Privacy Policy
Last updated: June 2026
Your privacy is important to Elda River Capital, LLC and our affiliates (collectively, “we”, “us”, “our” or “Elda River”). In certain circumstances we must collect, maintain, and process certain personal information or personal data about you, otherwise we may be unable to provide you with our products and services as well as the full functionality of the website. Please note that “personal information” and “personal data” as used in this website privacy notice (the “Privacy Notice”) shall have the meaning given to such terms (or the equivalent term) under applicable data protection laws. We use these terms interchangeably in this Privacy Notice for simplicity.
To better protect your privacy, we are providing information explaining our data handling practices. As further described in the section below titled “Categories of Personal Information We Collect and Process and How We Collect It”, this Privacy Notice describes how we gather and use personal information that we collect:
- on or through www.eldariver.com and as applicable, our other websites and digital platforms (including, as applicable, any of our portals and data rooms) (collectively the “website”);
- when you opt to receive communications from us including when you communicate with us offline and online (including via phone, email correspondence or “Get in touch”, “Contact us” or similar links);
- from and about representatives of, or individuals in connection with, our actual or prospective vendors, business partners or portfolio companies;
- to conduct business with you;
- about visitors to our premises and attendants of events or meetings we may arrange;
- when you apply for a job with us; and
- through other data collection points where we refer to this Privacy Notice.
Please read this Privacy Notice carefully and prior to using the website and providing any personal information.
This Privacy Notice does not apply to any processing of personal information by or on behalf of Elda River that is covered by a more specific privacy notice (including privacy notices issued in connection with any investments with us or our funds), and this Privacy Notice does not apply to any other websites that may be linked to it. We do not control the privacy notices or practices of other persons or entities, and we encourage you to read the privacy notices applicable to other websites before you disclose any personal information to them.
Jurisdiction-specific Information
This Privacy Notice is supplemented by the Privacy Notice and EU & UK Privacy Notice. In addition to reading this Privacy Notice, if you are:
- located in the European Economic Area (“EEA”), European Union (“EU”) or United Kingdom (“UK”), or the processing of your personal data would otherwise be subject to EU & UK Data Protection Laws (as defined below in the EU & UK Privacy Notice), please also read our EU & UK Privacy Notice.
Categories of Personal Information We Collect and Process and How We Collect It
The personal information we collect and process about you depends on the nature of our interaction with you and may include, but is not limited to, the following:
- Basic personal details and identifiers: such as name, personal/work email address(es) and postal address(es), title, prefix, age, job title, and personal/work telephone number(s);
- Internet or other electronic network activity information: such as information regarding your computer / device and IP address, content, traffic data, use of our website and geolocation data. We obtain some information about your IP address and web browser that you use to access the website;
- Information received through communications with us: such as information provided through telephone calls (which may be recorded for compliance purposes), video communications and other verbal communications and written correspondence;
- Marketing and communications information collected about you or that you provide to us: your preferences in receiving marketing information from us and/or our third parties, and/or your communication preferences; and
- Job applicant information: such as information that you may provide to us in connection with a job application, including CV information, education and job history, and identification documentation.
- Other information: such as information obtained through publicly available external websites in certain circumstances.
Information you provide to us
We collect your personal information when you decide to interact with us (e.g., via any contact/communication feature we utilize on the website, when you visit our offices, when you communicate with us over email or the telephone, when you apply for a job with us, etc.).
We may also collect personal information about you, such as your IP address, through automated technology when you access and use our website, such as cookies and similar technology (please see the “Cookies” section below for information about how we use such technologies).
Information provided by third parties or publicly available sources
We collect personal information from third parties, such as a resumé or CV sent to us by a recruiting firm, background information from a background check provider, personal information we viewed on social media (e.g., LinkedIn) or information obtained from publicly available lists of individuals subject to sanctions or trade restrictions.
If you represent one of our vendors, business partners or portfolio companies, we may also collect your personal information from the entity that you work for where this is necessary to receive products or services from, or otherwise conduct business with, such third party.
