‍Affluent Ventures LLC — 029 Capital contact@029cap.com | 029cap.com/privacy

‍Last updated: April 2026

1. Introduction

This Privacy Policy explains how Affluent Ventures LLC, a Delaware limited liability company operating under the trade name "029 Capital" (registered address: 111B S Governors Ave STE 28959, Dover, Delaware 19904, United States; "we," "us," or "our") collects, uses, and protects personal data in connection with your use of www.029cap.com (the "Website").

We are committed to protecting your privacy and handling your personal data in accordance with Regulation (EU) 2016/679 ("GDPR") and other applicable data protection laws. By accessing or using the Website, you acknowledge that you have read and understood this Privacy Policy.

2. Data Controller

Affluent Ventures LLC (029 Capital) 111B S Governors Ave STE 28959 Dover, Delaware 19904, United States contact@029cap.com

We currently assess whether the appointment of an EU representative is required under Article 27 GDPR given the nature and scope of our processing activities.

3. Data We Collect

3.1 Data collected automatically When you visit the Website, our hosting provider automatically collects certain technical information including your IP address (pseudonymized where applicable), browser type and version, operating system, referring URL, pages visited, time and date of access, and session duration. This data is processed solely for the purpose of ensuring the technical operation and security of the Website.

3.2 Data you provide voluntarily If you contact us by email or through any other channel, we process the data you provide including your name, email address, and the content of your message for the purpose of responding to your inquiry.

3.3 Data collected through tracking and analytics tools Subject to your prior explicit consent, we use the third-party tools described in Section 7 below. Analytics, marketing, and tracking technologies are only activated after you have provided explicit consent via the cookie banner. No analytics or marketing cookies or tracking scripts are loaded or activated prior to consent. Consent is obtained separately for different categories of cookies, including analytics and marketing where required. We document and store user consent in accordance with applicable legal requirements.

4. Purpose and Legal Basis for Processing

4.1 Operation and security of the Website Legal basis: legitimate interests pursuant to Article 6(1)(f) GDPR. Our legitimate interests are balanced against the rights and freedoms of data subjects. Our legitimate interest lies in maintaining a functional and secure online presence.

4.2 Responding to inquiries Legal basis: legitimate interests pursuant to Article 6(1)(f) GDPR, or performance of pre-contractual measures pursuant to Article 6(1)(b) GDPR where applicable.

4.3 Website analytics and marketing tracking Legal basis: your explicit consent pursuant to Article 6(1)(a) GDPR, obtained through our cookie consent mechanism prior to loading any analytics or marketing tools.

4.4 Compliance with legal obligations Processing may also occur where necessary to comply with applicable legal obligations pursuant to Article 6(1)(c) GDPR.

5. Cookies and Consent

We use cookies in connection with the third-party tools described in Section 7. Before any analytics or marketing cookies or tracking scripts are activated, we request your explicit consent through a cookie banner displayed on your first visit to the Website. No tracking tools are loaded prior to your consent.

Consent is obtained separately for different categories of cookies including analytics and marketing. It is as easy to withdraw consent as it is to give it. You may manage your cookie preferences at any time via the cookie settings tool available on the Website. Withdrawal of consent does not affect the lawfulness of processing prior to withdrawal.

Strictly necessary cookies required for the technical operation of the Website, including cookies required for security, session management, and basic website functionality, may be set without consent on the basis of our legitimate interests.

We do not carry out automated decision-making or profiling with legal or similarly significant effects within the meaning of Article 22 GDPR.

6. Data Retention

We retain personal data only for as long as necessary:

Server log data: deleted after 30 days. Google Analytics data: deleted after 14 months as configured in our settings. Microsoft Clarity data: retained for up to 13 months as configured in our settings. Meta Pixel and LinkedIn Insight Tag data: once transmitted to the respective platforms, we have no control over the retention periods applied by those providers. Contact inquiry data: retained for as long as necessary to handle your inquiry and deleted thereafter unless a longer retention period is required by law.

7. Third-Party Services

7.1 Hosting Provider We use a third-party hosting provider located within the European Union acting as a data processor on our behalf. A data processing agreement has been concluded in accordance with Article 28 GDPR.

7.2 Google Analytics We use Google Analytics provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. We have configured Google Analytics in a privacy-compliant manner, including IP anonymization where supported, disabling of data sharing with Google, and no use of User-ID tracking. IP anonymization is enabled where technically supported, meaning your IP address is truncated within the European Economic Area prior to transmission.

Data may be transferred to Google's servers in the United States on the basis of Standard Contractual Clauses. A Data Processing Amendment has been concluded with Google. You may request a copy of applicable safeguards by contacting us.

Opt-out: https://tools.google.com/dlpage/gaoptout Google Privacy Policy: https://policies.google.com/privacy

7.3 Google Tag Manager We use Google Tag Manager provided by Google Ireland Limited. Google Tag Manager does not independently process personal data but facilitates the loading of other services on the Website. It operates solely as a technical container and does not set cookies independently.

