This Privacy Policy describes how Avante Capital Partners and its affiliates (“Avante,” “we,” “us,” or “our”) collect, use, disclose, and protect personal information when you visit our public website(s) and related pages (the “Website”).
Important note about investor portals and subscription information. This Privacy Policy primarily addresses information collected through the public Website. Investor portals and subscription/onboarding processes may be provided through third‑party service providers and/or separate investor notices and agreements. Consistent with market practice, investor information collected in connection with investing (or applying to invest) is typically addressed through investor privacy notices and subscription documents made available through the investor portal.
Scope
This Policy applies to personal information collected from Website visitors and business contacts who interact with Avante through the Website (including forms, email signups, and general inquiries). This Policy does not cover:
- personal information collected through or in connection with an investor portal and subscription documents (which may be governed by separate investor privacy notices);
- information collected offline (e.g., at conferences) unless we specifically reference it here;
- information collected by third parties on their own sites or platforms, even if linked from our Website.
Information we collect
Information you provide. We may collect personal information you provide when you:
- submit a contact form or inquiry;
- register for an event or webinar;
- subscribe to email updates;
- request materials; or
- communicate with us by email or phone.
Depending on the context, this may include name, employer, title, email address, phone number, and the content of your message.
Information collected automatically. When you visit our Website, we and our service providers may automatically collect information such as IP address, device identifiers, browser type, referring URLs, pages visited, and interactions with our Website.
Cookies, analytics, and preference choices
Cookies and similar technologies. We use cookies and similar technologies for security, site operation, analytics, and to remember your preferences.
Cookie banner and preference center. Where required or appropriate, we present a cookie banner and allow you to manage preferences via a “Cookie Preferences” link (e.g., in the footer). Golub provides a market example of “Manage Cookie Preferences/Settings” and describes cookie preference management in its privacy materials.
Categories of cookies (suggested):
- Strictly Necessary (security, network management, core site functions)
- Analytics/Performance (traffic measurement, site improvement)
- Functional (preferences, usability features)
- Advertising/Targeting (if used; if not used, omit and state “we do not use advertising cookies”)
Do Not Sell/Share and opt-outs (California). If we engage in “sharing” for cross-context behavioral advertising as defined by California law, we will provide a “Do Not Sell or Share My Personal Information” mechanism and honor opt-out rights. If we do not engage in such sharing, we will state that clearly. Monroe’s California Privacy Addendum reflects CPRA terminology and structure.
How we use personal information
We may use personal information to:
- respond to requests and inquiries;
- communicate about Avante and requested materials;
- maintain the Website, monitor performance, and improve content;
- help maintain the security and integrity of our systems; and
- comply with legal obligations and enforce our terms.
This aligns with the standard enumerations found in institutional manager privacy notices.
How we disclose personal information
We may disclose personal information to:
- affiliates and personnel who need it for business purposes;
- service providers that support Website hosting, analytics, CRM, communications, and security, subject to contractual confidentiality obligations;
- professional advisers (legal, accounting, auditors) where relevant;
- government authorities or others as required by law, regulation, or legal process;
- successors in the event of a merger, acquisition, or similar transaction.
Investor privacy notices; Reg S‑P / GLBA considerations
Depending on Avante’s activities and regulatory status, Avante and certain affiliates may be subject to privacy obligations under U.S. financial privacy regimes (including Regulation S‑P and/or GLBA-like requirements). Crescent provides an example of a privacy notice drafted expressly to comply with Regulation S‑P and FTC privacy regulations, and also references California rights.
Avante approach (draft): We treat nonpublic personal information collected in connection with investor onboarding, subscription, and investor servicing as highly confidential and apply administrative, technical, and physical safeguards designed to protect such information. Investor-specific privacy notices may be delivered through the investor portal and subscription documents.
Data retention
We retain personal information as reasonably necessary for the purposes described in this Policy, including to meet legal, regulatory, accounting, and security requirements. Retention periods may vary based on the type of information and the context. (If you want hard numbers, add a retention table by category.)
Data security
We maintain measures designed to protect personal information against loss and unauthorized access, use, alteration, and disclosure. No system can be guaranteed 100% secure, and transmission over the internet is not completely secure. Monroe’s privacy policy provides a typical form of this “measures designed to secure” plus “cannot guarantee” caveat.
Children’s privacy
The Website is not intended for children under 18, and we do not knowingly collect information from children. Monroe provides a market example of this clause.
Jurisdiction-specific rights
California (CCPA/CPRA). If you are a California resident, you may have rights to request access, correction, deletion, and information about our collection and disclosure practices, subject to exceptions. We will not discriminate against you for exercising your rights. Monroe’s CPRA addendum and Golub’s California notice illustrate best‑practice structures and GLBA carve-out positioning.
Other jurisdictions. Depending on your jurisdiction, you may have additional rights (e.g., GDPR-like rights if applicable). Crescent provides an example of including EU/UK notice structure.
Changes to this Privacy Policy
We may update this Policy from time to time. The Effective Date at the top reflects the latest version.