Privacy policy

Last updated: August 18, 2026

1. PERSONAL INFORMATION WE COLLECT

We collect personal information that is reasonably necessary for the operation of our business, the provision of our Services, the establishment and management of commercial relationships, the evaluation and execution of transactions, compliance with legal and regulatory obligations, and the protection of our business and other persons.

The categories of personal information we collect may include:

Contact Information

• first and last name;
• title and professional position;
• company or organization;
• business and personal email address;
• telephone and mobile telephone number;
• mailing address;
• billing address;
• business address;
• country, state, city, and postal code; and
• other contact information provided to us.

Identification Information

Where appropriate or legally required, we may collect:

• passport information;
• driver’s license information;
• national identification information;
• tax identification numbers;
• Social Security numbers or equivalent identifiers;
• date and place of birth;
• nationality and citizenship information;
• residency information;
• visa or immigration information;
• photographs and identification documents;
• signatures; and
• information required to verify identity.

Professional and Business Information

We may collect:

• employer and employment history;
• professional title and responsibilities;
• professional qualifications;
• educational background;
• corporate affiliations;
• directorships and beneficial ownership information;
• business relationships;
• professional references;
• information concerning companies or organizations represented by you; and
• information contained in business correspondence and transaction documentation.

Financial Information

Where relevant to our Services or business relationships, we may collect:

• bank account information;
• payment information;
• transaction information;
• source-of-funds information;
• source-of-wealth information;
• financial statements;
• assets and liabilities;
• income and revenue information;
• investment experience;
• financing requirements;
• credit-related information;
• transaction history;
• payment history;
• tax information;
• ownership information; and
• information relating to financial transactions or proposed transactions.

Transaction Information

We may collect information relating to:

• financing applications;
• investment opportunities;
• payment transactions;
• merchant relationships;
• commercial agreements;
• invoices;
• contracts;
• transaction histories;
• counterparties;
• payment instruments;
• settlement information;
• banking relationships;
• financing structures;
• investment structures;
• advisory engagements; and
• other commercial activities conducted with or through us.

Communications Information

We may collect information contained in:

• emails;
• telephone communications;
• correspondence;
• website submissions;
• contact forms;
• meeting records;
• transaction communications;
• support requests;
• documents provided to us;
• communications with our personnel; and
• communications through third-party platforms used in connection with our Services.

Technical and Online Information

When you interact with our websites or digital Services, we may collect:

• IP address;
• browser type;
• operating system;
• device type;
• device identifiers;
• language preferences;
• screen resolution;
• approximate geographic location;
• pages viewed;
• navigation activity;
• referring websites;
• access times;
• session information;
• interaction data;
• website performance information;
• security and authentication information; and
• other technical information generated through your use of our Services.

Employment Information

For recruitment and employment purposes, we may collect:

• employment history;
• education;
• professional qualifications;
• references;
• compensation expectations;
• identification documents;
• residency and immigration information;
• background-check information where permitted by law;
• professional certifications;
• application materials; and
• other information submitted in connection with an employment or consulting application.

Other Information

We may collect other personal information where:

• you voluntarily provide it;
• it is reasonably necessary for a transaction or business relationship;
• applicable law permits or requires us to collect it; or
• we disclose the relevant collection at or before the time of collection.

2. INFORMATION YOU PROVIDE TO US

We collect personal information directly from you when you:

• contact us;
• request information;
• submit an inquiry;
• request financing or advisory services;
• participate in a potential transaction;
• establish or maintain a commercial relationship with us;
• submit documents;
• communicate with our personnel;
• subscribe to communications;
• participate in an event;
• submit an employment application;
• use our website or digital Services; or
• otherwise voluntarily provide information to us.

You are responsible for ensuring that personal information you provide to us is accurate and, where you provide information concerning another individual, that you are authorized to provide that information.

3. INFORMATION WE OBTAIN FROM THIRD PARTIES

We may obtain personal information from third parties, including:

• clients and prospective clients;
• business partners;
• financial institutions;
• payment service providers;
• banks;
• acquiring institutions;
• payment processors and gateways;
• investors;
• financing counterparties;
• professional advisers;
• lawyers;
• accountants;
• auditors;
• consultants;
• insurers;
• credit-reference agencies;
• fraud-prevention providers;
• identity-verification providers;
• KYC and AML service providers;
• sanctions-screening providers;
• corporate registries;
• government authorities;
• public databases;
• publicly available websites;
• social media platforms;
• data providers;
• transaction counterparties; and
• other lawful sources.

Where we receive personal information from another source, we may combine that information with information already held by us where permitted by applicable law.

