Privacy Policy

Dear User! White Sails would like to thank you for your interest in and use of our content, functionalities, and services offered on or through whitesails.com — “our Platform.” The Privacy Policy and any other document(s) incorporated herein by reference govern the collection and use of your personal data on or through our Platform, so please read it thoroughly before accessing or using Platform by White Sails LLC, (the “Company”).

This privacy policy informs you about the processing of personal data within our website on behalf of WhiteSails (“WhiteSails”) and its affiliates.

By accessing and using our platform YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTOOD AND AGREE THAT YOU ARE LEGALLY BOUND BY THIS PRIVACY POLICY. If you are using our Platform on behalf of any entity, then you are agreeing to this Privacy Policy on behalf of that entity. You are responsible for the actions of any other person who may utilize your access rights on our Platform. 

If you do not accept this Privacy Policy, you are not authorized to use our Platform. We reserve the right to modify this Privacy Policy at any time and such modification will be valid upon posting to our Platform and/or provision of an email notice to you thereof. Please review this Privacy Policy periodically for changes.

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Applicable law: By visiting our website, you agree that the laws of the States of FL and NY, without regard to principles of conflict of laws, will govern this Privacy Policy and any dispute of any sort that might arise between you and WhiteSails.

‍Collection of your personal information: In order to provide you with products and services offered on our website, WhiteSails collects personally identifiable information (collectively, your “Personal Information”) on or through our Platform, including:

– First and Last Name

– Email Address

– Phone Number

You have provided or may need to provide the listed above and, if necessary, other types of personal data to us by virtue of requesting information about WhiteSails, becoming a WhiteSailsclient, using the WhiteSailsplatform available at https://www.whitesails.com or any of its subdomains (the “Platform”), including by simply viewing content on the Platform, or otherwise interacting with WhiteSails. The Platform is part of your agreement with WhiteSails LLC and, as applicable, WhiteSails affiliates as well as any projects you may choose to invest in via the Platform. The privacy notice applies regardless of the domains, platforms and devices used (e.g. desktop, mobile, etc.).

‍Automated Collection and Use of Aggregated Data: We process personal data that we receive from you while using our website and, if applicable, in the course of our business relationship. White Sails may collect anonymous demographic information, which is not unique to you, including your:

–ZIP code

–Age

–Gender

–Race

–Preferences

In the case of purely informational use of our website, i.e., if you do not register or otherwise submit information to us, we only collect the personal data that your browser transmits to our server. When you access our website, we collect the following access data, which is technically necessary for us to present our website to you and to ensure stability and security. The access data includes the IP address, date and time of the request, time zone difference to Greenwich Mean Time (GMT), content of the request (i.e. name of the specific website accessed), access status/HTTP status code, amount of data transferred in each case, referrer URL (previously visited page), operating system and its interface, language and version as well as type of browser software and notification of successful retrieval.

This information is used by White Sails to ensure seamless operation of our Platform, maintain the high quality of our services, and provide general statistics regarding the use of our Platform.

White Sails may keep track of the websites and pages our users visit within White Sails Platform, in order to determine what White Sails services are the most popular. This data is used to deliver customized content and advertising within our platform to customers whose actions indicate that they are interested in a particular subject area.

WE DO NOT COLLECT ANY PERSONAL INFORMATION ABOUT YOU UNLESS YOU VOLUNTARILY PROVIDE IT TO US. Furthermore, we receive your personal data if you contact us via a contact form, chat or email, and through any associated documentation that you complete when subscribing for an interest in White Sails. The personal data that we collect in these circumstances are, for example, name, address, e-mail address, telephone number, date of birth, passport details or other national identifier, driving license, your national insurance or social security number and income, employment information and details about your investment or retirement portfolio(s), and, if applicable, any data contained in the message that you send us. 

You may be required to provide certain personal information to us when you elect to use certain products or services available on the Platform. These may include: (a) registering for an account on our Platform; (b) signing up for special offers from selected third parties; (c) sending us an email message on or through our Platform. 

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What do we process your data for (purpose of processing)

If you have given us consent to process personal data for certain purposes, in particular for contacting you (e.g. sending newsletters, advertising by telephone, e-mail, SMS, or in relation to the creation of a user account), this processing is lawful on the basis of your permission.

