, and company details such as industry and size. These details come from HubSpot's commercial dataset, third-party sources and publicly available information.

How will we use your data?

We use website information to respond to inquiries, evaluate service requests, communicate with you, manage and maintain accurate business contact records, deliver requested resources and updates, operate and secure the website, understand website usage and identify companies showing interest in our services. Our HubSpot configuration also permits the additional provider uses described below.

We send newsletters and marketing communications when you subscribe or where otherwise permitted by applicable law. You can unsubscribe using the link in a marketing email or by contacting info@thetaclv.com. Submitting an inquiry does not itself mean that you agree to optional visitor tracking or subscribe to marketing communications.

Where the EU or UK GDPR applies, we rely on consent for optional visitor analytics and communications requiring consent. Our legitimate interests include responding to business inquiries, maintaining accurate professional contact records and business relationships, and operating and securing our website, subject to your rights. We may also process information to take steps you request before a contract, perform a contract with you or meet a legal obligation, where applicable.

Who receives your information?

We use providers for website hosting, security, form processing, email delivery, contact management and communications. WP Engine provides hosting through our website agency, and HubSpot receives website inquiries and contact information. Some application pages use Qualtrics forms. Selected resources embed shinyapps.io simulators or X (Twitter) content, and Font Awesome supplies icon resources. An embedded provider may receive device and connection information when its content loads, and information you submit through that feature. The information disclosed depends on the feature you use.

Google Analytics measures website visits and interactions when you enable Google Analytics in Cookie Settings. HubSpot manages business contacts and processes website form submissions. Rejecting optional tracking does not prevent you from submitting a contact inquiry.

When you enable HubSpot company insights, HubSpot's visitor and company-insight features may receive IP addresses, online identifiers, page paths, timestamps and company information. With Intent data access enabled, HubSpot may use this information for its own product improvement and commercial dataset, including company-intent insights supplied to other customers. HubSpot acts as an independent controller for its own tracking and enrichment purposes; its Privacy Policy explains these uses and legal bases: https://legal.hubspot.com/privacy-policy .

Our HubSpot account also enables ongoing enrichment of previously enriched contact and company records. Eligible professional information may contribute to HubSpot's commercial dataset and be made available to other HubSpot customers for their business activities. Enrichment does not apply to every contact. Information we collect directly from you and information obtained through enrichment may be held together in our business contact records.

We have opted out of HubSpot AI model training for our account. The opt-out applies to future model training and does not undo training that occurred previously. HubSpot AI tools remain available and may process business contact records and ordinary sales correspondence to provide their features. This feature processing is separate from website cookie choices. HubSpot's Privacy Policy describes its processing and applicable rights.

We may disclose information to professional advisers or public authorities where necessary to comply with law, protect legal rights or address fraud or security issues.

Cookies

Cookies are small files stored on your browser or device. Similar technologies, including pixels and local storage, can support website functions, recognize a browser and measure interactions. We use CookieYes to present cookie choices and remember your preferences.

Necessary technologies record consent preferences and support security and requested website functions. Google Analytics and HubSpot company insights have separate optional choices. Google measures website use; HubSpot measures visits, identifies visiting companies and uses tracking data for the additional purposes described above. Cookie Settings lists the managed technologies, providers, purposes and durations. Embedded third-party features are described above.

You can accept or reject optional tracking through the cookie banner, choose Google Analytics and HubSpot company insights separately in Cookie Settings, and change or withdraw your choices through the Cookie Settings control in the footer. Each optional service remains off until you enable it. Contact inquiries still work when you reject optional tracking. Cookie choices control website tracking; they do not themselves opt you out of contact enrichment, AI processing of CRM information or newsletter communications.

Consent preferences are stored for a particular browser or device. You may need to make your choices again if you use a different browser or device, browse privately or clear cookies or browser data. Withdrawing consent affects future processing and does not affect the lawfulness of processing that took place before withdrawal.

You can also manage cookies in your browser. Browser controls may affect website functionality and are separate from Cookie Settings. Our cookie controls use your saved choices; a browser's Do Not Track signal does not automatically change those choices. Use Cookie Settings to reject or withdraw optional website tracking.

How long do we keep website information?

We retain inquiry and application information for as long as reasonably necessary to respond, manage any resulting business relationship and meet applicable legal, accounting or claims-related requirements. We consider the purpose, sensitivity, relationship history and applicable legal requirements when deciding the period.

We retain subscription details while you remain subscribed or while otherwise permitted to send the communications. After you unsubscribe, we may retain a limited suppression record to honor that choice. Unsubscribing does not necessarily delete correspondence or records we need for another permitted purpose.

Cookie lifetimes are shown in Cookie Settings. Our Google Analytics property is configured with event data retention of 2 months and user data retention of 14 months, with the user retention period reset by new activity. These controls do not determine the lifetime of most aggregated standard reports. Other website records are subject to the purpose-based criteria above and applicable legal requirements, including deletion or anonymization when they are no longer necessary, subject to lawful retention exceptions.

International processing

Theta is based in the United States. Website information may be processed there and in other countries where our providers operate; our HubSpot account is hosted in the United States (East). Google's data-processing terms and HubSpot's Data Processing Agreement provide international-transfer safeguards, including European Commission Standard Contractual Clauses and the UK Addendum where applicable. HubSpot's agreement also provides for the Data Privacy Framework where it applies. Details are available in Google's terms at https://business.safety.google/adsprocessorterms/ and HubSpot's agreement at https://legal.hubspot.com/dpa . Contact info@thetaclv.com for information or a copy of the safeguards relevant to your information.

What are your data protection rights?

Your rights depend on the law that applies to you and the circumstances of the processing. They may include the following:

The right to access – You may request access to your personal information and a copy of it. Requests are normally free of charge, subject to exceptions permitted by applicable law.

The right to rectification – You may request correction of inaccurate or incomplete personal information.

The right to erasure – You may request deletion of personal information, subject to applicable conditions and exceptions.

The right to restrict processing – You may request that we limit processing in circumstances provided by law.

The right to object – You may object to processing based on legitimate interests, subject to applicable conditions.

The right to data portability – Where applicable, you may request a portable copy of information you provided or its transfer to another organization.

You may object to the use of your information for direct marketing at any time. Where we rely on consent, you may withdraw it at any time without affecting processing that occurred before withdrawal.

To make a request, contact info@thetaclv.com or use our Prighter request channel below. We may need information reasonably necessary to verify your identity and locate the relevant records. We respond within the time required by applicable law.

You can ask Theta about enrichment, object where the applicable law gives you that right, or request correction or deletion using the same contact channels. You can also contact HubSpot about data it controls for its commercial dataset and other own purposes through https://www.hubspot.com/hubspot-privacy-preferences . A request to HubSpot does not replace a request concerning information Theta holds, and a newsletter unsubscribe is separate from an enrichment-data request.

You may also complain to the data-protection authority responsible for your location or processing. In the United Kingdom, this is the Information Commissioner's Office (ico.org.uk). Other privacy rights or complaint and appeal procedures may apply under the laws of your jurisdiction.

How to contact us

For questions about this Policy, your website information or your privacy rights, contact Theta Equity Partners, Inc. at info@thetaclv.com.

Representation for data subjects in the EU and the UK

Prighter is our EU and UK privacy representative. You can contact our representative or exercise your rights through https://prighter.com/q/16433828 .