We process information in relation to companies that we are evaluating in connection with a corporate transaction or potential investment. This information may include your personal information including name, title, email address, postal address, job title, telephone number, passport or other government-issued identification, financial information and/or job and benefits information, as appropriate.
We do not knowingly collect personal information from children under the age of 18. If we are made aware that we have collected personal information from a child under the age of 18, we will delete it as soon as practicable.
Purposes for Collecting Personal Information
We may collect or disclose the personal information we collect about you for one or more of the following purposes:
| Purpose | Legal Basis to Process personal data |
| To conduct business with you or to provide you with the services or products you have requested, including responding to your enquiries and requests and providing you with support | Contractual necessity; and/or our legitimate interest in operating our business and providing investment services |
| To keep a record of and manage your relationship with us | Our legitimate interest in operating our business and providing investment services; and/or consent |
| To communicate with you, to operate, schedule and facilitate meetings and in relation to your participation in any of our events | Our legitimate interest in operating our business and providing investment services; and/or consent |
| To verify your identity (including to conduct anti-money laundering or KYC checks and to enable you to access our offices) and to conduct conflicts checks | Our legitimate interest in operating our business and providing investment services; contractual necessity; legal requirement; and/or consent |
| To conduct due diligence and other business activities in connection with an actual or prospective corporate transaction or investment which we are party to | Our legitimate interest in operating our business; contractual necessity; and/or legal requirement |
| To protect against, identify and prevent, fraud, money-laundering, cyber-attacks, theft of our property, other threats to the safety, security and integrity of our website, assets our business, and other malicious or unlawful activity | Our legitimate interest in operating our business, website and services; and/or legal requirement |
| To monitor and manage our portfolio companies | Our legitimate interest in operating our business; and/or contractual necessity |
| Litigation management and conducting internal audits and investigations | Our legitimate interest in operating our business; and/or legal requirement |
| To process and administer details associated with you, and to offer and improve our services. | Our legitimate interest in operating our business; and/or legal requirement. |
| Recording or monitoring telephone calls or other communications with you in order to comply with our legal obligations, rules and practices, and corporate governance practices, and to protect our respective businesses and the security of our systems | Legal requirement; our legitimate interest in operating our business; and/or consent |
| To obtain advice from our professional advisors, including lawyers and accountants | Our legitimate interest in operating our business |
| To conduct due diligence and other business activities in connection with an actual or prospective corporate transaction or investment which we are party to | Our legitimate interest in operating our business and providing investment services; contractual necessity; and/or legal requirement |
| To administer and protect our business and our website | Our legitimate interest in operating our business |
| To make suggestions and recommendations to you (including to provide you with updates or other information) about our business and services that may be of interest to you, including in relation to services that are similar to those services we currently provide, or previously provided, to you | Consent or our legitimate interest in operating our business where we have an existing relationship with you |
| For statistical analysis and market research, including to understand how our service may be improved for you (including through our use of cookies), and to improve our services | Our legitimate interest in operating our business |
| For performance of our IT systems | Our legitimate interest in operating our business |
| For any other purpose that has been notified, or has been agreed, in writing | As identified in the relevant notice or where consent has been given to the processing of their personal information for the specific purpose. |
Where required by applicable law, we will obtain your consent to send you marketing communications about our products, services, offers and promotions, and to invite you to events and to participate in surveys. You may request that we stop sending you marketing communications by emailing InvestorRelations@eldariver.com at any time.
Disclosure of Personal Information
Unfortunately, the transmission of information and data via the internet is not completely secure. Although we try to protect your personal information, we cannot guarantee the security of any information or data transmitted to or through the website and any transmission of information or data by you or on your behalf to or through the website is at your sole risk.
We may disclose any of the categories of personal information we obtain about you as described in the “Categories of Personal Information We Collect and Process and How We Collect It” section above amongst Elda River and to service providers and persons employed and/or retained by Elda River to fulfil the purposes set out in this Privacy Notice. We use a number of service providers to perform certain services including legal and financial professional advisors, our auditors, recruitment firms, consultants, IT and data security providers, data hosting providers and in some instances, placements agents, administration agents, depositories, investment managers and other fund administrators.
