Version: 1.0

August 9, 2023

Introduction

Welcome to Alphascend Capital Group’s Privacy Policy. As a firm that specializes in oil and gas investment opportunities, protecting your privacy and the confidentiality of your investment-related information is of paramount importance to us. This Privacy Policy outlines how we collect, use, verify, protect, and share your personal and investment information when you express interest in our investment opportunities or interact with us through our website, forms, or other services.

At Alphascend Capital Group, we are committed to respecting your privacy rights and safeguarding your personal and financial information. We understand that the privacy of your personal data, as well as the confidentiality of your investment interests and accredited investor status, is vital, and we take our responsibility to protect this information very seriously.

This Privacy Policy applies specifically to the information that we collect from potential investors, in accordance with Rule 506(c), and through our website or other communication channels we provide. By expressing interest in our investment opportunities or using our services, you agree to the terms and conditions of this Privacy Policy, and you expressly consent to the collection, use, verification, and disclosure of your personal and investment information in accordance with this Privacy Policy.

We encourage you to read this Privacy Policy carefully, as it includes details on how we may use third-party services for verification and the measures we take to maintain the confidentiality of your investment-related information. If you have any questions or concerns about our privacy practices, please do not hesitate to reach out to us at connect@oilandgasinvestmentfunds.com. 

Alphascend Capital Group is the data controller for the purposes of investment opportunities, meaning we are responsible for deciding how and why we hold and use your personal and investment data. We are committed to being transparent about our practices, your privacy rights, and how you can control how your information is used, in full compliance with the privacy regulations in the United States.

Investor Information Collection and Usage

Collection of Information

At Alphascend Capital Group, we value your trust and are committed to the responsible management, use, and protection of personal information. As part of our investment process, particularly under Regulation D Rule 506(c), we may collect specific information from potential investors to verify their accredited investor status. The information collected may include, but is not limited to:

• Personal Identification Information: Full name, address, date of birth, and Social Security Number (or equivalent identification number).
• Financial Information: Net worth, income, assets, liabilities, and specific investment transactions.
• Employment Information: Occupation, employer’s name, and contact details.
• Investment Experience and Objectives: Information about your investment experience, risk tolerance, and investment objectives.
• Contact Information: Email address, phone number, and preferred method of communication.
• Consents and Agreements: Records of consents, acknowledgments, agreements related to the investment opportunities.

Usage of Information

The information collected from potential investors is used exclusively for the following purposes:

• Verification of Accredited Investor Status: To comply with the SEC’s Regulation D Rule 506(c), we must take reasonable steps to verify that all purchasers are accredited investors. The information collected assists in this verification process.
• Communication: To provide updates, notifications, and respond to inquiries or requests related to investment opportunities.
• Legal Compliance: To meet legal and regulatory requirements, including compliance with anti-money laundering regulations, securities laws, and tax reporting obligations.
• Internal Analysis: For internal analysis to understand investor needs, enhance our offerings, and improve overall service.

Safeguarding Investor Information

We implement robust security measures designed to protect your information from unauthorized access, disclosure, alteration, or destruction. These measures include technological, physical, and administrative safeguards consistent with industry standards.

Third-Party Disclosure

Your investor information is considered highly confidential. We do not sell, trade, or otherwise transfer your personal information to outside parties except to trusted third parties who assist us in conducting our business, and only when those parties agree to keep this information confidential and adhere to all relevant laws and regulations.

Your Consent

By providing your information and engaging in the investment process with Alphascend Capital Group, you consent to the collection and use of your information as described in this section.

How We Collect Information

At Alphascend Capital Group, we collect your personal information through various methods to ensure we understand your needs and can provide a personalized and efficient service. Here is how we collect information:

• Directly From You: Most of the information we collect is provided directly by you. This happens when you:
• Fill out forms on our Website: When you use our website, you may fill out forms to contact us or request more information about our services. These forms collect your contact information, general information about you or your business, and any questions or comments you may have.
• Interact with us: We collect information when you interact with us, such as when you communicate with our customer service or sales teams, use our services, or participate in a survey, competition, or promotion.
• Submit Leads: If you submit information through forms on platforms where we post advertisements or solicit interest, we collect that information.