When you visit our website for the first time, you will be asked whether you also wish to accept non-essential cookies. If you consent to the use of non-essential cookies, this will allow us to analyze your use of our website. Furthermore, we may carry out various marketing activities based on your interactions with the website, other marketing channels and other third parties, such as social networks.

When contacting us (via contact form, chat or e-mail), your data will be processed for the purpose of handling the contact request and its processing.

If you decide to register as an investor on our Platform and invest in projects we may offer to you, we process the necessary data in order to fulfill our contractual obligations with you.

We are required by regulatory obligations to record video calls, telephone calls and electronic communications (so-called taping) that directly relate to the conclusion of a transaction with you or that are intended to result in such a transaction.

In order to prevent and detect money laundering and the financing of terrorism and to comply with any other regulations relating to sanctions and embargoes through our Know Your Customer (KYC) process, we will process certain information, including to identify you, verify your identity, screen your details against sanctions lists and determine your profile. You should note that these services may be carried out by our third party service providers.

We process your access data to safeguard our legitimate interests or those of third parties. In particular, we pursue the following legitimate interests:

  • Ensuring IT security, in particular the security of our website; we also store the IP address in the event that someone leaves behind illegal content using the comment function (insults, prohibited propaganda, etc.) and we must be able to determine the author’s identity for our own legal protection;
  • Monitoring and improving our relationships with investors;
  • Asserting legal claims and conducting our defense in case of legal disputes.
  • Enabling any actual or proposed assignee or transferee, participant or sub-participant of the partnership’s rights or obligations to evaluate proposed transactions; and
  • Facilitating business asset transactions involving White Sails partnership.

We may from time to time hold events, either in person or online, in order to discuss our services and our business sector with potential clients and interested parties. We may make video and audio recordings of such events and, therefore, if you attend or speak at such an event we may record you and process your personal data, for example your name, company, job details, or any personal data that you reveal as part of discussions at the event. We will record such events where it is in our legitimate interests to do so, such as to promote the event, our business and that of the attendees, and to reproduce the event and make the content available to a wider audience.

Where necessary and in particular with regard to video and photographic material, we will obtain your consent.

Consent – where we process your personal data based on consent, you may withdraw your consent at any time by contacting us at contact details indicated on the White Sails website. Please note that the withdrawal is only effective from the date on which you notify us of such withdrawal. Processing that took place before the withdrawal is therefore not affected, but you are entitled to request that we provide you with details of, or that we delete, the personal data that we hold about you.

In any case, our legitimate interest remains proportionate and we verify according to a balancing test that your interests or fundamental rights are preserved.

Who can access my data?

Within the organization, departments that need to know your data to fulfill our contractual and regulatory obligations can access your data. 

In addition, processors engaged by us may also obtain access to data for the above-mentioned purposes. These may be, for example, our IT service providers, hosting provider, background and/or credit reference check providers or third parties that provide printing services, telecommunications, sales and marketing services. If we use processors to provide our services, we will take appropriate legal precautions as well as the relevant contractual, technical and organizational measures to protect personal data in accordance with applicable law.

Recipients of the data may also be White Sails Ambassadors and Members of the White Sails community who have referred you to White Sails; White Sailsgroup members; White Sails’s funds, the underlying funds and the fund sponsors / fund managers of such underlying funds and other service providers and delegates employed and/or retained by them; professional partners such as private banks, family offices, fund managers, law firms and other service providers; and public authorities.

‍No sharing information with third parties: White Sails does not sell, rent or lease its customer lists to third parties. White Sails may share data with trusted partners to help perform statistical analysis, send you email or postal mail, provide customer support, or arrange for deliveries. All such third parties are prohibited from using your personal information except to provide these services to White Sails, and they are required to maintain the confidentiality of your information. As we use third parties services, we have no control over these services.

Any transfer of data to third parties will be made only within the scope of legal requirements. We will disclose your data to third parties only if this is required, for example, for contractual purposes or based on legitimate interests pursuant in the economic and effective operation of our business or if you have consented to the transfer of data. In the case of purely informational use of the website, we do not pass on any data to third parties.

