This Privacy Policy (the “Policy”) describes how Silver Hook Capital and its affiliated investment vehicles and family-office entities (collectively, “Silver Hook,” “the Firm,” “we,” “our,” or “us”) collect, use, disclose, and safeguard personal information in connection with this website, silverhookcapital.com (the “Site”), and any inquiries or correspondence directed to us through the Site or through email addresses associated with the Site. By accessing or using the Site, or by submitting information to us, you acknowledge that you have read and understood this Policy.
1. Important Threshold Notice
Silver Hook Capital is a privately held family investment office. We do not solicit, accept, or manage capital from the general public. The Firm is not registered as an investment adviser, broker-dealer, commodity pool operator, or commodity trading adviser, and nothing on this Site constitutes the offer or sale of any security, investment advisory services, or any other regulated product or service. This Policy is provided as a matter of professional practice and goodwill; it is not a regulatory disclosure required of a registered firm.
2. Scope of This Policy
This Policy applies to personal information collected through the Site and through email or other electronic correspondence sent to addresses published on the Site. It does not apply to: (a) information collected offline or through channels other than the Site; (b) information collected by third parties to whom the Site may link, including privatecolorado.com or any other affiliated property-level project site, each of which is governed by its own privacy policy; or (c) information you provide to us in the course of a deal-specific diligence process, which will be governed by the confidentiality and non-disclosure agreements then in effect.
3. Information We Collect
The categories of personal information we may collect are limited and are summarized below.
- Information you voluntarily provide. When you complete our contact form or email us, we collect your name, the name of the entity or firm you represent, your email address, the nature of your inquiry, and the contents of your message, together with any attachments or supplemental information you elect to provide.
- Information collected automatically. Our hosting environment and any analytics service we engage may automatically log limited technical information about your visit, including IP address, approximate geographic location derived from IP address, browser type and version, device type, operating system, referring URL, pages visited, and timestamps. This information is used for site administration, security, fraud prevention, and aggregate performance analysis.
- Information derived from public or commercial sources. In the course of evaluating an inbound inquiry, we may consult publicly available sources (regulatory filings, public records, professional networking platforms, news, and commercial information services) to verify your identity or affiliation, assess fit with our investment focus, and conduct customary background and reputational diligence.
- Information from cookies and similar technologies. See Section 7 (Cookies, Analytics, and Tracking) below.
We do not knowingly collect, and the Site is not designed to elicit, sensitive personal information, special categories of data, government identifiers, financial account numbers, or health information. Please do not transmit such information through the Site.
4. How We Use Information
We use personal information only for legitimate, narrowly tailored purposes, including:
- responding to your inquiry and continuing a relevant business conversation;
- evaluating opportunities, principals, and counterparties for potential fit with the Firm’s investment focus;
- conducting customary diligence, including identity verification, sanctions and anti-money-laundering screening, and reputational review;
- maintaining records of communications consistent with our internal compliance, recordkeeping, and risk-management practices;
- protecting the security, availability, and integrity of the Site and our internal systems;
- satisfying applicable legal, regulatory, audit, tax, or court-ordered obligations; and
- establishing, exercising, or defending legal claims.
We do not sell personal information, and we do not share personal information for cross-context behavioral advertising, as those terms are defined under the California Consumer Privacy Act, as amended (the “CCPA”).
5. Legal Bases for Processing (EEA / UK Visitors)
If you are located in the European Economic Area, the United Kingdom, or Switzerland, we process your personal information on the following legal bases under the General Data Protection Regulation and equivalent law: (a) our legitimate interests in evaluating and responding to business inquiries, maintaining the security of the Site, conducting diligence on potential counterparties, and protecting our rights, provided those interests are not overridden by your fundamental rights and freedoms; (b) compliance with legal obligations to which we are subject; (c) your consent, where consent is required and obtained; and (d) the necessity of taking steps at your request prior to entering into a contract.
6. How We Disclose Information
We disclose personal information only in limited circumstances:
- Affiliates and personnel. Members of the Firm’s investment, operations, and advisory team who have a legitimate need to evaluate or act on your inquiry.
- Service providers. Vetted vendors that host our Site, deliver email, provide analytics, store records, and assist with diligence, in each case bound by confidentiality and data-protection commitments and permitted to use information only for the services they provide to us.
- Professional advisors. Outside counsel, accountants, auditors, and consultants engaged in connection with a transaction or matter that involves your inquiry.
- Co-investors and transaction counterparties. Where you have engaged us in connection with a specific opportunity, we may share information with prospective co-investors, lenders, brokers, sellers, or other counterparties as reasonably necessary to evaluate or close that opportunity, subject to appropriate confidentiality protections.
- Legal and regulatory disclosures. When required by law, subpoena, court order, regulatory inquiry, or legitimate request from a governmental authority, or where we believe in good faith that disclosure is necessary to protect rights, property, or safety.
- Business transitions. In connection with a reorganization, restructuring, merger, sale of assets, financing, or similar event involving the Firm, in which case personal information may be transferred subject to customary confidentiality obligations.
