Privacy Policy

Silver Rock Capital Holdings (“SRCH”, “we”, “us”, “our”)

Last Updated: September 22, 2025

Summary

• We collect limited personal data to run our website, manage investor and deal relationships, deliver research, and recruit talent.

• We don’t sell your data. We only share it with service providers, professional advisors, or when legally required.

• You can opt out of marketing, manage cookies, and request access, deletion, or correction of your data.

• If you’re in the EEA/UK, we rely on lawful bases under GDPR; if you’re in certain U.S. states, you have additional rights under state privacy laws.

1) Scope & Who This Covers

This Policy explains how SRCH processes personal data of:

• Website visitors to [website URL] and related pages;

• Investors and prospects (and their representatives);

• Founders, executives, counterparties, and advisors in connection with origination, diligence, and portfolio management;

• Research subscribers (newsletters, reports, event registrations);

• Job applicants and other candidates.

This Policy does not cover portfolio companies’ own processing activities (they maintain their own privacy notices).

2) The Data We Collect

Information you provide directly: name, email, phone, employer/title, postal address, account preferences, calendar scheduling details, documents you upload (e.g., CVs, decks, reports), and any messages you send us.
Information we collect automatically: IP address, device/browser type, pages viewed, referring/exit pages, timestamps, and approximate location derived from IP. We use cookies and similar technologies (see Section 9).
Deal & investor information: KYC/AML documents, beneficial ownership, accreditation status, subscription docs, wire instructions (tokenized/segmented), tax IDs where required by law.
Recruiting data: CV/resume, professional history, references, eligibility to work, assessment notes.
Research interactions: downloads, opens, link clicks, event attendance, and preference center selections.

We do not intentionally collect sensitive personal information unless required by law (e.g., sanctions screening) or you voluntarily provide it during recruiting; where required, we will obtain explicit consent.

3) Sources of Data

• Directly from you (forms, email, meetings, events).

• Your organization (if you act on its behalf).

• Referrals, publicly available sources, and professional databases (e.g., corporate registries, sanctions lists).

• Service providers (analytics, communications, KYC/AML vendors).

4) How We Use Your Data (Purposes)

• Website & security: operate, protect, debug, and improve our site and services.

• Communications: respond to inquiries, send research/insights, event invites, or operational notices.

• Origination & diligence: evaluate opportunities, perform KYC/AML/sanctions checks, manage NDAs and data rooms.

• Investor relations: onboard and service LPs, process subscriptions, comply with legal/reporting obligations.

• Recruiting: assess candidates, schedule interviews, maintain talent records.

• Compliance & risk: enforce agreements, prevent fraud, meet regulatory requirements, and maintain records.

5) Our Legal Bases (EEA/UK only)

Where GDPR/UK GDPR applies, we rely on:

• Legitimate interests (e.g., B2B communications, security, deal/investor management);

• Contract necessity (to perform an agreement with you or your organization);

• Legal obligation (e.g., KYC/AML, tax, recordkeeping);

• Consent (for certain marketing/cookies where required withdraw at any time via contact@silverrockcapitalholdings.com).

6) How We Share Information

We do not sell personal data. We share only as needed with:

• Service providers/processors: hosting, email/CRM, analytics, KYC/AML, document management, IT/security.

• Professional advisors: auditors, lawyers, consultants.

• Counterparties: if reasonably necessary for a transaction and subject to confidentiality.

• Regulators and law enforcement: when required by law or to protect rights, safety, and security.

• Corporate events: in the event of a merger, acquisition, or restructuring, subject to this Policy or a successor notice.

All processors are bound by contractual obligations to safeguard data and act on our instructions.

7) International Data Transfers

We may process and store data in countries outside your own, including the U.S. Where required, we use appropriate safeguards such as the EU Commission’s Standard Contractual Clauses (SCCs) and, for the UK, the International Data Transfer Addendum. Details available on request.

