Effective: August 4, 2026 – Last Updated: August 4, 2026
Privacy Notice
Waterway Capital LLC and its affiliates (collectively “Waterway”) are committed to protecting the privacy of current and former investors and prospective investors we introduce to investment offerings, as well as former investors. In order to provide our financial services and facilitate investment opportunities, we collect personal information about you. The privacy of the information you provide to us is important, and we want to assure you that we are committed to protecting your privacy. This Privacy Notice describes the personal information we collect, how we use it, and when we may disclose it. We urge you to read this Privacy Notice, so that you will understand our commitment to you and to your privacy.
Information we may collect and use
In order to provide services to clients and develop new client relationships, we may collect the following:
- Information from you – We may collect personal information directly from you including: your name, mailing address, social Security number, date of birth, email address, telephone number, government- issued identification (such as driver’s license or passport), bank account information, information regarding your assets, income, net worth, and investment experience;
- Information about your transactions – We may keep information about your transactions with Waterway, for example, information regarding your investments and transactions involving the issuers or offerings we facilitate;
- Information from outside Waterway– We may also collect other information that may include information from publicly available sources, consumer reporting agencies, identification verification providers, or other third-party service providers, in order to qualify you for those offerings we represent.
How we treat your information
Waterway may share the information described above with our affiliated entities in order to help facilitate your transactions. Waterway will not share non-public personal information with non-affiliated, except for the purpose of processing transactions, obtaining services requested by the client or as required/permitted by law; accordingly, this Privacy Notice does not include an opt-out provision.
Because Waterway limits its sharing of nonpublic personal information as described above, it may qualify for the annual privacy notice exception under applicable law.
Data Security and Incident Response
Waterway maintains written policies and procedures to protect personal and customer information against unauthorized access, loss or misuse. These include physical, electronic, and procedural safeguards proportionate to the sensitivity of the information maintained. In the event of a data security incident affecting sensitive information, we have procedures to notify affected individuals as required by applicable laws and by SEC Regulation S-P, as amended in 2024, which requires broker dealers to provide timely notification of incidents involving sensitive customer information.
Your Rights: U.S. Residents
Depending on your state of residence, you may have rights under applicable U.S. state privacy law regarding your personal information, including rights to know, access, correct or request deletion of your data. For information about your rights or to submit a privacy request, contact award@waterwaycap.com or write to us at 699 Boylston Street, 8th Floor, Boston, MA 02116.
California Residents
If you are a California resident and believe you have rights under the California Consumer Privacy Act (CCPA) or California Privacy Rights Act (CPRA), please contact us at award@waterwaycap.com with your specific request. We will respond in accordance with applicable law.
Privacy Inquiries and Contact
For questions about this Privacy Policy, to exercise your data rights, or to report a privacy concern, contact us at: Waterway Capital LLC, Attn: Compliance, 699 Boylston Street, 8th Floor, Boston, MA 02116. Email: award@waterwaycap.com.
Updates to This Policy
We may update this Privacy Policy from time to time to reflect changes in our data practices or applicable law. The effective date at the top of this page reflects the most recent revision. We encourage you to review this policy periodically. Material changes will be reflected in an updated effective date.