We use this collected information to better understand your needs and interests, to complete your transactions, and to provide you with an efficient service. Rest assured, we respect your privacy and take great care to protect your information.

Verification of Accredited Investor Status Under Rule 506(c)

Purpose of Verification

Under SEC’s Regulation D Rule 506(c), offerings are limited to accredited investors, and issuers must take reasonable steps to verify that all purchasers are indeed accredited investors. The verification process is essential to comply with the legal requirements and to maintain the integrity and transparency of the investment process.

Information Utilized for Verification

To verify the accredited investor status, Alphascend Capital Group may use the following information:

• Income Verification: Reviewing documents such as W-2s, tax returns, or other government records for the two most recent years, and obtaining written confirmation that the individual has a reasonable expectation of reaching the income level required for an accredited investor in the current year.
• Net Worth Verification: Analyzing statements of securities holdings, bank statements, credit reports, and appraisal reports, along with a written representation that all liabilities have been disclosed. The value of the primary residence must be excluded from this calculation.
• Use of Third-Party Services for Verification: Alphascend Capital Group may also engage specialized third-party services that are dedicated to verifying the accredited investor status. These third-party services must adhere to our stringent privacy and compliance standards.
• Third-Party Verification: Engaging a registered broker-dealer, SEC-registered investment adviser, licensed attorney, or certified public accountant to provide written confirmation that they have taken reasonable steps to verify that the purchaser is an accredited investor.
• Representations from the Investor: Obtaining written confirmation and agreements from the potential investor, confirming their accredited investor status.

Reasonable Steps and Procedures

The verification process under Rule 506(c) requires reasonable steps to be taken, depending on the circumstances of each purchaser and the specific offering. Alphascend Capital Group will:

• Review and analyze the documents and information provided by the investor.
• Confirm the authenticity of documents where necessary.
• Consider the total cost and amount of the investment in relation to the investor’s overall net worth.
• Assess the investor’s understanding and acknowledgment of the investment risks.
• Consult with legal and financial professionals as needed to ensure compliance.

Record-Keeping

All information obtained for verification will be maintained in strict confidence and retained in accordance with the applicable legal requirements and Alphascend Capital Group’s record-keeping policy.

Privacy Considerations

The verification process will be conducted in accordance with Alphascend Capital Group’s Privacy Policy, ensuring that all personal and financial information is handled with the utmost care, confidentiality, and security.

Use of Cookies and Other Tracking Technologies

At Alphascend Capital Group, we may use cookies and other similar technologies to enhance your experience with our services, understand user behavior, and improve our offerings. Here’s more detail about these technologies and how we use them:

Cookies: Cookies are small files placed on your device when you visit a website. They are widely used to make websites work more efficiently, and to provide information to the website’s owners. Cookies allow us to recognize your device, remember your preferences, provide certain features, and collect information about your use of our services, such as which pages you visit and the links you click on.

We use two types of cookies:

• Session cookies – These are temporary cookies that expire when you close your browser or app.
• Persistent cookies – These cookies stay on your device until they expire or you delete them, allowing us to remember your preferences.
• Other Tracking Technologies: In addition to cookies, we may use other tracking technologies like web beacons (also known as pixel tags or clear gifs) and local storage. These technologies help us understand user behavior, monitor our services’ performance, personalize your experience, and improve our services.

Why we use these technologies: 

Enhance functionality: These technologies allow our website to remember choices you make and provide enhanced, more personal features.

Improve performance: We use these technologies to understand how our services are being used, track site performance, and make improvements.

Analytics and Research: We may use third-party analytics tools to better understand who is using our services and how, which helps us improve our services and create a better overall user experience.

Please note that most browsers allow you to control cookies through their settings preferences. However, if you limit the ability of websites to set cookies, you may worsen your overall user experience, as it will no longer be personalized to you.

Communication Compliance

Alphascend Capital Group is committed to complying with all applicable laws and regulations, including the Telephone Consumer Protection Act (TCPA). The TCPA is a federal statute that restricts telemarketing communications via voice calls, SMS texts, and fax.