We may also disclose personal information: (1) if we are required or permitted to do so by law or legal process (such as a court order or subpoena); (2) in response to requests by government or regulatory agencies, such as law enforcement, tax, and data protection supervisory authorities; (3) to establish, exercise or defend legal rights; (4) when we believe disclosure is necessary or appropriate to prevent physical or other harm or financial loss; (5) in connection with an investigation of suspected or actual illegal activity; or (6) otherwise with your consent.
We do not sell any of the personal information we collect about you to third parties. However, we reserve the right to transfer any personal information we have about you in the event of an actual or proposed sale or transfer of all or a portion of our business or assets (including in the event of a merger, acquisition, joint venture, reorganization, divestiture, dissolution, or liquidation).
The website may contain links to other websites which are not hosted, affiliated or operated by us. These websites may use automated means to collect information regarding your use of the websites. Your use of such websites is subject to the privacy policies or notices of the provider’s website.
Retention of Personal Information
We retain your personal information for as long as reasonably necessary and proportionate to achieve the purposes and uses set out in this Privacy Notice or as long as is required by our regulatory obligations, or where we believe it is necessary to establish, defend or protect our legal rights and interests or those of others.
How We Protect Your Personal Information
We maintain physical, electronic, and procedural safeguards to prevent unauthorized access to data and to protect the integrity of our systems. We take reasonable steps to protect any personal information that you provide us online by employing appropriate technical and organizational measures. We permit access only by authorized persons who need access to that information to provide services to us and you and who are required to abide by applicable confidentiality and information security practices. Despite the security procedures we employ, you should be aware that it is impossible to guarantee the security of information that you transmit to us via the internet.
Marketing
We may use your personal information to keep you informed of our products and services, if you have provided your consent to us doing so, or where we have an existing relationship with you and we wish to contact you about products and services similar to those which we have provided to you, on the basis of our legitimate interest in operating our business. You may opt-in to certain kinds of marketing, or all forms of marketing, at any time, by contacting us and you may unsubscribe to receiving emails by clicking on the “opt-out” or “unsubscribe” link provided in all our marketing emails, at any time.
Cookies
Information regarding how you access the website (e.g., browser type, access times, and Internet Protocol (IP) address) and your hardware and software is automatically collected through the use of cookies (a small text file placed on your hard drive) or other technologies or tools. This information is used to improve website performance and for our business or commercial purposes. Where cookies are not necessary for us to provide the products or services you have requested or for the functioning of the website, we will ask you to consent to their use. You may opt-in to accept cookies automatically by changing the settings on your browser. If you opt-out of certain cookies, you may not be able to access certain parts of the website.
Subject to your consent, the website will place the cookies listed below:
| Cookie | Type / Purpose | Duration | More Information |
| _pk_id.<appID>.<domainHash> | First-party cookie. Used to recognize visitors and hold their various properties. | Cookie expires after 13 months or 30 minutes for anonymous visitors if the 30-minute cookie option is turned on. | Cookie stores the following information: cookieID; cookieCreationTimestamp; visitsCount; currentVisitTimestamp;lastVisitTimestamp; lastEcommerceOrderTimestamp |
| _pk_ses.<appID>.<domainHash> | First party cookie that shows the visitor’s active session. | Cookie expires 30 minutes after the visitor’s last event. | |
| ppms_privacy_<appID> | First party cookie that stores the visitor’s consent to data collection and usage. | Cookie expires after 12 months. | |
| stg_traffic_source_priority | First party cookie that stores the type of traffic source from which the visitor came to the site. | Cookie expires after 30 minutes. | |
| stg_last_interaction | First-party cookie that indicates whether the last visitor’s session is still running or a new session has started. | Cookie expires after 365 days. | |
| stg_returning_visitor | First-party cookie that indicates whether a visitor has been to site before. | Cookie expires after 365 days. | |
| stg_fired__<conditionID> | First-party cookie that indicates whether the tag and trigger combination was fired during the current visitor session. | Cookie expires after the session ends (fixed idle time or after a browser is closed). | |
