Last Updated: 02/03/2026
 

Second Wave Partners LLC and its affiliates and subsidiaries (collectively, “Second Wave,” “we,” “us,” or “our”) welcome you. Our collection and use of information from visitors, prospective investors, members, and counterparties in connection with our website(s), communications, and investment activities (collectively, the “Services”) are subject to this Privacy Policy (the “Privacy Policy”).
 

By accessing or using our Services, submitting information to us, or participating in Second Wave–related offerings or processes, you agree that we may collect, use, and disclose your information in accordance with this Privacy Policy.

Our Services may contain links to content or services provided by third parties. This Privacy Policy does not apply to the practices of those third parties.

 

Collection, Use, and Retention of Personally Identifiable Information (PII)

Second Wave Network and Investment Activities
 

You may interact with Second Wave to learn about our investment activities, participate in diligence processes, apply for membership or inclusion in our investor network, or engage in secondary transactions facilitated by or associated with Second Wave.
 

We collect Personally Identifiable Information (“PII”) when it is voluntarily provided to us, including through emails, forms, onboarding processes, data rooms, calls, or third-party platforms we use in connection with our operations.

The PII we collect may include, but is not limited to:
 

• Name, nickname, and contact information (email address, phone number, postal address)

• Professional and biographical information

• Investor qualification information (e.g., accredited or qualified purchaser status)

• Tax identification numbers and banking information (where required)

• Investment preferences, transaction history, and portfolio-related information

• Information provided during diligence, onboarding, or compliance processes

• Optional demographic or diversity-related information, where voluntarily provided

• Information you provide about counterparties, sellers, or companies
   

We process this information to:
 

• Evaluate eligibility for participation in Second Wave–related opportunities

• Conduct diligence and compliance checks

• Facilitate secondary transactions, SPVs, and related investment activity

• Communicate with you regarding opportunities, transactions, and operational matters

• Maintain internal records and improve our Services

• Comply with legal, regulatory, and contractual obligations
   

Acceptance into any Second Wave network, opportunity, or transaction is at our sole discretion.

 

Access to PII by Second Wave Personnel
 

Second Wave personnel have access to PII only as necessary to perform their roles, including investor relations, operations, compliance, accounting, and transaction execution.
 

We use PII responsibly, including to:
 

• Complete transaction documentation

• Facilitate authorized wire or ACH transfers

• Manage compliance, tax, and reporting obligations
   

We maintain internal policies designed to prevent unauthorized access, disclosure, or misuse of PII. We do not sell PII you provide to us.

 

Cookies; Analytics Providers
 

We may collect information through cookies and similar technologies when you interact with our website(s) or online Services. Cookies are small data files stored on your device to improve functionality and understand usage patterns.

We may use first-party and third-party cookies, including analytics providers such as Google Analytics, to collect information about usage (e.g., IP address, browser type, operating system, referring pages, time spent, and interaction data).
 

By using our Services, you consent to such processing. You may disable cookies via your browser settings, though this may limit functionality.

 

Third-Party Service Providers and Onward Transfers
 

We engage third-party service providers to support our business operations, including but not limited to:
 

• Fund administration platforms

• Compliance and KYC/AML providers

• Accounting and tax advisors

• Legal counsel

• Data room and document management providers

• Analytics and communication tools
   

We share PII with such providers only as necessary for them to perform services on our behalf and subject to confidentiality obligations.
 

In the event of a merger, reorganization, dissolution, or sale of all or substantially all of our assets, PII may be transferred to a successor entity, subject to this Privacy Policy.

 

Disclosure to Public Authorities

We may disclose PII when required to do so by law, regulation, court order, subpoena, or governmental request, including for national security or law enforcement purposes.

 

Accessing Your Information and Your Choices

You may request access to, correction of, or updates to your PII by contacting us at operations@secondwaveinvestments.com.
 

You may opt out of non-essential communications by following unsubscribe instructions in emails. Service-related or transactional communications may still be sent.

 

How We Protect Your Information

Second Wave implements reasonable administrative, technical, and physical safeguards designed to protect PII against loss, misuse, unauthorized access, disclosure, alteration, or destruction.

No system is fully secure. We cannot guarantee the absolute security of information transmitted or stored electronically.

 

Information About Children

Our Services are not intended for individuals under the age of 13. We do not knowingly collect PII from children under 13.

 

Notices to California Residents

Second Wave does not sell personal information or disclose personal information for direct marketing purposes.

If Second Wave becomes subject to the California Consumer Privacy Act (CCPA) or other California privacy laws, this Privacy Policy will be updated accordingly.

 

Notices to Nevada Residents

Second Wave does not sell PII for monetary consideration. Nevada residents may submit requests regarding their information by emailing alberto@secondwaveinvestments.com with the subject “Nevada Privacy Request.”

 

Notices to Residents of Virginia, Colorado, Connecticut, and Utah

Second Wave is not currently subject to the comprehensive privacy laws of these states. If that changes, we will update this Privacy Policy accordingly.

 

International Users; Cross-Border Transfers

Second Wave operates in the United States. Information collected may be transferred to, processed, and stored in the United States or other jurisdictions where privacy laws may differ from those in your country.

Where required, we implement appropriate safeguards for international data transfers, including standard contractual clauses or other lawful mechanisms.

 

EEA and UK Residents

For purposes of the GDPR, UK GDPR, and applicable data protection laws, Second Wave acts as a data controller unless otherwise specified.
 

We process Personal Information on the following lawful bases:
 

• Performance of contractual or pre-contractual obligations

• Legitimate business interests not overridden by individual rights

• Compliance with legal obligations

• Consent, where required
   

EEA and UK residents may have the right to:
 

• Access Personal Information

• Correct inaccurate information

• Request deletion or restriction of processing

• Request data portability

• Lodge complaints with supervisory authorities
   

Requests may be submitted to operations@secondwaveinvestments.com. We aim to respond within one month, subject to lawful extensions.

 

Do Not Track

Second Wave does not currently respond to “Do Not Track” signals.

 

External Links

Our Services may link to third-party websites. We are not responsible for the privacy practices or content of those sites. Please review their policies before providing personal information.

 

Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Changes are effective upon posting. Continued use of our Services constitutes acceptance of any updates.

 

How to Contact Us

If you have questions about this Privacy Policy or our data practices, contact us at:

Second Wave Partners LLC
Email: operations@secondwaveinvestments.com