Obtaining Express Written Consent: In accordance with the TCPA, we obtain your express written consent before sending any calls or text messages to your mobile phone. We do this in the following ways:

• When you fill out a form or provide us with your information, either on our website or any other platform, we include clear and noticeable language asking for your consent to receive marketing calls or text messages from us.
• Before submission, we provide a clear and understandable disclosure that, by providing your number and submitting the form, you are authorizing Alphascend Capital Group to send you marketing text messages or calls.
• Please note that ‘express written consent’ can be obtained through electronic means, including website forms, text messages, and email.

Opt-In or Opt-Out Options

Opt-In: Where applicable, investors may be provided with the option to opt-in to additional services or communications, such as newsletters, investment updates, or promotional content. Opting-in will be an active choice, requiring explicit consent.

Opt-Out: Investors have the right to opt-out of certain uses or sharing of their information, where applicable. This includes the right to unsubscribe from email communications or to request that their information not be shared with specific third parties. Instructions for opting out will be provided in relevant communications or may be requested by contacting our compliance department at connect@oilandgasinvestmentfunds.com.

Impact of Opting Out: Investors should understand that opting out of certain uses or sharing of information may impact the services available to them or the nature of their relationship with Alphascend Capital Group.

Alphascend Capital Group is dedicated to respecting your communication preferences and ensuring that we only contact you in accordance with your expressed wishes and applicable laws. If you have any questions about our compliance with TCPA, CAN-SPAM Act and other regulations or about your communication preferences, please do not hesitate to contact us.

CAN-SPAM Compliance

Alphascend Capital Group is committed to respecting and protecting your rights and privacy and therefore, strictly adheres to the requirements of the Controlling the Assault of Non-Solicited Pornography And Marketing (CAN-SPAM) Act. The CAN-SPAM Act is a law that sets rules for commercial emails, establishes requirements for commercial messages, and gives recipients the right to stop emails from being sent to them.

Here’s how we ensure compliance with the CAN-SPAM Act:

• Clear Identification: Our marketing emails are clearly identified as advertisements when required by law. We also ensure that our “From,” “To,” “Reply-To,” and routing information accurately reflect the business or individual initiating the email.
• Valuable Information: We always strive to provide valuable and desired content in our emails. Our goal is to share information that is helpful and relevant to you.
• Physical Address: We include our physical postal address in our emails so you know where we are.
• Opt-Out Mechanism: Every email we send includes an easy, clear, and conspicuous way to opt out of future emails. You’ll typically find this in the form of an ‘unsubscribe’ link at the bottom of our emails.
• Prompt Opt-Out: If you choose to opt-out or ‘unsubscribe’ from our emails, we honor your request promptly, as required by the CAN-SPAM Act. Once you have opted out, you will no longer receive promotional emails from us.

Please note, however, that even after opting out of marketing emails, you may continue to receive transactional or relationship-based emails from us, such as communication about an existing account or contracted services.

At Alphascend Capital Group, we take the protection of your personal information very seriously. We are committed to maintaining your trust by protecting the personal information we collect about you. If you have any questions about our compliance with the CAN-SPAM Act, or our email practices, please do not hesitate to contact us.

Sharing and Disclosure of Your Information

We at Alphascend Capital Group highly respect your privacy and the confidentiality of your personal information. We only disclose your information in certain situations and always in accordance with applicable laws and regulations. Here’s how and why we might share your information:

Consent to Collection, Use, and Sharing

Consent at Collection Point: By providing personal and financial information as part of the investment process, investors explicitly consent to the collection, use, and sharing of their information as outlined in this Privacy Policy. This includes the verification of accredited investor status as required under Rule 506(c), and where applicable, sharing information with third-party verification services.

Details of Use: The specific ways in which we may use investor information are detailed in previous sections of this Privacy Policy, including but not limited to evaluating investment opportunities, complying with legal and regulatory requirements, providing investor support, and optimizing our investment services.