White Sails may disclose your personal information, without notice, if required to do so by law or in the good faith belief that such action is necessary to: (a) conform to the edicts of the law or comply with the legal process served on White Sailsor the site; (b) protect and defend the rights or property of White Sails; and/or (c) act under exigent circumstances to protect the personal safety of users of White Sails, or the public.

‍E-mail communications: From time to time, White Sails may contact you via email for the purpose of providing announcements, promotional offers, alerts, confirmations, surveys, and/or other general communication.

If you would like to stop receiving marketing or promotional communications via email from White Sails, you may opt out of such communications by clicking on the UNSUBSCRIBE emails.

How long will my data be retained?

For security reasons (e.g. to clarify acts of abuse or fraud), log file information is stored for a maximum of 30 days and then deleted. Data whose further storage is necessary for evidentiary purposes is exempt from deletion until the final clarification of the respective incident.

As far as necessary, we process and store your personal data for the duration of our business relationship, which also includes, for example, the initiation of a contract via contact form or by e-mail.

Is there an obligation for me to provide data?

You must provide the personal data that is required for the use of our website for technical or IT security reasons in order to use our website. If you do not provide this data, you will not be able to use our website.

When contacting us by form or e-mail, you only need to provide the personal data that is required to process your request. Otherwise we will not be able to process your request.

When you enter into a business relationship with us, you must provide the personal data that is required for the establishment, performance and termination of a business relationship or that we are required to collect by law. Without this data, we usually have to refuse to conclude a contract or can no longer fulfill an existing contract and may have to terminate it.

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‍Security of your personal information: White Sails secures your personal information from unauthorized access, use, or disclosure. White Sailsuses the following methods for this purpose:

– SSL Protocol

When personal information (such as a credit card number) is transmitted to other websites, it is protected through the use of encryption, such as the Secure Sockets Layer (SSL) protocol.

We strive to take appropriate security measures to protect against unauthorized access to or alteration of your personal information. Unfortunately, no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, you acknowledge that: (a) there are security and privacy limitations inherent to the Internet which are beyond our control; and (b) security, integrity, and privacy of any and all information and data exchanged between you and us through this Platform cannot be guaranteed.

‍Links: This Platform contains links to other sites. Please be aware that we are not responsible for the content or privacy practices of such other sites. We encourage our users to be aware when they leave our Platform and to read the privacy statements of any other site that collects personally identifiable information.

‍Right to deletion: Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:

• Delete your personal information from our records; 

• Direct any service providers to delete your personal information from their records; 

Please note that we may not be able to comply with requests to delete your personal information if it is necessary to:

• Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us;

• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity; 

• Debug to identify and repair errors that impair existing intended functionality;

• Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;

• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent;

• Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;

• Comply with an existing legal obligation; and/or

• Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.

‍Children under thirteen: White Sails does not knowingly collect personally identifiable information from children under the age of thirteen. If you are under the age of thirteen, you must ask your parent or guardian for permission to use this website.

Indemnification: You agree to defend, indemnify and hold harmless White Sails and independent contractors and consultants, and each of their respective officers, employees, agents, affiliates, successors and assigns, from and against any claims, damages, costs, liabilities, and expenses (including, but not limited to, reasonable attorneys’ fees) arising out of your breach of violation of this Privacy Policy, any applicable law or the rights of any third party; and/or your gross negligence, fraud and/or willful misconduct.

Notices and ‍contact Information: Any notices or other communications permitted or required will be in writing and delivered by White Sails to you by email (to the address that you voluntarily indicated while requesting services). You are responsible to maintain your verified email mailbox and agree to check your mailbox frequently. We hold no responsibility for a missed communication and any consequence caused by such missed communication. All notices shall be deemed effective within one (1) business day after successful transmission (or posting) thereof. 

Copyright and trademark notices: All contents of our platform are: copyright by White Sails and/or its suppliers. All rights reserved.

White Sails welcomes your questions or comments regarding this Privacy Policy. If you believe that White Sails has not adhered to this Statement, please contact White Sails at:

White Sails LLC

Email Address:

Telephone number:

Last Revised on February 22, 2023

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