PRIVACY POLICY
Privacy Notice
What we collect, why we collect it, and what you can ask us to do about it. This notice covers the NWX Invest website and the investor platform behind it. It is written to be read, not to be survived: what we collect, where it goes, how long it stays, and the requests you can make of us. Where a specific investment has its own privacy notice, that notice governs that investment and this one covers everything else.
Effective August 2026
Who we are, and what this notice covers
This website is published by NWX Invest LP, a Delaware limited partnership, whose general partner is NWX Management LLC of 1165 Northchase Pkwy SE, Suite 470, Marietta, GA 30067, United States. In this notice, "NWX", "we" and "us" mean those entities and the affiliates that operate the platform with them. For questions about anything below, write to info@nwxinvest.com.
This notice applies to nwxinvest.com, its Portuguese and Spanish versions, and the investor platform you reach after signing in. It does not apply to a site operated by someone else that you reach from a link here, and it does not replace the privacy notice supplied with the offering documents for a specific investment vehicle. Where the two differ about that vehicle, the offering notice governs.
Two relationships, two sets of information
Most people who read this are visitors. You arrive, read, and perhaps ask us for something. The information involved is small: what your browser reports, what you type into a form, and whether you accepted optional analytics.
A smaller number of people become investors, and that relationship is regulated. Verifying accredited status, meeting anti-money-laundering obligations and reporting to tax authorities all require documents that a website visitor would never be asked for. We have kept the two apart throughout this notice, because collapsing them produces the familiar and useless sentence in which a company may collect everything from everyone for any purpose.
Information you give us
When you submit a form on this site, we receive the fields you filled in. Our lead form collects your first and last name, email address, phone number, the interest you selected, and your confirmation that you agree to receive investment-related communications. Free-text fields are trimmed and length-limited before they are stored.
If you write to us, we keep the correspondence. If you apply to invest, the offering process collects considerably more, and it collects it because law or the fund's own documents require it rather than because we find it useful:
- Identity and contact details: legal name, date of birth, residential address, nationality, and a government-issued identification document.
- Verification of accredited status, which under Rule 506(c) cannot be a self-certification: income or net-worth evidence, or written confirmation from a licensed attorney, certified public accountant, registered broker-dealer or investment adviser.
- Tax identifiers and tax forms required to report your investment to the relevant authority.
- Banking and payment details used to receive your subscription and to pay distributions to you.
- Entity information where you invest through a company, trust or partnership, including its formation documents and the identity of the people who control or benefit from it.
Information collected automatically
Like any website, this one receives technical information from your browser simply because it has to in order to send you a page. Our servers and their logs record it, and the optional analytics described below add to it only after you have accepted them.
- Network and device data: IP address, browser and operating system, screen size, and language preference.
- Usage data: the pages you open, the order you open them in, how long you stay, and where you arrived from.
- Campaign attribution: the utm_source, utm_medium, utm_campaign, utm_content and utm_term values in a link you followed, and the Google Click Identifier (gclid) when you arrive from an advertisement.
- Your consent decision, stored in your own browser under the key nwx-consent so that we do not ask again on every page.
What we deliberately do not collect
Form fields are masked from session analytics: the forms on this site carry an instruction that keeps their contents out of any session recording, so what you type is delivered to us and not to a measurement tool. We do not ask for financial account information through this public website, and we ask you not to send account numbers, tax identifiers or scanned identity documents by ordinary email. We do not knowingly collect information from children, and we do not buy contact lists.
What happens if you do not give it to us
Most of this site works without telling us anything at all, and you are welcome to read it that way. Where a field is marked as required on a form, we cannot act on the request without it — we cannot send you material without an address to send it to. For an investment, the position is stricter and not ours to relax: without the identity, accreditation and tax information that securities and anti-money-laundering law requires, a subscription cannot be accepted, however much both sides would like it to be. If you would rather not provide something, ask us what it is for before deciding; sometimes the answer is that we do not actually need it.
Information from other sources
We may receive information about you from sources other than you: a referral from an existing investor or an adviser acting for you, a service provider that verifies accredited status or performs sanctions and anti-money-laundering screening, public registries and public filings, and advertising or analytics platforms that report which campaign brought a visitor to the site. Where a third party gives us information about you, it remains subject to this notice from the moment we hold it.
Your choices, and how to change them
The banner that appears on your first visit has two real options, and rejecting optional analytics is one of them. Your decision is remembered in your browser, and you can change it at any time through the "Privacy choices" button in the footer of every page — including changing it back. Clearing your browser's storage erases the decision, and the banner will ask again.
Controls in your own browser work regardless of what you told our banner: blocking cookies, blocking scripts, or installing Google's analytics opt-out add-on will each prevent collection. We do not currently claim to interpret Do Not Track headers, which browsers send with no agreed meaning; saying we honour a signal we do not act on would be worse than saying nothing. Our banner and your browser are the two controls that actually work here.
Why we use your information
We use what we hold for a short list of purposes, and not for others:
- To answer you: responding to a request, sending the material you asked for, and following up about it.
- To assess fit and eligibility, including verifying accredited investor status before any offering document is shared.
- To administer an investment: subscriptions, capital calls, distributions, reporting and investor communications.
- To operate and improve the site, understand which pages are read, and measure whether a campaign worked.
- To protect the platform: detecting fraudulent access, investigating misuse of the NWX name, and keeping audit records of administrative actions.
- To meet legal obligations: anti-money-laundering and sanctions screening, tax reporting, securities filings, and responding to lawful requests.