| stg_utm_campaign | First-party cookie that stores the name of the campaign that directed visitor to site. | Cookie expires after the session ends (fixed idle time or after a browser is closed). | |
| stg_pk_campaign | First-party cookie that stores the name of the campaign that directed visitor to site. | Cookie expires after the session ends (fixed idle time or after a browser is closed). | |
| stg_externalReferrer | First-party cookie that stores the URL of the site that referred the visitor to site. | Cookie expires after the session ends (fixed idle time or after a browser is closed). | |
| _stg_optout | First-party cookie that helps to turn off all tracking tags on site. | Cookie expires after 365 days. | |
| _pk_cvar.<appID>.<domainHash> (deprecated) | First-party cookie that stores a custom variable that is part of the visit scope. | Cookie expires 30 minutes after visitor’s last event. | |
| _ga | Used to distinguish users. | Cookie expires after 2 years. | Google Analytics. |
| _ga_<container-id> | Used to persist session state. | Cookie expires after 2 years. | Google Analytics. |
| bcookie | Browser Identifier cookie to uniquely indentify devices accessing LinkedIn to detect abust on the platform and diagnostic purposes. | Cookie expires after 1 year. | Provided by LinkedIn and domain is: .linkedin.com |
| bscookie | Used for remembering that a logged in user is verified by two factor authentication and has previously logged in. | Cookie expires after 1 year. | Provided by LinkedIn and domain is: .www.linkedin.com |
| JSESSIONID | Used for Cross Site Request Forgery (CSRF) protection and URL signature validation. | Cookie expires after session. | Provided by LinkedIn and domain is: .www.linkedin.com |
| lang | Used to remember a user’s language setting to ensure LinkedIn.com displays in the language selected by the user in their settings | Cookie expires after session. | Provided by LinkedIn and domain is: .linkedin.com |
| lidc | Used to facilitate data center selection. | Cookie expires after 24 hours. | Provided by LinkedIn and domain is: .linkedin.com |
| sdsc | Signed data service context cookie used for database routing to ensure consistency across all databases when a change is made. Used to ensure that user-inputted content is immediately available to the submitting user upon submission. | Cookie expires after session. | Provided by LinkedIn and domain is: .linkedin.com |
| li_gc | Used to store consent of guests regarding the use of cookies for non-essential purposes. | Cookie expires after 6 months. | Provided by LinkedIn and domain is: .linkedin.com |
| li_mc | Used as a temporary cache to avoid database lookups for a member’s consent for use of non-essential cookies and used for having consent information on the client side to enforce consent on the client side | Cookie expires after 6 months. | Provided by LinkedIn and domain is: .linkedin.com |
| UID | Cookie used for market and user research | Cookie expires after 720 days. | Provided by Scorecard research and domain is: scorecardresearch.com |
| UserMatchHistory | LinkedIn Ads ID syncing | Cookie expires after 30 days. | Provided by LinkedIn and domain is: .linkedin.com |
| AnalyticsSyncHistory | Used to store information about the time a sync took place with the lms_analytics cookie | Cookie expires after 30 days. | Provided by LinkedIn and domain is: .linkedin.com |
| lms_ads | Used to identify LinkedIn Members off LinkedIn for advertising | Cookie expires after 30 days. | Provided by LinkedIn and domain is: .linkedin.com |
| lms_analytics | Used to identify LinkedIn Members off LinkedIn for analytics | Cookie expires after 30 days. | Provided by LinkedIn and domain is: .linkedin.com |
| li_fat_id | Member indirect identifier for Members for conversion tracking, retargeting, analytics | Cookie expires after 30 days. | Provided by LinkedIn |
| li_sugr | Used to make a probabilistic match of a user’s identity outside the Designated Countries | Cookie expires after 90 days. | Provided by LinkedIn and domain is: .linkedin.com |
| _guid | Used to identify a LinkedIn Member for advertising through Google Ads | Cookie expires after 90 days. | Provided by LinkedIn and domain is: .linkedin.com |
| BizographicsOptOut | Used to determine opt-out status for non-members | Cookie expires after 10 years. | Provided by LinkedIn and domain is: .linkedin.com |
| li_giant | Indirect indentifier for groups of LinkedIn Members used for conversion tracking | Cookie expires after 7 days. | Provided by LinkedIn |
| oribi_cookie_test | To determine if tracking can be enabled on current domain | Cookie expires after session. | Provided by Oribi. |
| oribili_user_guid | Used to count unique visitors to a website | Cookie expires after 1 year. | Provided by Oribi. |
| ln_or | Used to determine if Oribi analytics can be carried out on a specific domain | Cookie expires after 1 day. | Provided by Oribi. |
You may wish to visit www.aboutcookies.org, which contains comprehensive information about types of cookies, how they are used, and how you manage your cookie preferences.