8) Data Retention

We keep data only as long as necessary for the purposes described, or as required by law. Typical periods:

• Website analytics logs: [e.g., 12–24 months]

• Marketing records: until you opt out or after [e.g., 24 months] of inactivity

• Investor/KYC records: [e.g., 5–7 years] from the end of the relationship (or longer if required)

• Deal diligence files: [e.g., 5–7 years] or per legal/contractual requirements

• Recruiting: [e.g., 24 months] unless you ask us to retain or delete sooner

9) Cookies & Similar Technologies

We use:

• Strictly necessary cookies (site functionality/security),

• Performance/analytics (traffic patterns, page performance),

• Functional (remember choices), and

• Marketing (when you opt in, to measure engagement with research).

Manage preferences at any time via [contact@silverrockcapitalholdings.com]. Browser-level controls may limit some site features.

10) Your Rights

Your rights depend on your location. Subject to applicable law, you may have the right to:

Global/General

• Access/know the personal data we hold about you.

• Correct (rectify) inaccurate data.

• Delete (erase) data in certain circumstances.

• Restrict or object to processing (especially for direct marketing).

• Withdraw consent where processing is based on consent.

• Data portability (receive your data in a usable format).

EEA/UK

• Lodge a complaint with your supervisory authority (e.g., in the EEA, see https://edpb.europa.eu; in the UK, the ICO).

• Know if we use automated decision-making with legal or similarly significant effects (we do not engage in such decisions).

U.S. (e.g., CA/CO/CT/VA/UT, “state privacy laws”)

• Right to know/access, correct, delete, data portability.

• Right to opt out of sale, sharing for cross-context behavioral advertising, and targeted advertising. SRCH does not “sell” personal data as defined by these laws and does not share for cross-context advertising.

• Right to limit use and disclosure of sensitive personal information (we do not use SPI beyond what’s necessary for compliance and operations).

• Appeals process: If we deny your request, you may appeal by emailing [contact@silverrockcapitalholdings.com]with Subject: Privacy Request Appeal; we will respond within the time required by law.

To exercise any rights, contact [contact@silverrockcapitalholdings.com] and specify your request and jurisdiction. We may verify your identity and, in some regions, accept authorized agent requests.

11) Marketing Preferences

You can opt out of marketing emails by clicking “unsubscribe” in our messages or emailing [contact@silverrockcapitalholdings.com]. We may still send you non-marketing communications (e.g., transactional or legal notices).

12) Security

We apply administrative, technical, and physical safeguards appropriate to the nature of the data, including access controls, encryption in transit and at rest (where applicable), logging/monitoring, and regular reviews. No method of transmission or storage is 100% secure; we cannot guarantee absolute security.

13) Children’s Privacy

Our services are not directed to children under 16 (or the age defined by local law). We do not knowingly collect personal data from children. If you believe a child has provided us data, contact [contato@silverrockcapitalholdings.com] and we will delete it.

14) Third-Party Links

Our site may contain links to third-party websites or services. Their privacy practices are governed by their own policies; we are not responsible for them.

15) Changes to This Policy

We may update this Policy from time to time. When we do, we will revise the “Last Updated” date above and, where appropriate, notify you by prominent notice on our site or by email.

16) Contact Us

Silver Rock Capital Holdings
Email: contact@silverrockcapitalholdings.com
Mailing Address: 16901 Collins avenue, Sunny Isles 33160

17) Region-Specific Notices (Optional Add-Ons)

California “Shine the Light”

California residents may request a list of third parties to whom we disclosed personal information for their direct marketing purposes during the prior calendar year (if any). To request this, email [contact@silverrockcapitalholdings.com] with “Shine the Light” in the subject line.

Candidate Privacy Notice (Summary)

For job applicants, we process your data to evaluate fit, verify information, organize interviews, and comply with law. We may retain your profile to consider you for future roles. To request deletion or updates, contact [contact@silverrockcapitalholdings.com].

Annex (Optional): Cookie Categories We Use

• Necessary: session, load balancing, security.

• Analytics: page views, scroll depth, referring sites ([e.g., Google Analytics] with IP anonymization where configured).

• Functional: language, saved preferences.

• Marketing (opt-in): email open/click tracking for research distribution ([e.g., Mailchimp/HubSpot]).