Legal

Privacy Policy

Last updated: June 13, 2026

Draft for review. This policy is a starting-point template that reflects how the 53 Peaks platform is built. It is not legal advice and has not been reviewed by counsel. Please have a qualified attorney review and finalize it before relying on it in production.

53 Peaks ("53 Peaks," "we," "us") provides a fund administration platform for investment managers and their service providers. This policy explains what information we handle, how we use it, and the choices available to you. It applies to our website and the 53 Peaks application.

1. Information We Handle

Account information — names, work email addresses, and credentials of fund-manager and reviewer users.
Fund & investor data — information our customers enter or import about their funds, investors (LPs), commitments, transactions, and books of record. This may include investor names, contact details, tax identifiers, and bank account details, which our customers provide as the data controllers.
Verification data — identity-verification (KYC/AML) information processed through our verification provider.
Connected-account data — read-only balances and transactions from financial accounts you connect (e.g., via Plaid) for monitoring and reconciliation.
Usage & security data — log data, IP addresses, and activity records kept for security, audit, and reliability.

2. How We Use Information

To provide and operate the platform — accounting, NAV, capital calls, distributions, reporting, and preparation of payment files.
To authenticate users, secure accounts, and maintain an audit trail.
To verify investor identities where our customers use that feature.
To communicate service, security, and account messages.
To meet legal, regulatory, audit, and tax obligations.

We do not sell personal information, and we do not use customer fund or investor data to train third-party models.

3. Sensitive Data & Security

Bank account numbers and tax identifiers are encrypted at rest. Access to the application is protected by authentication (with optional two-factor authentication for managers), least-privilege database roles, an append-only audit log, and encrypted transport (TLS). No system is perfectly secure, but we design controls to align with SOC 2 expectations.

4. How Information Is Shared

With your direction — reviewers (auditors, tax preparers) and investors you grant access receive scoped, read-only views you control.
Service providers (sub-processors) — infrastructure, identity verification, bank-data connectivity, and email delivery vendors that process data on our behalf under contract (see Section 6).
Legal — where required by law, regulation, or valid legal process.

53 Peaks never holds customer funds and never initiates payments. We prepare bank-ready payment files; the customer reviews and releases them in their own bank.

5. Data Retention

Because the platform maintains books and records subject to audit, tax, and regulatory retention rules, financial records and audit logs are retained for the periods required by applicable law and our customers' obligations, and certain regulated records are soft-deleted (retained, not erased) rather than hard-deleted. We retain other personal data only as long as needed for the purposes above.

6. Third-Party Sub-Processors

We rely on a small set of vendors to operate the platform, which may include cloud hosting, identity verification, bank-data connectivity, and transactional email. Each is engaged under terms requiring appropriate confidentiality and security. A current list is available on request.

7. Your Rights & Choices

Depending on your jurisdiction, you may have rights to access, correct, or delete personal information, or to object to certain processing. Because much of the data we handle belongs to our customers (who act as controllers), we will route many requests to the relevant customer. Contact us at the address below to exercise a right or ask a question.

8. International Data

We operate from the United States and process data there. If you access the platform from another region, you consent to processing in the United States.

9. Changes to This Policy

We may update this policy as the platform evolves. Material changes will be reflected by an updated "Last updated" date and, where appropriate, additional notice.

10. Contact

Questions about this policy can be sent to cole@53peaks.io.