Further Information
Elda River reserves the right to update this Privacy Notice at any time. In the event that we do so, we will make an updated version of this Privacy Notice available to you via the website. The examples contained within this Privacy Notice are illustrations only and are not intended to be exhaustive. This Privacy Notice complies with the privacy provisions of Regulation S-P under the Gramm-Leach-Bliley Act and certain privacy provisions of other laws. You may have additional rights under other foreign or domestic laws that apply to you.
Contact Us
If you have questions about this Privacy Notice, wish to contact Elda River, wish to exercise opt-out rights or submit verified requests, wish to appeal decisions, or wish to make any changes to the personal information you have provided to us, including removing it from a particular subscription list or removing it from our databases, please contact us at 346-614-4250 or InvestorRelations@eldariver.com.
Please note that, unless expressly advised otherwise, our website and communication facilities do not provide a means for completely secure and private communications and use. Although we will attempt to keep personal information confidential, from a technical standpoint, there is still a risk. For that reason, use caution when using the website, e-mail and other communication methods to communicate information to Elda River that is considered to be confidential.
Our goal is to respond to any verifiable consumer request within the timeframes mandated applicable law, and we will notify you in writing if we cannot meet any such timelines.
No Discrimination: We will not discriminate against you for exercising your rights under the applicable privacy regulations in your jurisdiction.
EU & UK Privacy Notice
Applicability
This EU & UK Privacy Notice supplements the information contained in the Privacy Notice above and applies solely to the processing of personal data which is subject to EU & UK Data Protection Laws.
For the purposes of this EU & UK Privacy Notice, the “EU & UK Data Protection Laws” mean all applicable laws and regulations relating to privacy, protection or processing of personal data in the EEA, EU, Switzerland and UK, including (without limitation): the General Data Protection Regulation (Regulation (EU) 2016/679) (“EU GDPR”), the EU GDPR as it forms part of the laws of England and Wales, Scotland and Northern Ireland by virtue of section 3 of the European Union Withdrawal Act 2018 (“UK GDPR”), the Federal Act on Data Protection of 25 September 2020 and its ordinances; and including in respect of the foregoing any implementing or successor legislation and any amendments or re-enactments. The terms “controller”, “data subject”, “personal data”, “process” and “processing” or other applicable or analogous terms shall be interpreted in accordance with the applicable EU & UK Data Protection Laws.
Information required to be disclosed under EU & UK Data Protection Laws regarding the collection of your personal data that is not set forth in this EU & UK Privacy Notice is otherwise set forth in the general Privacy Notice above. To the extent there is any conflict in respect of any processing subject to EU & UK Data Protection Laws between the general Privacy Notice and this EU & UK Privacy Notice, this EU & UK Privacy Notice shall apply.
You do not need to take any action as a result of this EU & UK Privacy Notice, but you may have certain rights as described below in the section headed “Your Rights”. Please read this EU & UK Privacy Notice carefully.
If you have any questions regarding our use of your personal data, or this EEA-UK Privacy Policy, please contact InvestorRelations@eldariver.com.