4. AUTOMATICALLY COLLECTED INFORMATION

We, our technology providers, and our service providers may automatically collect information about your device and interactions with our Services.

This may include:

• IP address;
• device identifiers;
• browser information;
• operating system;
• device type;
• network information;
• website activity;
• pages viewed;
• links clicked;
• time spent on pages;
• access dates and times;
• referring URLs;
• error logs;
• security logs;
• authentication information; and
• similar technical information.

We may use this information to operate, secure, analyze, maintain, and improve our Services.

5. COOKIES AND SIMILAR TECHNOLOGIES

Our websites may use cookies, pixels, tags, scripts, local storage, and similar technologies.

These technologies may be used to:

• operate our website;
• remember preferences;
• maintain security;
• understand website traffic;
• analyze website performance;
• measure communications;
• improve user experience; and
• support marketing activities where permitted by applicable law.

Where applicable law requires consent for non-essential cookies or similar technologies, we will request consent before using those technologies.

You may also control certain cookies through your browser settings or available cookie-management tools.

Disabling certain cookies may affect the functionality of our Services.

6. HOW WE USE PERSONAL INFORMATION

We may use personal information for the following purposes:

Service Delivery and Operations

We may use personal information to:

• provide and operate our Services;
• respond to inquiries;
• establish and maintain business relationships;
• manage accounts and relationships;
• communicate with clients and counterparties;
• administer transactions;
• provide support;
• maintain records;
• manage our systems; and
• operate our business.

Transaction Evaluation and Execution

We may process personal information to:

• evaluate potential transactions;
• evaluate financing opportunities;
• evaluate investment opportunities;
• conduct commercial due diligence;
• assess counterparties;
• administer transactions;
• negotiate agreements;
• execute contracts;
• facilitate settlements;
• coordinate with financial institutions and service providers; and
• maintain transaction records.

Business Development

We may use personal information to:

• identify potential clients;
• identify potential business partners;
• evaluate commercial opportunities;
• communicate with potential counterparties;
• provide information regarding our Services; and
• develop and maintain business relationships.

Security

We may use personal information to:

• protect our systems;
• authenticate users;
• detect unauthorized access;
• investigate security incidents;
• prevent fraud;
• prevent identity theft;
• monitor suspicious activity; and
• protect our personnel, clients, counterparties, systems, and property.

7. BUSINESS, TRANSACTION, FINANCING AND INVESTMENT ACTIVITIES

Because ANGULO & PARTNERS operates in commercial, financial, payment, financing, advisory, and investment-related environments, we may process personal information as part of evaluating, structuring, negotiating, executing, administering, monitoring, and terminating business relationships and transactions.

This may include information relating to:

• business owners;
• directors;
• officers;
• shareholders;
• beneficial owners;
• investors;
• lenders;
• borrowers;
• merchants;
• payment counterparties;
• financial institutions;
• service providers;
• advisers; and
• other persons connected with a transaction.

Such processing may be necessary to establish commercial relationships, perform contractual obligations, comply with applicable law, conduct due diligence, manage risk, and protect legitimate business interests.

8. COMPLIANCE, DUE DILIGENCE AND RISK MANAGEMENT

We may process personal information to comply with legal, regulatory, contractual, and internal requirements.

These activities may include:

• know-your-customer procedures;
• customer due diligence;
• enhanced due diligence;
• anti-money laundering procedures;
• counter-terrorist financing requirements;
• sanctions screening;
• fraud prevention;
• identity verification;
• beneficial ownership verification;
• source-of-funds verification;
• source-of-wealth verification;
• regulatory reporting;
• tax compliance;
• accounting and audit requirements;
• legal proceedings;
• responding to subpoenas and lawful requests;
• enforcing contractual rights;
• investigating suspected misconduct; and
• preventing or detecting unlawful activity.

We may obtain relevant information from public records, government authorities, compliance providers, financial institutions, screening providers, and other lawful sources.

9. COMMUNICATIONS AND MARKETING

We may communicate with you regarding:

• our Services;
• transactions;
• business opportunities;
• financing opportunities;
• investment opportunities;
• corporate developments;
• publications;
• events;
• research;
• newsletters; and
• other business-related matters.

Where required by applicable law, we will obtain consent before sending certain marketing communications.

You may unsubscribe from marketing communications by using the unsubscribe mechanism contained in the communication or by contacting us.

You will continue to receive essential administrative, transactional, security, legal, and service-related communications where necessary.

10. RESEARCH, ANALYTICS AND BUSINESS IMPROVEMENT

We may use personal information to:

• analyze website usage;
• understand business trends;
• evaluate the effectiveness of our Services;
• improve our website;
• improve internal systems;
• develop new Services;
• conduct research;
• assess business performance;
• identify operational risks; and
• create aggregated, statistical, de-identified, or anonymized information.

