Privacy Policy
Last Revised: April 9, 2026
This Privacy Policy describes how Hbar Capital LLC ("HBAR Capital," "we," "us," or "our") collects, uses, and protects information obtained through our website at hbarcapital.ai and in connection with our business activities. Please read this policy carefully. By using our website, you acknowledge the practices described herein.
Scope and Applicability
This Privacy Policy applies to personal information collected through the hbarcapital.ai website and through direct business inquiries and communications. It does not apply to information collected from investors pursuant to a fund subscription or investment management agreement, which is governed separately by our investor privacy notice issued under the Gramm-Leach-Bliley Act ("GLBA") and SEC Regulation S-P.
As a fund manager domiciled in Delaware with principal operations in California, HBAR Capital is subject to applicable federal privacy requirements under the GLBA and Regulation S-P, as well as the California Consumer Privacy Act ("CCPA"), as amended by the California Privacy Rights Act ("CPRA"), for certain categories of personal information not covered by federal financial privacy law.
Information We Collect
Information you provide directly
When you submit an inquiry through our website contact form or communicate with us directly, we may collect:
- Name, email address, firm name, and job title
- Investor type and professional background
- Any other information you voluntarily provide in your inquiry
Information collected automatically
When you visit our website, we may automatically collect certain technical information, including:
- IP address and general geographic location
- Browser type, operating system, and device information
- Pages visited, time spent on pages, and referring URLs
- Date and time of your visit
This information is collected through standard server logs and may be supplemented by analytics tools. We do not use this information to identify you personally unless combined with information you provide directly.
Cookies and tracking technologies
Our website may use cookies and similar technologies to improve your browsing experience and analyze site usage. You may configure your browser to refuse cookies, though this may affect certain website functionality. We do not use cookies for targeted advertising or cross-site tracking.
How We Use Your Information
We use the information we collect for the following purposes:
- To respond to your inquiries and communicate with you about HBAR Capital and its strategies
- To evaluate whether you meet the qualifications for receiving fund offering materials
- To send you information you have requested about our investment strategies, consistent with applicable securities laws
- To maintain records of our business communications as required by applicable regulations
- To improve the functionality and content of our website
- To comply with legal and regulatory obligations
- To protect the security and integrity of our systems and information
We do not sell, rent, or trade your personal information to third parties for their own marketing purposes. We do not use your information for automated decision-making or profiling that produces legal or similarly significant effects.
Legal Basis for Processing
Where applicable law requires a legal basis for processing personal information, we rely on the following:
- Legitimate interests — operating our business, responding to inquiries, and maintaining business records
- Legal obligation — complying with applicable securities laws, anti-money laundering requirements, and other regulatory obligations
- Consent — where you have expressly consented to specific uses of your information
- Contract — where processing is necessary to take steps at your request prior to entering into a contractual relationship
Information Sharing and Disclosure
We may share your personal information in limited circumstances:
- Service providers — We may share information with third-party service providers who assist us in operating our website, managing our CRM systems, or processing data on our behalf. Such providers are contractually bound to use your information only as directed by us and to maintain appropriate confidentiality.
- Legal and regulatory requirements — We may disclose information when required by law, regulation, court order, or governmental authority, including the SEC and FINRA.
- Business transfers — In the event of a merger, acquisition, or sale of all or a portion of our assets, personal information may be transferred as part of that transaction.
- Protection of rights — We may disclose information to protect the rights, property, or safety of HBAR Capital, our personnel, or others.
We do not otherwise disclose your personal information to third parties without your consent.
Data Retention
We retain personal information for as long as necessary to fulfill the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law. Business communication records are generally retained for a minimum of five years in accordance with applicable securities regulations. Website analytics data is retained for a shorter period consistent with its operational purpose.
When personal information is no longer needed, we take reasonable steps to securely delete or anonymize it.
Data Security
We implement administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, disclosure, alteration, and destruction. These measures include access controls, encryption of data in transit, and periodic security assessments.
No method of transmission over the internet or electronic storage is completely secure. While we strive to use commercially acceptable means to protect your information, we cannot guarantee absolute security. In the event of a data breach affecting your personal information, we will notify you as required by applicable law.
California Privacy Rights (CCPA / CPRA)
If you are a California resident, you may have certain rights under the CCPA and CPRA with respect to personal information not covered by the GLBA exemption. These rights include:
Right to know
You have the right to request disclosure of the categories and specific pieces of personal information we have collected about you, the sources of that information, the purposes for which we use it, and the categories of third parties with whom we share it.
Right to delete
You have the right to request deletion of personal information we have collected about you, subject to certain exceptions permitted by law, including information we are required to retain for legal or regulatory compliance purposes.
Right to correct
You have the right to request correction of inaccurate personal information we maintain about you.
Right to opt out of sale or sharing
We do not sell or share personal information as those terms are defined under the CCPA/CPRA. You therefore do not need to submit an opt-out request with respect to sale or sharing.
Right to non-discrimination
We will not discriminate against you for exercising any of your CCPA/CPRA rights.
How to exercise your California rights
To submit a verifiable consumer request, please contact us at privacy@hbarcapital.ai. We will respond within 45 days of receiving a verifiable request. If we need additional time, we will notify you of the extension and the reason within the initial 45-day period.
International Visitors
Our website is operated from and directed at persons in the United States. If you are located outside the United States, please be aware that information you provide will be transferred to and processed in the United States, where privacy laws may differ from those in your jurisdiction. By using our website, you consent to this transfer and processing.
We do not specifically target or solicit persons in the European Economic Area. If you are located in the EEA and believe GDPR applies to your information, please contact us at the address below and we will address your inquiry appropriately.
Children's Privacy
Our website is not directed at children under the age of 18, and we do not knowingly collect personal information from minors. If we become aware that we have collected personal information from a person under 18, we will take steps to delete that information promptly.
Third-Party Links
Our website may contain links to third-party websites. This Privacy Policy does not apply to those websites. We encourage you to review the privacy policies of any third-party sites you visit. We are not responsible for the privacy practices or content of external websites.
Changes to This Privacy Policy
We reserve the right to modify this Privacy Policy at any time. Changes are effective upon posting to our website. We will note the date of the most recent revision at the top of this page. We encourage you to review this policy periodically. Your continued use of our website after changes are posted constitutes acceptance of the updated policy.
Contact Us
For questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact:
Hbar Capital LLC
Menlo Park, California
Email: privacy@hbarcapital.ai
This Privacy Policy does not constitute legal advice. HBAR Capital recommends that prospective investors consult their own legal advisors regarding privacy rights and data protection matters applicable to their specific circumstances.