The Controller
To the extent that EU & UK Data Protection Laws apply to our processing of your personal data, Elda River (as defined in the Privacy Notice above) is a “controller” of your personal data. In simple terms, this means we: (i) “control” the personal data that we collect from you or other sources; and (ii) make certain decisions on how to use and protect such personal data.
What type of personal data do we collect and how do we collect it?
The types of personal data that we collect, and how we collect it, are set forth in the “Categories of Personal Information We Collect and Process and How We Collect It” section of the Privacy Notice.
Please note that we do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data), or information about criminal convictions and offences, although there may be limited circumstances where we need to collect this type of personal data (e.g. as part of our legal obligations, in performance of a contract or as may be disclosed in our legitimate interest as part of a job application).
Purposes and Legal Bases for Collecting and Using Personal Data
We rely on various legal bases under the EU & UK Privacy Laws in order to process your personal data for various purposes, details of which are set forth in the “Purposes for Collecting Personal Information” section of the Privacy Notice.
We may process your personal data on more than one legal basis depending on the specific purpose for which we are using your personal data. These purposes are also set out in the “Purposes for Collecting Personal Information” section of the Privacy Notice, which in general are to operate our business, conduct business with you and perform essential or legitimate business operations.
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so.
No solely automated decision making, including profiling, is used when processing your personal data.
Disclosure of Personal Data
Elda River may disclose and transfer your personal data to third parties as set forth in the “Disclosure of Personal Information” section of the Privacy Notice above, which may involve the transfer of your personal data outside of the EEA, EU, Switzerland or UK, including to the United States or other Non-Equivalent Countries (as defined below). Elda River will only transfer your personal data in accordance with applicable EU & UK Data Protection Laws and in order to fulfill the purposes described in the Privacy Notice. For information on the safeguards applied to such transfers, please contact us at InvestorRelations@eldariver.com.
For the purposes of this Privacy Notice, “Non-Equivalent Country” means a country or territory other than (i) a member state of the EEA or EU; (ii) the United Kingdom; (iii) Switzerland; or (iv) a country or territory which has at the relevant time been decided by the European Commission, the Government of the United Kingdom or the Swiss Federal Data Protection Commission (as applicable) in accordance with the applicable EU & UK Data Protection Laws to ensure an adequate level of protection for personal data.
Retention and Security
Information about the security we use to protection your personal data, and the how long we retain your personal data, is included in the sections of the general Privacy Notice headed “Retention of Personal Information” and “How do we Protect Your Personal Information”.
Data Subject Rights To the extent set forth in EU & UK Data Protection Laws, you may have certain rights relating to the collection and use of your personal data, including, as applicable, the right to: (i) request a copy of the personal data retained by Elda River (ii) to correct any inaccurate information contained within the personal data retained by Elda River; (iii) delete any personal data retained by Elda River; (iv) restrict the processing of personal data retained by Elda River, including the purposes for which personal data is processed by or on behalf of Elda River; (v) object to the processing of personal data undertaken by Elda River when the processing is based on the legitimate interest basis or for direct marketing purposes; (vi) direct the transfer of your personal data to a third party designated by you; (vii) withdraw your consent to our processing of your personal data at any time (which will not affect the lawfulness of processing before such withdrawal request); and (viii) not be subject to solely automated decision making which produces legal effects concerning you or similarly affects you. If you are located in the UK, EU, EEA or Switzerland, you may also “opt out” or unsubscribe from any marketing communications from Elda River.
An individual may contact Elda River’s at InvestorRelations@eldariver.com if they wish to exercise any of the rights set forth herein. Furthermore, you have a right to lodge a complaint with the local supervisory authority (i.e., a full list of EU data protection supervisory authorities is available here: https://edpb.europa.eu/about-edpb/about-edpb/members_en. In the UK, this is the Information Commissioner’s Office – https://ico.org.uk/global/contact-us). These rights are not absolute and in certain circumstances their exercise may not be possible including when personal data must be maintained to comply with applicable laws.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
To the extent EU & UK Data Protection Laws apply, should you have any questions or wish to contact us in relation to this EU & UK Privacy Notice and the Privacy Notice, please contact us at InvestorRelations@eldariver.com.