Where information has been properly de-identified or anonymized, we may use and disclose such information for lawful business purposes to the extent permitted by applicable law.

11. AUTOMATED DECISION-MAKING AND ARTIFICIAL INTELLIGENCE

We may use automated technologies, including artificial intelligence and machine-learning tools, for legitimate business purposes such as:

• document analysis;
• operational support;
• cybersecurity;
• fraud detection;
• compliance screening;
• data organization;
• research;
• analytics;
• service improvement; and
• internal business processes.

Unless otherwise disclosed to you, we do not intend to make decisions based solely on automated processing that produce legal or similarly significant effects on you.

Where applicable law provides rights relating to automated decision-making or profiling, we will comply with those requirements.

12. HOW WE SHARE PERSONAL INFORMATION

We may disclose personal information to the following categories of recipients:

Affiliates and Related Entities

We may share information with our subsidiaries, affiliates, controlled entities, and related business operations where necessary for legitimate business purposes.

Service Providers

We may share information with third parties that provide services to us, including:

• hosting providers;
• cloud providers;
• information technology providers;
• cybersecurity providers;
• communications providers;
• document-management providers;
• payment providers;
• banking service providers;
• analytics providers;
• compliance providers;
• identity-verification providers;
• KYC/AML providers;
• accounting providers;
• administrative providers; and
• other operational service providers.

These providers may process personal information only as permitted by applicable law and contractual arrangements.

Professional Advisers

We may disclose information to:

• attorneys;
• accountants;
• auditors;
• tax advisers;
• consultants;
• insurers;
• investment advisers;
• financial advisers; and
• other professional advisers.

Financial and Transaction Counterparties

Where necessary for a transaction or business relationship, we may disclose information to:

• banks;
• payment institutions;
• payment processors;
• acquiring institutions;
• payment gateways;
• investors;
• lenders;
• borrowers;
• financing providers;
• counterparties;
• brokers;
• agents;
• investment firms; and
• other transaction participants.

Authorities

We may disclose information to:

• courts;
• regulators;
• law enforcement;
• tax authorities;
• governmental authorities;
• supervisory authorities; and
• other parties where disclosure is required or permitted by law.

Parties Designated by You

We may disclose information to third parties where you direct us to do so or provide appropriate authorization.

13. PROFESSIONAL ADVISERS AND FINANCIAL COUNTERPARTIES

Given the nature of our business, certain transactions require us to work with third-party professional and financial institutions.

Personal information may therefore be shared where reasonably necessary to:

• conduct due diligence;
• evaluate financing;
• evaluate investment opportunities;
• establish payment relationships;
• process transactions;
• obtain legal advice;
• obtain tax or accounting advice;
• conduct audits;
• assess risk;
• satisfy compliance obligations; or
• complete a transaction.

Where appropriate, contractual confidentiality and data-protection obligations will apply.

14. CORPORATE TRANSACTIONS

We may disclose personal information in connection with an actual or contemplated:

• merger;
• acquisition;
• financing;
• investment;
• restructuring;
• sale of assets;
• sale of equity interests;
• joint venture;
• corporate reorganization;
• bankruptcy;
• insolvency;
• receivership; or
• other corporate transaction.

This may include disclosure to prospective or actual counterparties, investors, lenders, advisers, auditors, legal counsel, insurers, and other transaction participants.

15. DATA RETENTION

We retain personal information for no longer than reasonably necessary for the purposes for which it was collected, taking into account:

• the nature of the information;
• the purpose of processing;
• the relevant business relationship;
• contractual requirements;
• accounting requirements;
• tax requirements;
• legal and regulatory obligations;
• dispute-resolution requirements;
• fraud-prevention requirements;
• compliance requirements; and
• applicable limitation periods.

Certain information may therefore be retained after a business relationship ends where required by law or reasonably necessary to establish, exercise, or defend legal claims.

When personal information is no longer required, we will take reasonable steps to securely delete, destroy, anonymize, or otherwise dispose of it in accordance with applicable requirements.

16. YOUR CHOICES

Depending on your jurisdiction and applicable law, you may have rights to:

• access personal information;
• correct inaccurate information;
• request deletion;
• request restriction of processing;
• object to certain processing;
• request data portability;
• withdraw consent where processing is based on consent;
• opt out of certain marketing communications; and
• exercise other rights provided by applicable privacy law.

We may need to verify your identity before fulfilling certain requests.

Certain legal exceptions may apply.

