Privacy Policy

Version: April 22, 2025. Replaces all prior versions.

1. Introduction

This Privacy Policy explains how Anneal Investment Management LLC and our affiliated companies (“Anneal,” “we,” or “us”) collect, use, and protect your information when you use our website at anneal.co (“Website”). This policy only applies to the Website—not to other ways we might collect your information.

This Policy also applies to any mobile version of our Website or Anneal applications that link to this notice.

This Privacy Policy is part of and should be read together with our Website Terms of Use, which govern your use of this Website. The Terms include important disclaimers, limitations of liability, and eligibility requirements that also apply to your use of the site.

2. What We Collect

Personal Information

We may collect information like your name, company, address, phone number, email, or anything else you provide through forms or documents on our site. If you submit investor-related information through our Website—such as an indication of interest, accreditation documents, or subscription forms—please note that such information is governed by the relevant investor privacy notice or offering materials. This policy only applies to general Website usage.

Non-Personal Information

We also gather things like your device’s IP address, your browser type, operating system, and how long and how often you visit our site. We collect this automatically using cookies and web beacons (small pieces of code that track website usage).

3. How We Use Your Information

We use your information to:

  • Respond to your questions or requests
  • Tell you more about Anneal and our services
  • Improve our website and services
  • Communicate with you about your interactions with us
  • Keep our website secure

We don’t sell or share your information with advertisers or marketers. We may use your info as permitted by law.

4. When We Share Information

We may share your information with:

  • Our staff, agents, or service providers who help us run the website or respond to you
  • Legal authorities if required, such as through a subpoena or investigation
  • Others if needed to prevent fraud or protect someone’s safety

In cases where you provide information related to a potential investment or service relationship, we may also share it with our fund administrator, legal counsel, independent auditors, or other professional service providers who support our operations and help us comply with applicable legal, tax, and regulatory requirements.

We take reasonable steps to ensure that our service providers uphold privacy and security standards consistent with this Policy, including through contractual obligations and, where appropriate, due diligence processes.

5. Cookies & Tracking

Cookies are small text files stored on your device. They help the site remember your settings and preferences, so you don’t have to re-enter them every time. We use two types of cookies:

  • Session cookies: Deleted when you close your browser
  • Persistent cookies: Stay on your device for a longer time

Cookies help us:

  • Understand how people use the site
  • Improve performance and layout
  • Customize your browsing experience

We use different types of cookies for different purposes:

  • Essential cookies help the site function properly and support features like form submissions.
  • Analytics cookies help us understand how visitors interact with the site so we can improve it.
  • Performance cookies help improve page load times and overall user experience.

We ask for your permission before using non-essential cookies, like those for analytics. You can control cookie settings through your browser or our cookie preferences tool.

Note: Our website doesn’t respond to “Do Not Track” signals.

6. Keeping Your Information

We keep your personal information only as long as needed to fulfill the purposes outlined in this Policy, including legal, tax, accounting, or operational reasons. We regularly review the information we hold and delete or anonymize anything we no longer need. In some cases, we may retain personal information for extended periods to comply with recordkeeping requirements under applicable financial regulations, such as those imposed by the U.S. Securities and Exchange Commission (SEC) or Commodity Futures Trading Commission (CFTC).

7. If Anneal Is Sold or Merged

If Anneal is ever sold or merges with another company, your information may be part of the deal.

8. Links to Other Sites

If you click a link to another website, this policy no longer applies. We’re not responsible for how other websites handle your information.

9. Google reCAPTCHA

We use Google’s reCAPTCHA to block bots from using our online forms. Google may collect your IP address and other information as part of this. Their privacy policy is here: Google Privacy Policy.

10. Security Practices

We work hard to protect your personal information, but no online system is 100% secure. Please be cautious when sharing information online.

If you’re outside the U.S., know that we may store your data in the U.S., which may not have the same privacy protections as your country. By using our site, you agree to this.

Access to personal information is limited to employees, agents, and service providers who need it for business purposes. We train our personnel on data privacy responsibilities and maintain access controls to help protect your information.

If we become aware of a data breach involving your personal information, we will notify you in accordance with applicable laws and follow our internal incident response procedures to investigate and mitigate the impact.

11. Children’s Privacy

Our website is for people 18 or older. We don’t knowingly collect information from kids under 13. If you’re a parent and think your child shared information with us, email us (see below). We’ll take action to remove it.

12. Rights for EEA and UK Residents

We process your data because it is necessary for our contract with you or based on our legitimate business interests.

If you live in the European Economic Area or the UK, you can:

  • See or update your information
  • Ask us to delete your data
  • Ask us to stop using your data in certain ways
  • Request a copy of your data

We may need to keep some data for legal or business reasons. You also have the right to complain to your local privacy authority.

When we transfer personal information outside the EEA or the UK, we use appropriate legal safeguards such as standard contractual clauses approved by the European Commission or other lawful mechanisms to help ensure your data remains protected.

13. Rights for California Residents

If you live in California, you can:

  • Ask what personal information we’ve collected and how we’ve used it
  • Request a copy of your data
  • Ask us to correct or delete your information
  • Opt out of data sharing (though we don’t sell or share your info for advertising)
  • Not be discriminated against for exercising these rights

You can also ask someone to make these requests on your behalf. Just make sure they have your written permission and can prove their identity.

If we collect any sensitive personal information, we only use it for permitted business purposes and do not use it to infer characteristics about you. We may also combine or anonymize data to better understand trends without identifying anyone personally.

Please note that, for certain types of relationships, we may be subject to the U.S. Gramm-Leach-Bliley Act (GLBA), which sets specific requirements for how we handle personal financial information. Where applicable, we provide a separate GLBA privacy notice to investors in our funds.

We don’t share your info with others for their own direct marketing.

14. Changes to This Policy

We may change this policy from time to time. If we do, we’ll update the date at the top and post the new version here. Please check back occasionally.

We keep copies of past versions. Just ask if you’d like to see them.

15. Contact Us

If you have any questions or want to use your privacy rights, email us at: privacypolicy@anneal.co

Or write to:
Anneal Investment Management, LLC
Attn: Privacy Compliance
169 Madison Ave, Suite 2958
New York, NY 10016