7.4 Microsoft Clarity We use Microsoft Clarity provided by Microsoft Corporation, One Microsoft Way, Redmond, WA 98052, USA. Microsoft Clarity records pseudonymized session data including mouse movements, clicks, and scrolling behavior to help us understand how visitors interact with the Website. These services may combine your data with information from your user account on their respective platforms and may be used for profiling and personalized advertising. This tool is only activated following your explicit consent.

Data may be transferred to the United States on the basis of Standard Contractual Clauses. You may request a copy of applicable safeguards by contacting us. Microsoft Privacy Policy: https://privacy.microsoft.com/privacystatement

7.5 Meta Pixel We use the Meta Pixel provided by Meta Platforms Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland. The Meta Pixel collects data about your interactions with the Website and transmits it to Meta for measuring advertising effectiveness and enabling retargeting on Facebook and Instagram. These services may combine your data with information from your user account on their respective platforms and may be used for profiling and personalized advertising. This tool is only activated following your explicit consent.

For certain processing activities in connection with the Meta Pixel, we and Meta may act as joint controllers pursuant to Article 26 GDPR. The respective agreement pursuant to Article 26 GDPR defines the allocation of responsibilities between the parties. You can manage your ad preferences via your Meta account settings.

Data may be transferred to the United States on the basis of Standard Contractual Clauses. You may request a copy of applicable safeguards by contacting us. Meta Privacy Policy: https://www.facebook.com/privacy/policy/

7.6 LinkedIn Insight Tag We use the LinkedIn Insight Tag provided by LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland. The LinkedIn Insight Tag collects data about your visits to the Website and enables conversion tracking and retargeted advertising on LinkedIn. These services may combine your data with information from your user account on their respective platforms and may be used for profiling and personalized advertising. This tool is only activated following your explicit consent.

For certain processing activities in connection with the LinkedIn Insight Tag, we and LinkedIn may act as joint controllers pursuant to Article 26 GDPR. The respective agreement pursuant to Article 26 GDPR defines the allocation of responsibilities between the parties. You can manage your ad preferences via your LinkedIn account settings.

Data may be transferred to the United States on the basis of Standard Contractual Clauses. You may request a copy of applicable safeguards by contacting us. LinkedIn Privacy Policy: https://www.linkedin.com/legal/privacy-policy

8. International Data Transfers

Affluent Ventures LLC is based in the United States. If you access the Website from the European Economic Area, your personal data may be transferred to and processed in the United States or other countries that do not provide a level of data protection equivalent to that of the European Union.

We ensure that such transfers are conducted on the basis of Standard Contractual Clauses adopted by the European Commission pursuant to Article 46(2)(c) GDPR or other appropriate safeguards where applicable. We assess whether additional safeguards are required on a case-by-case basis in accordance with applicable guidance following Schrems II. You may request a copy of the applicable safeguards by contacting us at contact@029cap.com.

9. Your Rights

If you are located in the European Economic Area, you have the following rights:

Right of access — Request confirmation and a copy of your personal data (Article 15 GDPR).

Right to rectification — Request correction of inaccurate or incomplete data (Article 16 GDPR).

Right to erasure — Request deletion where there is no longer a lawful basis for processing (Article 17 GDPR).

Right to restriction — Request restriction of processing in certain circumstances (Article 18 GDPR).

Right to data portability — Request your data in a structured, machine-readable format (Article 20 GDPR).

Right to object — Object to processing based on legitimate interests, in particular to processing for direct marketing or analytics purposes (Article 21 GDPR).

Right to withdraw consent — Withdraw consent at any time via the cookie settings tool on the Website or by contacting us. It is as easy to withdraw consent as it is to give it. Withdrawal does not affect prior lawful processing.

Right to lodge a complaint — You have the right to lodge a complaint with the competent supervisory authority in your jurisdiction.

To exercise any of these rights: contact@029cap.com

We will respond within 30 days. We may request identity verification before processing your request.

10. Children

This Website is not directed at persons under the age of 18. We do not knowingly process data of individuals under 18 and do not target such individuals. If you believe we have inadvertently collected such data, please contact us and we will delete it promptly.

11. Security

We implement appropriate technical and organizational measures to protect personal data against unauthorized access, accidental loss, destruction, or disclosure, including encryption, access controls, restricted access to systems, and data minimization principles. No transmission over the internet is entirely secure and we cannot guarantee absolute security.

12. Third-Party Websites

This Website may contain links to third-party websites. We are not responsible for the privacy practices of those websites and encourage you to review their respective privacy policies.

13. Changes to This Policy

We may update this Privacy Policy from time to time. Any changes will be published on this page with a revised "last updated" date. Continued use of the Website following any update constitutes acceptance of the revised Policy.

14. Contact

Affluent Ventures LLC (029 Capital) contact@029cap.com 111B S Governors Ave STE 28959 Dover, Delaware 19904, United States

Last updated: April 2026

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