Privacy Policy

1322 Capital LLC, a Virginia limited liability company (“1322 Capital,” “we,” “us,” or “our”), respects your privacy. This Privacy Policy explains what personal information we collect through 1322-capital.com, including our Insights blog (the “Site”), and through the email, telephone, and text-message communications that originate from it; how we use and disclose that information; and the rights and choices available to you. It does not apply to the websites of our portfolio companies or affiliated organizations, which maintain their own policies.

1. Information we collect

Information you provide. When you submit a form, email or call us, or register for text messages, we collect the information you choose to give us: your name, company or organization, title, email address, mobile or telephone number, mailing address, and the contents of your message. When you register for text messages, we also record your consent, including the date, time, and web page on which it was given.

Information collected automatically. When you visit the Site, our hosting and analytics providers automatically collect technical information such as your IP address, browser and device type, operating system, pages viewed, referring page, and the date and time of your visit, using cookies, pixels, and similar technologies.

Information from others. We may receive your business contact information from a colleague, client, or advisor who refers you to us.

Sensitive information. We do not request, and ask that you not submit through the Site, sensitive data such as Social Security numbers, government identification numbers, financial account numbers, health information, or precise geolocation. We do not knowingly collect such data through the Site.

2. How we use information

• To respond to inquiries and to evaluate, provide, and administer the services you request.
• To schedule, confirm, and follow up on meetings and engagements.
• To send service-related messages by email, telephone, or text message where you have provided the required consent.
• To operate, maintain, secure, and improve the Site, including detecting and preventing fraud, abuse, and security incidents.
• To keep records of consent and opt-out requests and to comply with legal, regulatory, tax, and recordkeeping obligations.
• To establish, exercise, or defend legal claims.

We do not sell personal information, we do not use it for targeted (cross-context behavioral) advertising, and we do not use it for profiling that produces legal or similarly significant effects.

3. Text messaging (SMS/MMS)

If you provide your mobile number and affirmatively check the consent box on our SMS Registration form or another form that presents it, you agree to receive text messages from 1322 Capital LLC about your inquiry, appointment scheduling and coordination, service updates, confirmations, and follow-ups. These are informational, non-marketing messages. Consent to receive text messages is not a condition of purchasing any goods or services.

• Message frequency varies. Message and data rates may apply.
• You may opt out at any time by replying STOP to any message. We also honor other reasonable expressions of your wish to stop, including replies such as QUIT, END, CANCEL, UNSUBSCRIBE, REVOKE, or OPT OUT, and requests made by email or telephone. We process opt-out requests promptly and in no case later than ten business days after receipt. You may receive one message confirming your opt-out.
• Reply HELP for assistance, or contact us using the details below.
• Carriers are not liable for delayed or undelivered messages.

No mobile information will be shared with third parties or affiliates for marketing or promotional purposes. Text-messaging originator opt-in data and consent are excluded from all other categories of sharing described in this Policy and will not be shared with any third parties, except with the service providers that transmit our messages on our behalf.

We do not place telephone solicitation calls or send telephone solicitation texts. If we ever do, we will comply with the federal Telephone Consumer Protection Act and the Virginia Telephone Privacy Protection Act, including by honoring opt-out requests for at least ten years. Additional terms appear in our SMS Terms & Conditions.

4. Email communications

Any commercial email we send will identify 1322 Capital LLC as the sender, include our postal address, and contain a working unsubscribe link, consistent with the federal CAN-SPAM Act. We honor unsubscribe requests within ten business days. We may continue to send transactional or relationship messages concerning an engagement you have with us.