7. Cookies, Analytics, and Tracking
The Site uses a minimal set of cookies and similar technologies that may be necessary for basic functionality and security. We do not use the Site to serve advertising, and we do not sell or share personal information for cross-context behavioral advertising.
We use two analytics services to understand how the Site is used:
- Vercel Web Analytics, provided by our hosting provider, which is cookieless and collects only aggregate, non-identifying information about page visits.
- Google Analytics 4, provided by Google LLC, which sets cookies on your device and collects information such as pages visited, referring URL, approximate geographic location derived from IP address, device and browser type, and interactions with the Site. Google Analytics 4 does not store IP addresses. We have disabled Google Signals, so your analytics data is not used for cross-device advertising or audience targeting, and we do not combine analytics data with identifying information for marketing purposes. Analytics data is retained for no longer than 14 months.
You may control cookies through your browser settings; doing so may affect Site functionality. You may also opt out of Google Analytics entirely by installing Google’s Analytics Opt-out Browser Add-on. Google’s handling of information collected through its services is described in the Google Privacy Policy.
8. International Data Transfers
The Firm is established in the United States. Information you submit may be processed in the United States or in other jurisdictions where our service providers operate, which may have data-protection laws different from those of your home jurisdiction. Where required, we rely on appropriate transfer mechanisms such as the European Commission’s Standard Contractual Clauses and equivalent safeguards.
9. Data Retention
We retain personal information only for as long as reasonably necessary to fulfill the purposes for which it was collected, to satisfy our legal, regulatory, recordkeeping, tax, audit, accounting, or reporting obligations, and to establish, exercise, or defend legal claims. Records relating to inquiries that do not proceed are retained for a reasonable evaluation period and thereafter purged on a recurring cadence, except where retention is required by law or warranted by ongoing relationship or risk-management considerations.
10. Information Security
We maintain administrative, technical, and physical safeguards designed to protect the confidentiality, integrity, and availability of personal information in our possession. No method of electronic transmission or storage is, however, completely secure, and we cannot guarantee absolute security. You should not transmit sensitive or non-public information through unsecured email or the contact form on the Site; appropriate secure channels will be made available once a confidentiality framework has been established for a specific matter.
11. Your Rights
Depending on the jurisdiction in which you reside, you may have certain rights with respect to personal information we hold about you, including the right to:
- request access to, or a copy of, personal information we maintain about you;
- request correction of inaccurate or incomplete personal information;
- request deletion of personal information, subject to applicable exceptions and our retention obligations;
- object to or restrict certain processing of your personal information;
- withdraw consent where processing is based on consent (without affecting the lawfulness of prior processing);
- request portability of personal information you provided to us;
- opt out of the sale or sharing of personal information (we do not engage in either); and
- lodge a complaint with a competent supervisory authority.
To exercise any of these rights, please email info@silverhookcapital.com with a clear description of your request. We will verify your identity in a manner proportionate to the sensitivity of the request and respond within the timeframes required by applicable law. You may designate an authorized agent to make a request on your behalf upon written authorization that we can verify.
12. California Privacy Notice
This section supplements the foregoing for California residents. In the preceding twelve months we have collected the following categories of personal information identified under the CCPA: identifiers (name, email, IP address), professional or employment-related information (employer, role), internet or other electronic network activity information, geolocation (general, from IP address), and inferences drawn from the foregoing. Such information is collected from you directly and, in limited circumstances, from public sources. The purposes are described in Section 4. We do not sell or share personal information for cross-context behavioral advertising. California residents have the rights described in Section 11 above and may also be entitled to be free from discrimination for exercising their rights. To submit a verifiable consumer request, email info@silverhookcapital.com.
13. Children’s Privacy
The Site is directed to a sophisticated adult audience and is not intended for, or directed to, individuals under the age of eighteen. We do not knowingly collect personal information from children. If you believe a child has submitted information through the Site, please contact us so that we can take appropriate action.
14. “Do Not Track” Signals
The Site does not currently respond to browser-based “Do Not Track” signals because no industry standard has been finalized for honoring such signals. We do not, however, engage in the cross-site tracking that the Do Not Track signal is generally intended to prevent.
15. Third-Party Sites and Featured Projects
The Site may link to third-party websites, including project-specific sites such as privatecolorado.com. Those sites are governed by their own privacy policies, and we are not responsible for their content or practices. Please review each site’s policy before submitting personal information.
16. Changes to This Policy
We may revise this Policy from time to time. The “Last Updated” date at the top of this page indicates when the Policy was last revised. Material changes will be reflected by a conspicuous notice on the Site, the Site’s footer, or otherwise as required by law. Your continued use of the Site after the effective date of a revision constitutes your acceptance of the revised Policy.
17. Contact
Questions about this Policy, or about how we handle personal information, may be directed to:
Silver Hook Capital
Attention: Privacy & Compliance
Email: info@silverhookcapital.com
Nothing in this Policy is intended to create rights enforceable by third parties or to require disclosure of information that is privileged, confidential, or otherwise protected from disclosure under applicable law.