Consent to Third-Party Sharing: Investors may also consent to the sharing of their information with selected third-party partners for purposes aligned with their investment interests. This sharing is subject to the restrictions and obligations defined in the “Confidentiality of Investor Information” section.

Withdrawal of Consent: Investors have the right to withdraw their consent to the collection, use, or sharing of their information at any time. Withdrawal of consent must be communicated in writing to Alphascend Capital Group at connect@oilandgasinvestmentfunds.com. Please note that withdrawal of consent may affect the provision of investment services, and Alphascend Capital Group will explain any such effects at the time of the withdrawal request.

How We Store and Protect Your Information

At Alphascend Capital Group, we take the protection of your personal data very seriously. We adopt industry-standard practices and security measures to prevent unauthorized access, use, disclosure, modification, or destruction of your data. Here is how we store and protect your information:

Data Storage: Your personal information is stored on our secure servers and on the servers of our trusted third-party service providers, which could be located worldwide. All data is stored in compliance with applicable laws and regulations of the respective jurisdictions.

Third-Party Service Providers

To offer you our services and to operate our business, we may share your personal data with our trusted third-party service providers. These service providers help us with various tasks such as, email dispatch, data analysis, marketing assistance, customer service, and so on.

Each of these third-party service providers has been selected by us for their ability to provide the necessary services to our standard and in compliance with applicable laws and regulations. When we employ another company to perform a function of this nature, we provide them with the information that they need to perform their specific function, which may include your personal data.

Retention of Investor Information

Retention Period

Defined Time Frame: At Alphascend Capital Group, we retain investor information for a period consistent with the applicable legal and regulatory requirements. Typically, this includes retaining the information for as long as your investment is active, plus a defined period thereafter to comply with legal obligations, resolve disputes, and enforce our agreements. For specific investments under Rule 506(c), the information will be retained for a certain period as required by law.

Ongoing Review: We regularly review the information we hold to ensure that it is retained for no longer than necessary for the purpose for which it was collected or as required by applicable laws and regulations.

Disposal or Deletion of Investor Information

Secure Disposal Procedures: Once the retention period has expired, we undertake secure disposal procedures to ensure that investor information is permanently deleted or destroyed. Physical records are securely shredded, and electronic records are deleted using secure deletion methods that render the data unrecoverable.

Third-Party Disposal: In cases where we engage third-party service providers for disposal, they are contractually obligated to comply with our secure disposal standards and provide certification of secure destruction.

Retention for Legal Purposes: In some cases, we may be required to retain certain information for longer periods due to legal or regulatory obligations. In these cases, the information will continue to be safeguarded and will be accessed only as necessary to meet those obligations.

Your Data Rights and Choices

As a user of our services at Alphascend Capital Group, you have certain rights concerning the personal information we hold about you under applicable data protection laws. Here is a summary of these rights and how you can exercise them:

• Right to Access: You have the right to request a copy of the personal information we hold about you. If you would like to request this information, please contact us using the contact details provided in this policy.
• Right to Rectification: If you believe that any of your personal information we have on record is incorrect or incomplete, you have the right to ask us to correct it. Please reach out to us with the updated information.
• Right to Erasure: Under certain circumstances, you have the right to request that we delete your personal information from our records. Please note that this right is not absolute and only applies in certain circumstances. We may be required to retain certain information for longer periods due to legal or regulatory obligations.
• Right to Restrict Processing: You have the right to request the restriction of processing your personal information in certain situations, such as if you contest the accuracy of the data or if you have objected to processing and we are considering whether our legitimate grounds override yours.
• Right to Data Portability: You have the right to receive the personal data we hold about you in a structured, commonly used, and machine-readable format, and have the right to transmit those data to another controller without hindrance from us.
• Right to Object: You have the right to object to our processing of your personal information based on our legitimate interests. We will comply with your request unless we have compelling legitimate grounds for processing that outweigh your interests, rights, and freedoms, or if we need to process the data for the establishment, exercise, or defense of legal claims.
• Right to Withdraw Consent: If we process your personal data based on your consent, you have the right to withdraw that consent at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.
• Right to Lodge a Complaint: You have the right to lodge a complaint with a supervisory authority if you believe that our processing of your personal information violates applicable data protection laws.

