This Privacy Policy explains how Equus Capital Partners, Ltd. (“we”, “us” or “our”) and some of the companies we may work with collect, use, or disclose personal information and data we receive through use of our Site.  The term “Site” means all web sites and web pages within, or any related mobile app or online services we provide, as well as any mirror, replacement, substitute or backup sites, pages, resources and facilities controlled, owned or operated by us or on our behalf.  The policy also gives you choices about the collection and use of your information.  While this Policy governs use of the Site, personal information associated with any funds managed by us or our affiliates may be subject to a different Privacy Policy provided to you in connection with fund materials.

Please read the Privacy Policy before you use our Site; by using the Site, you agree to be bound and abide by the Terms of Use and our Privacy Policy.  If you do not agree to the Terms of Use and our Privacy Policy, or if you violate them in any way, your right to access or use the Site is terminated.

Please see the Terms of Use regarding restrictions on your legal rights in any dispute involving our Site, Terms of Use or Privacy Policy.

You understand that we may revise and update the Privacy Policy from time to time in our sole discretion.  Where appropriate, we may seek to provide advance notice before an updated Privacy Policy becomes effective. You agree that we may notify you of the updated Privacy Policy by posting it on the Site, and that your use of the Site after the effective date of the updated Privacy Policy (or engaging in such other conduct as we may reasonably specify) constitutes your agreement to the updated Privacy Policy.  It is your responsibility to check the Privacy Policy posted on the Site periodically so that you are aware of any changes, as they are binding on you.


We may collect the following types of information.

  • Information you voluntarily provide. This may include contact and registration information, username and password, and communications with us, including through email in connection with the Site
  • Information that is passively collected by the Site. We may use analytics tools to help us measure traffic, usage, and sales trends on our Site. This may also include cookies and similar technologies running on the Site.  Cookies are small files stored as text on a computer hard drive.  These “cookies” and other similar technologies like pixels, web beacons (also known as “clear GIFs”), and local storage may be used to collect information about how you use the Site and provide features to you.  Note that if a visitor does not want information collected through the use of cookies, most browsers allow the visitor to reject cookies. We may share non-personal information obtained via cookies with our advertisers and affiliates.
  • Device Identifier. When you use a mobile device to connect to our Site we may receive and use a unique device identifier to provide certain services and/or functionality.
  • Log file information. Log file information may be automatically reported by your browser each time you make a request to access (i.e., visit) the Site. It can also be provided when the content of the Site is downloaded to your browser or device.  For example, our servers can automatically record certain log file information, including your web request, Internet Protocol (“IP”) address, browser type, referring / exit pages and URLs, number of clicks and how you interact with links on the Site, domain names, landing pages, pages viewed, and other such information. We may also collect similar information from promotional emails we send send to help us track which emails are opened and which links are clicked by recipients.


In general, we use your personal information to: (1) provide customer support; (2) comply with third party contracts; (3) help you efficiently access your information after you sign in; (4) remember information so you will not have to re-enter it during your visit or the next time you visit the Site; (5) provide personalized content and information to you and others, which could include online ads or other forms of marketing; (6) provide, improve, test, and monitor the effectiveness of the Site; (7) develop and test new products and features; (8) monitor metrics such as total number of visitors, traffic, and demographic patterns; or (9) diagnose or fix technology problems.  We may also use personal information for any legitimate purpose otherwise allowed by applicable law.


We are not in the business of selling personal information about our users to third parties without your consent, except as noted in this Policy. Parties with whom we may share your information include:

  • Third Party Affiliates. We may either employ or partner with third party companies for the purposes of advertising, facilitating, or enhancing our Site. In order for these third party companies to carry out their services, your personal Information and other data collected may be shared with these third party companies (including, without limitation, website development and hosting, maintenance services, web analytics and improvement of our Site).
  • Government, Courts, and Law Enforcement. We will access, preserve, and share any information about you, without your consent, to government or law enforcement officials or private parties as we in good faith believe necessary or appropriate to respond to claims and legal process (including, but not limited to, subpoenas), to comply with applicable laws, to protect the property and rights of Equus, you or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to pose a risk of being, or is illegal, unethical or legally actionable. This may include responding to legal requests from jurisdictions outside of the United States where we have a good faith belief that the response is required by law in that jurisdiction, affects users in that jurisdiction, and is consistent with internationally recognized standards.
  • Inappropriate Activity. We may also access, preserve and share information when we have a good faith belief it is necessary to: detect, prevent and address fraud and other illegal activity; to protect ourselves, you and others, including as part of investigations; and to prevent death or imminent bodily harm. Information we receive about you may be accessed, processed and retained for an extended period of time when it is the subject of a legal request or obligation, governmental investigation, or investigations concerning possible violations of our terms or policies, or otherwise to prevent harm.


By registering for and using the Site you consent to the transfer of information to anywhere where the Site or its service providers maintain facilities and the use and disclosure of information about you as described in this Privacy Policy.

Although we implement reasonable security measures designed to protect your personal information from unauthorized access, we cannot ensure the security of any information you transmit to or guarantee that this information will not be accessed, disclosed, altered, or destroyed. We will make any legally required disclosures of any breach of the personal information.  To the extent the law of your jurisdiction allows for notification of a breach via e-mail or conspicuous posting on the Site, you agree to accept notice in that form.


In all promotional emails, you will be given the opportunity to opt-out of receiving such messages in the future by clicking on the link at the bottom of the email that says “unsubscribe.” It may take up to ten (10) business days for us to process your opt-out request.  Please note that we reserve the right to send you Site-related communications (e.g., account information, payment confirmations, as well as technical, security and administrative notices) that you may not opt out of.

If you do not want information collected through the use of cookies, most browsers allow the visitor to reject cookies. Note this this may impact the functionality of the Site.


We may share all or some of your personal information with any of our subsidiaries, joint ventures, or other companies under common control to be used in a manner consistent with this Policy. Additionally, in the event we anticipate or go through a business transition such as a merger, acquisition by another company, or sale of all or a portion of our assets, your personal information may be among the assets transferred. You acknowledge that such transfers may occur and are permitted by this Privacy Policy, and that any entity that acquires such personal information by transfer may continue to process your personal information as set forth in this Policy.  The buyer or transferee will have to honor the commitments we have made in this Privacy Policy.


Information that you provide or that we collect through the Site are retained as long as needed for business purposes, but may be retained indefinitely.


We do not knowingly collect or solicit any information from anyone under the age of 13 or knowingly allow such persons to register for the Site. The Site and its content is not directed at children under the age of 13. In the event that we learn that we have collected personal information from a child under age 13 without parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13, please contact us at


We do not track users over time and across third party websites to provide targeted advertising.  We do not respond to Do Not Track (DNT) signals and handle all user information consistent with our Terms of Use and this Privacy Policy.


The Site may contain links to other websites or services that we do not own or operate. We are not responsible for the practices employed by any websites or services linked to or from the Site, including the information or content contained within them. Your browsing and interaction on any third-party website or service, including those that have a link on our Site, are subject to that third party’s own rules and policies, not ours.  In addition, you agree that we are not responsible and do not have control over any third-parties that you authorize to access your information. If you are using a third-party website or service and you allow them to access your information you do so at your own risk.


We have developed data practices designed to assure information is appropriately protected but we cannot always know where personal information may be accessed or processed. While our primary data centers are in the United States, we may transfer personal information or other information to our offices outside of the United States. In addition, we may employ other companies and individuals to perform functions on our behalf. If we disclose personal information to a third party or to our employees outside of the United States, we will seek assurances that any information we may provide to them is safeguarded adequately and in accordance with this Privacy Policy and the requirements of applicable privacy laws.

If you are visiting from the European Union or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your personal data, including sensitive data, by us from your region to countries which do not have data protection laws that provide the same level of protection that exists in countries in the European Economic Area, including the United States. By providing your personal information, you consent to any transfer and processing in accordance with this Policy.


Please direct questions or concerns about this Privacy Policy to