Privacy Policy

Affluent Ventures LLC (trading as 029 Capital)
victor@029cap.com | 029cap.com/privacy
Last updated: July 2026

1. Introduction
This Privacy Policy explains how Affluent Ventures LLC, a Delaware limited liability company operating under the trade name "029 Capital" (registered address: 111B S Governors Ave STE 28959, Dover, Delaware 19904, United States; "we," "us," or "our") collects, uses, and protects personal data in connection with your use of www.029cap.com (the "Website") and any related services ("Services").

We are committed to protecting your privacy and handling your personal data in accordance with Regulation (EU) 2016/679 ("GDPR"), the California Consumer Privacy Act ("CCPA") where applicable, and other applicable data protection laws. By accessing or using the Website, you acknowledge that you have read and understood this Privacy Policy. This Privacy Policy should be read together with any other privacy notice we may provide on specific occasions.

2. Definitions
Personal Data: any information relating to an identified or identifiable individual, whether directly or indirectly, through an identifier such as a name, email address, IP address, or one or more factors specific to that person.

Process / Processing: any operation performed on Personal Data, whether automated or not, including collecting, recording, organizing, storing, using, disclosing, or deleting such data.

Any capitalized terms not defined in this policy carry the meaning given to them in our Terms of Service.

3. Data Controller
Affluent Ventures LLC (029 Capital)
111B S Governors Ave STE 28959
Dover, Delaware 19904, United States
victor@029cap.com

We currently assess whether the appointment of an EU representative is required under Article 27 GDPR given the nature and scope of our processing activities.

4. Data We Collect

4.1 Data collected automatically
When you visit the Website, our hosting provider automatically collects certain technical information (Technical Data) including your IP address (pseudonymized where applicable), browser type and version, operating system, referring URL, pages visited, time and date of access, and session duration. This data is processed solely for the purpose of ensuring the technical operation and security of the Website.

4.2 Data you provide voluntarily
If you contact us by email or through any other channel, we process the data you provide (Identity and Contact Data) including your name, email address, company, and the content of your message, for the purpose of responding to your inquiry.

4.3 Marketing and Communications Data
If you engage with our outbound communications (email, and where applicable SMS), we process your contact details, your engagement and response history, and your communication preferences, including opt-in and opt-out status, for the purpose of managing our outreach and complying with anti-spam and consent requirements. Where SMS communications are used, we additionally record your phone number, opt-in status, and the date and time of consent, solely to deliver those communications and maintain compliance records. This data is not shared with third parties for their own marketing purposes.

4.4 Data collected through tracking and analytics tools
Subject to your prior explicit consent, we use the third-party tools described in Section 8 below. No analytics or marketing cookies or tracking scripts are loaded or activated prior to consent. Consent is obtained separately for different categories of cookies. We document and store user consent in accordance with applicable legal requirements.

We may also process aggregated, anonymized statistical data derived from the above, which does not, in itself, identify you and is not considered Personal Data.

5. Purpose and Legal Basis for Processing

5.1 Operation and security of the Website: legitimate interests, Article 6(1)(f) GDPR.
5.2 Responding to inquiries: legitimate interests, Article 6(1)(f) GDPR, or performance of pre-contractual measures, Article 6(1)(b) GDPR where applicable.
5.3 Outbound marketing communications (email/SMS): legitimate interests or consent, Article 6(1)(a)/(f) GDPR, depending on jurisdiction and channel; you may opt out at any time (see Section 12).
5.4 Website analytics and marketing tracking: your explicit consent, Article 6(1)(a) GDPR, obtained via our cookie banner prior to loading any analytics or marketing tools.
5.5 Compliance with legal obligations: Article 6(1)(c) GDPR.

6. Cookies and Consent
We use cookies in connection with the third-party tools described in Section 8. Before any analytics or marketing cookies or tracking scripts are activated, we request your explicit consent through a cookie banner. No tracking tools are loaded prior to consent.

Consent is obtained separately for different categories of cookies (analytics, marketing). It is as easy to withdraw consent as it is to give it, via the cookie settings tool available on the Website. Withdrawal does not affect the lawfulness of processing prior to withdrawal.

Strictly necessary cookies required for the technical operation, security, and session management of the Website may be set without consent on the basis of our legitimate interests.

We do not carry out automated decision making or profiling with legal or similarly significant effects within the meaning of Article 22 GDPR.

Do Not Track Signals: there is currently no widely accepted standard for browser initiated Do Not Track signals, and we do not currently recognize or respond to them.

7. Data Retention
We retain personal data only as long as necessary for the purposes described in this Policy:

Server log data: deleted after 30 days.
Google Analytics data: deleted after 14 months as configured.
Microsoft Clarity data: retained up to 13 months as configured.
LinkedIn Insight Tag data: retention governed by the platform once transmitted, we have no control over it.
Contact inquiry data: retained only as long as necessary to handle the inquiry, then deleted, unless a longer period is required by law.
Marketing/outreach contact and consent data: retained for as long as the contact remains in active outreach, or until you opt out, whichever is earlier.