17. SECURITY

We maintain technical, organizational, and physical safeguards designed to protect personal information against:

• unauthorized access;
• unauthorized disclosure;
• alteration;
• loss;
• misuse;
• destruction; and
• other unlawful or unauthorized processing.

Security measures may include access controls, authentication procedures, encryption where appropriate, monitoring, logging, security policies, employee controls, vendor controls, and other administrative, technical, and physical safeguards.

No internet transmission, electronic storage system, or security measure can be guaranteed to be completely secure.

Accordingly, while we maintain safeguards designed to protect personal information, we cannot guarantee absolute security.

18. INTERNATIONAL DATA TRANSFERS

ANGULO & PARTNERS is based in the United States and may work with clients, counterparties, service providers, advisers, and other organizations located in different countries.

Accordingly, personal information may be transferred to, accessed from, or processed in countries other than the country in which it was originally collected.

Where personal information is transferred from the European Economic Area, United Kingdom, or another jurisdiction imposing transfer restrictions, we will use an appropriate lawful transfer mechanism where required, which may include:

• an adequacy decision;
• Standard Contractual Clauses;
• appropriate contractual safeguards;
• binding corporate rules where applicable;
• recognized certification mechanisms; or
• another lawful transfer mechanism permitted under applicable law.

EU data-protection rules continue to apply to protected personal data transferred outside the EEA, and the European Commission recognizes mechanisms including adequacy decisions and Standard Contractual Clauses for such transfers.

19. EUROPEAN ECONOMIC AREA, SWITZERLAND AND UNITED KINGDOM

This section applies to individuals located in the European Economic Area, Switzerland, or the United Kingdom to the extent applicable law applies to our processing of their personal information.

For purposes of applicable European data-protection legislation, ANGULO & PARTNERS may act as a data controller where we determine the purposes and means of processing personal information.

European data-protection law requires organizations to provide individuals with information concerning the controller, purposes of processing, categories of data, legal bases, retention periods, recipients, international transfers, and applicable rights.

Legal Bases

Depending on the circumstances, we may process personal information on the following legal bases:

Contractual Necessity

Where processing is necessary to:

• enter into a contract;
• perform a contract;
• administer a business relationship; or
• take steps requested by you before entering into a contract.

Legal Obligation

Where processing is necessary to comply with:

• applicable law;
• regulatory obligations;
• tax obligations;
• accounting requirements;
• court orders;
• governmental requests; or
• other legally binding requirements.

Legitimate Interests

We may process personal information where necessary for our legitimate interests, including:

• operating and managing our business;
• establishing business relationships;
• protecting our systems;
• preventing fraud;
• conducting compliance procedures;
• managing risk;
• enforcing agreements;
• defending legal claims;
• improving our Services; and
• developing our business.

We will consider whether our legitimate interests are overridden by the rights and freedoms of the relevant individual.

Consent

Where consent is required, we will request it before processing the relevant personal information.

You may withdraw consent at any time, although withdrawal does not affect processing already carried out lawfully before withdrawal.

European Data Protection Rights

Subject to applicable law and applicable exceptions, European individuals may have the right to:

• Access personal information we hold about them;
• Correct inaccurate or incomplete personal information;
• Delete personal information in certain circumstances;
• Restrict processing in certain circumstances;
• Object to processing based on legitimate interests or for direct marketing;
• Data portability where applicable;
• Withdraw consent where processing relies on consent; and
• receive information concerning the processing of their personal information.

These rights are recognized under the GDPR, subject to applicable limitations and exceptions.

Requests may be submitted using the contact information provided below.

We may request information necessary to verify your identity and authority to make a request.

You also have the right to lodge a complaint with the data-protection supervisory authority applicable to your jurisdiction.

20. CALIFORNIA RESIDENTS

This section applies to California residents to the extent ANGULO & PARTNERS is subject to the California Consumer Privacy Act, as amended, including applicable regulations.

California privacy law provides certain rights regarding personal information, including rights concerning access, deletion, correction, opt-out of sale or sharing, limitation of certain uses of sensitive personal information, and non-discrimination.

Categories of Personal Information

Depending on our relationship with you, we may collect categories including:

• identifiers;
• contact information;
• commercial information;
• internet or electronic network activity;
• geolocation information;
• professional or employment-related information;
• financial information;
• education information;
• inferences;
• government-issued identification information; and
• sensitive personal information where reasonably necessary and legally permitted.

We do not necessarily collect every category from every individual.

Sources

We may collect information from:

• you;
• your company;
• business partners;
• financial institutions;
• service providers;
• public records;
• government authorities;
• compliance providers;
• identity-verification providers;
• KYC/AML providers;
• analytics providers;
• professional advisers; and
• other lawful sources.