5. How we disclose information

We disclose personal information only as follows:

• Service providers (processors) that perform services on our behalf under written obligations to use the information only to provide those services and to protect it, including website hosting and customer-relationship management, email and productivity, text-message delivery, scheduling, and analytics providers.
• Professional advisors, such as attorneys, accountants, and auditors, who are bound by duties of confidentiality.
• Legal and safety purposes: to comply with law, regulation, subpoena, or court order; to respond to lawful requests from public authorities; or to protect the rights, property, or safety of 1322 Capital, our clients, or others.
• Business transfers: in connection with a merger, acquisition, financing, reorganization, or sale of all or part of our business, subject to this Policy.
• With your consent or at your direction.

6. Cookies, analytics, and browser signals

We use cookies and similar technologies that are necessary to operate the Site and to understand how it is used. You can block or delete cookies through your browser settings; doing so may affect some features. Because we do not sell personal information or use it for targeted advertising, opt-out preference signals such as Global Privacy Control and “Do Not Track” do not change how we process data today. If our practices change, we will update this Policy and honor applicable signals as required by law.

7. Data retention

We keep personal information only as long as reasonably necessary for the purposes described in this Policy, including to maintain our business relationship with you, and as required to comply with legal, tax, and recordkeeping obligations. We keep records of text-message consent and opt-out requests for as long as needed to demonstrate compliance with applicable telephone and messaging laws. When information is no longer needed, we delete or de-identify it.

8. Data security and breach notification

We maintain reasonable administrative, technical, and physical safeguards appropriate to the nature of the information we process, including access controls, multi-factor authentication, and encryption in transit. No method of transmission or storage is completely secure, and we cannot guarantee absolute security. If a breach of the security of our systems compromises your personal information, we will notify you and, where required, the Virginia Office of the Attorney General, as provided in Virginia Code § 18.2-186.6 and other applicable law.

9. Your privacy rights

Whether or not a particular privacy statute applies to us, we extend the following rights to every individual who uses the Site. Subject to verification of your identity and to limited legal exceptions, you may:

• Confirm whether we process your personal information and obtain access to it;
• Correct inaccuracies in your personal information;
• Delete personal information you provided or that we obtained about you;
• Obtain a copy of your personal information in a portable and, where technically feasible, readily usable format; and
• Opt out of the sale of your personal information, targeted advertising, and profiling in furtherance of decisions that produce legal or similarly significant effects. (We do not engage in these activities.)

How to submit a request. Email [email protected] with the subject line “Privacy Request,” or call 804.636.5849. We will ask for information sufficient to verify your identity, and we will not require you to create an account. We respond within 45 days of receipt. Where reasonably necessary, we may extend that period once by an additional 45 days and will tell you why. We do not charge for requests unless they are manifestly unfounded, excessive, or repetitive. We will not discriminate against you for exercising these rights.

Appeals. If we decline to act on your request, you may appeal by replying to our decision or emailing [email protected] with the subject line “Privacy Appeal” within a reasonable time after receiving it. We will respond in writing within 60 days and explain our decision. If your appeal is denied, you may contact the Virginia Office of the Attorney General, Consumer Protection Section, at www.oag.state.va.us/consumer-protection.

10. Children’s privacy

The Site is intended for business audiences and is not directed to children. We do not knowingly collect personal information from children under 13, consistent with the Children’s Online Privacy Protection Act, and we do not knowingly sell, or use for targeted advertising, the personal information of anyone under 18. If you believe a child has provided us personal information, contact us and we will delete it.

11. Third-party links

The Site links to websites we do not operate, including those of our portfolio companies and affiliated organizations. We are not responsible for their content or privacy practices, and we encourage you to review their policies.

12. Location of processing

1322 Capital operates in the United States, and the information we collect is processed and stored in the United States. If you access the Site from outside the United States, you understand that your information will be transferred to and processed in the United States.

13. Changes to this Policy

We may update this Policy from time to time. We will post the revised Policy on this page and update the “Last updated” date above. If we make material changes to how we use or disclose personal information we have already collected, we will provide additional notice and, where required by law, obtain your consent.

14. Contact us

1322 Capital LLC
8401 Mayland Drive, Suite 8123
Richmond, VA 23294
[email protected] · 804.636.5849