Where data has been anonymized such that it can no longer be associated with you, we may retain and use it indefinitely for statistical purposes without further notice.

8. Third-Party Services

8.1 Hosting Provider. EU based hosting provider acting as processor. Article 28 GDPR data processing agreement in place.
8.2 Google Analytics. Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Configured with IP anonymization where supported, no data sharing with Google, no User ID tracking. Transfers to the US on the basis of Standard Contractual Clauses. Opt out: https://tools.google.com/dlpage/gaoptout. Privacy Policy: https://policies.google.com/privacy
8.3 Google Tag Manager. Google Ireland Limited. Technical container only, does not independently set cookies or process personal data.
8.4 Microsoft Clarity. Microsoft Corporation, One Microsoft Way, Redmond, WA 98052, USA. Records pseudonymized session behavior after consent. Transfers on the basis of Standard Contractual Clauses. Privacy Policy: https://privacy.microsoft.com/privacystatement
8.5 LinkedIn Insight Tag. LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland. Used for conversion tracking and retargeting after consent. Joint controller arrangement under Article 26 GDPR applies to relevant processing. Privacy Policy: https://www.linkedin.com/legal/privacy-policy
8.6 Digital marketing and outreach service providers. We may engage third party service providers (email/SMS delivery platforms, CRM, e-signature and proposal tools) to carry out marketing, outreach, and client onboarding activity on our behalf. These providers process data only under our instructions and applicable data processing agreements.

9. Disclosure of Your Personal Data
Beyond the third-party tools listed above, we may disclose your Personal Data to:

Service providers, contractors, and agents performing services on our behalf (payment and proposal processing, hosting, customer support, analytics).
Professional advisers, including lawyers, accountants, and auditors.
Regulators and other authorities, where required by law.
A successor entity, in the event of a merger, acquisition, financing, or sale of some or all of our business assets. Your Personal Data may be among the transferred assets, subject to the same protections described here.
Third parties with your consent, where you agree to disclosure outside the scope of this Policy.

We do not sell Personal Data to third parties for their own independent marketing purposes.

10. International Data Transfers
Affluent Ventures LLC is based in the United States. If you access the Website from the European Economic Area or United Kingdom, your Personal Data may be transferred to and processed in the United States or other countries that do not provide an equivalent level of data protection.

We rely on Standard Contractual Clauses adopted by the European Commission pursuant to Article 46(2)(c) GDPR, or other appropriate safeguards, for such transfers, and assess whether additional safeguards are required on a case by case basis following applicable Schrems II guidance. You may request a copy of applicable safeguards by contacting us.

11. Your Rights

If you are located in the European Economic Area or United Kingdom, you have the following rights:

Right of access (Article 15 GDPR)
Right to rectification (Article 16 GDPR)
Right to erasure (Article 17 GDPR)
Right to restriction of processing (Article 18 GDPR)
Right to data portability (Article 20 GDPR)
Right to object, in particular to direct marketing or analytics processing (Article 21 GDPR)
Right to withdraw consent at any time, without affecting prior lawful processing
Right to lodge a complaint with your competent supervisory authority

If you are a California resident, you additionally have rights under the CCPA, including:

Right to know what Personal Data we hold about you and to access a copy
Right to request deletion of Personal Data we have collected about you
Right to opt out of the "sale" or "sharing" of Personal Data, as those terms are defined under the CCPA (we do not sell Personal Data in the traditional sense, but certain cookies may make non identifiable information available to third parties, you may opt out via your browser or cookie settings)
Right to non-discrimination for exercising any of these rights

To exercise any of the above rights, contact  victor@029cap.com. We will respond within 30 days (or as required under CCPA timelines). We may request identity verification before processing your request, and may charge a reasonable fee if a request is manifestly unfounded, repetitive, or excessive. You may designate an authorized agent to submit a request on your behalf.

12. Marketing Communications
Where permitted, we may use your contact data to inform you about our services, including by email or, where applicable, SMS. You may opt out of marketing communications at any time via the unsubscribe link included in our emails, by replying STOP for SMS, or by contacting us directly. Opting out of marketing communications does not affect transactional or service related communications necessary to respond to an inquiry you have initiated.

13. Children
This Website is not directed at persons under the age of 18. We do not knowingly process data of individuals under 18 and do not target such individuals. If you believe we have inadvertently collected such data, please contact us and we will delete it promptly.

14. Security
We implement appropriate technical and organizational measures to protect Personal Data against unauthorized access, accidental loss, destruction, or disclosure, including encryption, access controls, and data minimization. No transmission over the internet is entirely secure, and we cannot guarantee absolute security.

15. Third-Party Websites
This Website may contain links to third party websites. We are not responsible for the privacy practices of those websites and encourage you to review their respective privacy policies.

16. Changes to This Policy
We may update this Privacy Policy from time to time. Any changes will be published on this page with a revised "last updated" date. Continued use of the Website following any update constitutes acceptance of the revised Policy.

17. Contact
Affluent Ventures LLC (029 Capital)
contact@029cap.com
111B S Governors Ave STE 28959
Dover, Delaware 19904, United States

Last updated: July 2026

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