The legal bases we rely on
Where the GDPR, the UK GDPR or Brazil's LGPD applies to you, we rely on your consent for optional analytics and for marketing messages, which you may withdraw at any time; on the necessity of processing to enter into or perform a contract with you, which covers everything involved in subscribing to and administering an investment; on our legal obligations, which is what compels the identity, tax and anti-money-laundering processing; and on our legitimate interests in operating, securing and improving the business, where we have satisfied ourselves that those interests do not override your rights. If you want to know which basis applies to a particular use, ask and we will tell you.
Automated decisions
We do not make decisions that produce legal or similarly significant effects about you by automated means alone. AI is used inside NWX to organise research, summarise documents and support service work. It does not decide whether you are eligible, approve a transaction, move money, or send you a communication on its own; a person is accountable for each of those, and the platform is built so that no automated account can complete one. The security page explains the controls that enforce this.
Selling and sharing for advertising
We do not sell personal information for money, and we never have. Two things deserve a straight answer rather than that sentence alone. First, if you accept optional analytics and advertising cookies, information about your visit is shared with Google for measurement and advertising purposes, and some United States privacy laws — California's among them — treat that as "sharing for cross-context behavioural advertising" whether or not money changes hands. Rejecting optional analytics stops it. Second, we do not disclose investor information to anyone for their own marketing.
Where your information goes
NWX is based in the United States and our systems run in United States regions of Google Cloud. If you are in Brazil, the European Union, the United Kingdom or elsewhere outside the United States, the information you give us is transferred to and processed in the United States, whose data protection laws differ from those of your own country. Where the GDPR or the LGPD requires a transfer mechanism, we rely on Standard Contractual Clauses or the equivalent instrument in our contracts with the providers involved.
How long we keep it
We keep information for as long as the purpose it was collected for still exists, and then for as long as the law tells us to. Enquiries that do not become relationships are reviewed and removed once they are no longer live. Marketing contacts stay until you unsubscribe, after which we retain the minimum record needed to honour your unsubscribe. Investor records are kept for the life of the investment and for the retention period that securities, tax and anti-money-laundering rules impose afterwards, which is measured in years and is not ours to shorten. Analytics data is retained on the schedule set inside the analytics platform.
How we protect it
Encryption in transit and at rest, access granted by role and logged, and a second person required for anything that moves money or changes an investor's position. The security page sets this out in full, along with the things NWX will never ask you for — a password, or new wire instructions by email — which is the part that protects you against people who are not us.
Aggregated and anonymised information
Some of what we produce from this data is no longer about you: counts of how many people opened a page, which campaigns performed, how long a document is typically read for. Once information has been aggregated or anonymised so that it can no longer identify you, and cannot reasonably be re-identified, we use and retain it without the restrictions in this notice, because there is no longer a person in it to protect. We do not attempt to re-identify anonymised data, and we do not permit our providers to.
If something goes wrong
If a security incident affects your personal information, we will investigate it, contain it, and notify you and the relevant authority where the law requires it and within the period the law sets — 72 hours to a supervisory authority under the GDPR, without unreasonable delay under state law in the United States. We will tell you what happened, what information was involved, and what you should do, in that order. We will not delay a notification in order to establish who is to blame first. The security page describes the controls intended to make this section unnecessary.
Your rights
Depending on where you live, some or all of the following apply to you. We do not require you to be in a particular place to ask; where we can honour a request for anyone, we do:
- Know what we hold about you, and get a copy of it.
- Correct information that is wrong or incomplete.
- Delete information, where no legal obligation requires us to keep it.
- Withdraw consent you previously gave, including for analytics and marketing, without affecting what was lawful before you withdrew it.
- Object to or restrict processing based on legitimate interests.
- Receive your information in a portable, machine-readable form, or have it sent to another controller.
- Opt out of the sharing described above, and not be treated differently for having done so.
- Complain to your supervisory authority — the ANPD in Brazil, your national authority in the EU, the ICO in the United Kingdom — without going through us first.
How to exercise a right
Write to info@nwxinvest.com and say what you want. We will confirm receipt, and we will verify that the request really comes from you before we act on it — for an investor record, by a method we already use with you, never by asking you to send identity documents to an address that contacted you. We respond within the period the applicable law sets, which is one month under the GDPR and forty-five days under California law, and we will tell you if we need longer and why. An authorised agent may act for you with written proof of the authority. If we cannot do what you asked, we will say so and explain which obligation prevents it.
Marketing, and how to stop it
We send investment-related communications only to people who asked for them, which is what the consent checkbox on our forms records. Every marketing email carries an unsubscribe link that works immediately and without a reason. Unsubscribing stops marketing; it does not stop the operational messages an existing investor needs to receive, such as statements, capital calls and notices about their own investment, because those are part of the investment rather than promotion of it.
Children
This website is directed at adults, and the investments described on it are available only to verified accredited investors. We do not knowingly collect information from anyone under 18. If you believe a child has given us information, write to info@nwxinvest.com and we will delete it.
Changes to this notice
We update this notice when what we do changes, and the effective date at the top tells you which version you are reading. If a change materially affects how we use information you have already given us, we will do more than change the date: we will say so, by email where we hold your address or by a notice on the site. Continuing to use the site after a change means the current version applies to your use of it.
How to reach us
Write to info@nwxinvest.com, or to NWX Invest LP, c/o NWX Management LLC, 1165 Northchase Pkwy SE, Suite 470, Marietta, GA 30067, United States. Mark privacy questions as such and they will reach the right person faster. If your question is about what is and is not being offered on this site rather than about your information, the Important Notice answers it.