To exercise any of these rights, please contact us at connect@oilandgasinvestmentfunds.com with your request. We will respond to your request within a reasonable timeframe in accordance with applicable data protection laws. Please note that we may need to verify your identity before processing your request, and in some cases, we may need to collect additional information to fulfill your request.

We are committed to respecting your rights and choices about how your personal information is used. If you have any questions about these rights or if you need any assistance with exercising these rights, please don’t hesitate to contact us.

Links to Other Websites

Our Alphascend Capital Group website and our services may contain links to other websites that are not operated by us. These links are provided for your reference and convenience only and do not imply any endorsement of the activities of these third-party websites or any association with their operators.

This Privacy Policy applies only to the personal information that we collect through our services or as part of our business operations, or that you provide to us directly. Therefore, if you disclose your information to others, different rules may apply to their use or disclosure of the information you disclose to them. We do not control the privacy policies or practices of third parties.

Confidentiality of Investor Information

13. Commitment to Confidentiality

At Alphascend Capital Group, we recognize the importance of maintaining the confidentiality of our investors’ personal and financial information. We are committed to implementing stringent measures to protect this information, ensuring that it is handled with the highest degree of confidentiality, integrity, and security.

Circumstances Under Which Information May Be Disclosed

While we are committed to maintaining the confidentiality of investor information, there may be specific circumstances under which this information might be disclosed:

• Legal Requirements and Compliance: We may disclose investor information if required by law, regulation, or legal process, such as responding to subpoenas, regulatory requests, or other lawful requests.
• To Affiliated Entities: We may share investor information with our affiliated entities for the purpose of servicing your investment or to inform you about additional investment opportunities, consistent with applicable laws.
• To Service Providers: We may share information with third-party service providers engaged to perform services on our behalf, such as auditors, legal advisors, or verification agencies. These providers are contractually bound to maintain the confidentiality of the information.
• With Consent: We may disclose information to other third parties with your explicit consent or direction.

Changes to Your Personal Information

We believe in the importance of keeping your personal information accurate and up-to-date to provide you with the best possible service. To this end, we encourage you to promptly update your personal information if it changes or is inaccurate.

Here’s how you can update your information:

By Contacting Us: If you cannot update your information through your account, or if you prefer, you can contact us directly to request an update. Please reach out to us via the ‘Contact Us’ form on our website or send us an email at connect@oilandgasinvestmentfunds.com. Please include your name, email address, and detailed information about the change you want to make.

Acceptance of This Privacy Policy

By using our website and/or services, you signify your acceptance of this Privacy Policy. If you do not agree or are not comfortable with any part of this Policy, your only remedy is to discontinue use of our services.

Please understand that your continued use of our website or services after we publish or communicate a notice about any changes to this Privacy Policy means that the collection, use, and sharing of your personal data is subject to the updated Privacy Policy. 

Your access and use of our website and services are always subject to the most current version of our Privacy Policy at the time of such use.

If we make any material changes to this Privacy Policy that would lessen your privacy rights, we will provide a prominent notice on our website. It’s important that you review the Privacy Policy whenever we update it or at least every time you give us personal information.

We value your trust and are committed to protecting and respecting your privacy. If you have any questions about this Privacy Policy, please contact us at connect@oilandgasinvestmentfunds.com.

Contact Us

If you have any questions about this Privacy Policy, the practices of this site, or your dealings with this site, please contact us:

Company Name: Alphascend Capital Group

Address: 4870 Sadler Rd PMB# 0680, Suite 300,
                Richmond, VA 2306

Email: connect@oilandgasinvestmentfunds.com

We are committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using this website, then you can be assured that it will only be used in accordance with this privacy policy.

If you believe that any information we are holding on you is incorrect or incomplete, or if you would like to express any concerns or complaints about our privacy practices, please feel free to contact us. We will promptly correct any information found to be incorrect and address your concerns to the best of our ability.

We always welcome your feedback and suggestions about our Privacy Policy. We believe in constant improvement, transparency and accountability, and your feedback will help us serve you better in protecting your personal information.