Privacy Policy

1. Scope

This policy describes the privacy practices of TokenCap Advisors LLC (“TCA”, “we”, “our”), a Texas limited liability company and an entity of 2678 Holdings LLC. It applies to this website (tokencapadvisors.com) and related communications.

2. What we collect

The website does not currently require account creation, does not operate on-site forms with server submission, and does not set first-party analytics cookies. We collect:

• Email correspondence. When you email inquiries@tokencapadvisors.com, we receive your email address, the content of your message, and any materials you attach.
• Engagement data. If TCA enters a formal engagement with you or your entity, we collect the data necessary to perform the engagement (sponsor information, project materials, signatory details) under the terms of the engagement letter.
• Technical access logs. Our hosting provider (Vercel) maintains standard server logs including IP address, user agent, and page accessed. These logs are retained per the hosting provider’s standard retention policy and are not used for analytics or marketing profiling.

3. How we use data

Data is used strictly for the following purposes:

• Responding to inquiries
• Performing analytical work under engagement terms
• Regulatory and recordkeeping compliance (see also our Regulatory Posture page)
• Security and operational integrity of the website and our systems

We do not sell personal data. We do not use personal data to train AI or machine learning systems. We do not share personal data with third parties for marketing purposes.

4. How long we keep data

Consistent with our voluntary adherence to recordkeeping practices modeled on 17 C.F.R. § 275.204-2, engagement-related records are retained for a minimum of five years. Inquiries not leading to engagement are retained only as long as needed to complete the conversation. Access logs follow the hosting provider’s standard retention.

5. Your rights

Depending on your jurisdiction, you may have rights to request access to, correction of, or deletion of personal data we hold about you. Requests can be submitted to inquiries@tokencapadvisors.com with subject “Privacy Rights Request”. We will respond within applicable legal timelines.

Note that records subject to our regulatory recordkeeping commitments cannot be deleted prior to the end of their required retention period, even on request.

6. Security

TCA applies reasonable administrative, technical, and physical safeguards to protect personal data. This includes encrypted communications, access controls, and audit logging for our internal analytical systems. No system is perfectly secure; we commit to transparency about significant security events affecting your data.

7. Children

This website is not directed to children under 16. We do not knowingly collect data from children.

8. Changes to this policy

We may update this policy as our practices evolve. Material changes will be noted on this page with an updated date. We encourage periodic review.

9. Contact

Questions about this policy or our privacy practices can be directed to inquiries@tokencapadvisors.com with subject “Privacy Inquiry”.