Business Purposes

We may use California personal information for purposes including:

• providing Services;
• processing transactions;
• customer service;
• maintaining accounts and relationships;
• security;
• fraud prevention;
• compliance;
• auditing;
• debugging;
• research;
• service improvement;
• business administration;
• financing activities;
• investment activities;
• legal and regulatory compliance; and
• other purposes disclosed in this Privacy Notice.

Sale and Sharing

We do not sell personal information for monetary compensation in the ordinary meaning of that term.

We may, however, engage third parties in ways that could be characterized as a “sale” or “sharing” under California law depending on the specific technology, service, or relationship involved.

Where applicable, California residents may have the right to opt out of sale or sharing.

If required, we will provide the appropriate California privacy choice mechanism.

California Rights

Subject to applicable exceptions, California residents may have the right to:

• know what personal information we collect;
• request access to personal information;
• request deletion;
• request correction;
• opt out of sale or sharing;
• limit certain uses or disclosures of sensitive personal information;
• receive equal treatment for exercising privacy rights; and
• exercise other rights provided under California law.

California law requires covered businesses to provide appropriate methods for submitting privacy requests and, in applicable circumstances, to recognize qualifying opt-out preference signals such as Global Privacy Control.

We will verify requests as required by applicable law.

We will not discriminate against you for exercising rights provided by applicable California privacy law.

21. OTHER U.S. STATE PRIVACY RIGHTS

Other U.S. states have enacted comprehensive privacy legislation that may provide residents with rights concerning personal information.

Where applicable to ANGULO & PARTNERS, we will comply with the privacy requirements applicable to residents of those jurisdictions.

Depending on the applicable law, such rights may include:

• access;
• correction;
• deletion;
• portability;
• objection;
• restriction;
• opt-out rights;
• rights relating to profiling or automated decision-making; and
• rights relating to sensitive personal information.

The availability and scope of these rights depend on the applicable state law, the nature of the information, and the applicable statutory exemptions.

22. CHILDREN

Our Services are not directed toward children under the age of 18.

We do not knowingly collect personal information from children through our Services where prohibited by law.

If we become aware that we have collected personal information from a child in circumstances requiring deletion or parental consent, we will take appropriate steps consistent with applicable law.

23. THIRD-PARTY WEBSITES AND SERVICES

Our Services may contain links to third-party websites, applications, platforms, or services.

These third-party services operate independently from ANGULO & PARTNERS.

We are not responsible for the privacy practices, security practices, content, or policies of third parties that we do not control.

You should review the privacy notice of any third-party website or service before providing personal information.

24. JOB APPLICANTS AND PERSONNEL

If you apply for employment, consulting work, an internship, or another position with ANGULO & PARTNERS, we may process information necessary to:

• evaluate your application;
• verify qualifications;
• conduct interviews;
• contact references;
• conduct lawful background checks;
• assess eligibility;
• communicate with you;
• administer the recruitment process; and
• comply with applicable employment laws.

Additional privacy information may be provided during the recruitment process where appropriate.

For current personnel, we may process information necessary to administer the employment or contractual relationship, compensation, benefits, performance, security, compliance, tax, and other employment-related matters.

25. DATA BREACH AND SECURITY INCIDENTS

If we become aware of a security incident involving personal information, we will investigate the incident and take reasonable measures to contain, remediate, and prevent recurrence.

Where notification is required by applicable law, we will notify affected individuals, regulators, law enforcement authorities, or other relevant parties within the timeframe and manner required by applicable law.

26. CHANGES TO THIS PRIVACY NOTICE

We may update this Online Privacy Notice from time to time to reflect:

• changes to our business;
• changes to our Services;
• changes to technology;
• changes to legal or regulatory requirements;
• changes to privacy practices; or
• other developments.

When we make material changes, we may update the “Last Updated” date and provide additional notice where required.

The updated Privacy Notice will become effective when posted unless otherwise stated.

Your continued interaction with our Services after the effective date of an updated Privacy Notice will be subject to the updated notice to the extent permitted by law.

27. HOW TO CONTACT US

If you have questions regarding this Online Privacy Notice, our privacy practices, or wish to exercise an applicable privacy right, please contact us:

ANGULO & PARTNERS INTERNATIONAL LLC
1 Maiden Lane, 5th Floor
New York, NY 10038
United States

Privacy Contact: info@anguloholdings.com

For privacy requests, please include:

• your full name;
• contact information;
• the nature of your request;
• the jurisdiction in which you reside; and
• sufficient information for us to verify your identity where required.

We will process privacy requests in accordance with applicable law.