Effective October 1, 2026
Privacy Policy
This policy explains how Northwind Capital Partners LLC ("Northwind", "we") collects, uses, shares and protects personal information about prospective clients, clients and visitors to this website, and the choices and rights you have.
1. Information we collect
| Category | Examples | Source |
|---|---|---|
| Identifiers and contact details | Name, email, phone, postal address, client reference number | You, our advisors |
| Government identifiers | Social Security number, passport, driver's licence, national ID numbers | You, during account opening |
| Financial information | Account and routing numbers, holdings, transactions, income and net worth | You, custodians, our systems |
| Verification results | Identity checks, sanctions and politically-exposed-person screening outcomes | Our identity verification provider |
| Website and device data | Cookies, IP address, pages visited | Your browser (see our Cookie Policy) |
2. How and why we use it
| Purpose | What it involves | Legal basis (UK/EU) |
|---|---|---|
| Account servicing | Opening and running your account, statements, answering requests | Contract |
| Know-your-customer and anti-money-laundering checks | Verifying identity and screening for fraud and sanctions. Automated checks run first; every flag is reviewed by a person before any decision. | Legal obligation |
| Trade execution and record-keeping | Executing instructions and keeping records regulators require | Legal obligation |
| Marketing communications | Market insights, newsletters and event invitations | Consent — you can withdraw any time |
| Sharing with custody and investment partners | Offering related services through our partners | Consent — you can withdraw any time |
You cannot opt out of account servicing, identity checks or regulatory record-keeping while you are a client, because we need them to provide the service and to meet the law. Marketing and partner sharing are always your choice.
3. Who we share it with
- Apex Custody Bank (United States) — holds client assets as our custodian.
- VerifyKYC Ltd (United Kingdom) — identity verification and sanctions screening on our behalf.
- Regulators and law enforcement — when the law requires it, for example anti-money-laundering reporting.
We do not sell your personal information for money. Some advertising cookies on this website may count as "sharing" under California law; you can turn them off with .
4. International transfers
When we send information to VerifyKYC Ltd in the United Kingdom, we protect it with Standard Contractual Clauses and a transfer impact assessment.
5. How long we keep it
We keep client records for five years after the relationship ends, as US securities rules require, and enquiry details from this website for up to two years if you do not become a client.
6. Your privacy rights and how to use them
Depending on where you live, you may have the right to:
- Access — get a copy of the personal information we hold about you.
- Correct — fix information that is wrong or incomplete.
- Delete — ask us to erase information, subject to legal record-keeping duties.
- Opt out of sale or sharing and limit the use of sensitive information (California).
- Object, restrict or port your data, and not be subject to solely automated decisions (UK and EU).
- Not be treated differently for using any of these rights.
To make a request, use our secure request form. We will confirm your email address, may ask for a copy of an identity document, and respond within the time the law allows (usually 30 to 45 days).
7. Your choices: communications and cookies
- Marketing and partner sharing — change these any time in the preference center.
- Cookies — non-essential cookies are used only with your choice. See the Cookie Policy or open .
8. Security
We use encryption, access controls and monitoring appropriate to financial data, and we limit access to people who need it for their job.
9. Contact us
Privacy Office, Northwind Capital Partners LLC, 400 Market Street, Suite 1200, San Francisco, CA 94105 · [email protected] · 1-800-555-0142.