Privacy Policy

Privacy Policy

Effective Date: February 2, 2026

1. Why We Collect Your Information

Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand our commitment to your data security.

2. Information We Collect

The types of personal information we collect and share depend on the product or service you have with us. This information can include:
● Identifiers: Social Security numbers, Tax ID numbers, and government-issued identification.
● Financial Data: Income, net worth, account balances, and wire transfer instructions (for ivestors).
● Credit Information: Credit scores, payment history, and transaction history (for Borrowers).
● Property Data: Mortgage loan details, property valuations, and forensic title reports.

3. How We Share Information

All financial companies need to share customers’ personal information to run their everyday business. In the table below, we list the reasons Ascent Capital chooses to share information:

Reasons we can share your personal information

Does Ascent Share?

Can you limit this?

Everyday Business Purposes: To process transactions, maintain accounts, respond to court orders/legal investigations, or report to credit bureaus.

Yes

No

Marketing Purposes: To offer our products and services to you.

Yes

Yes

Joint Marketing with other financial companies.

No

We don't share

Affiliates’ Everyday Business Purposes: Information about your transactions and experiences.

Yes

No

Affiliates’ Everyday Business Purposes: Information about your creditworthiness.

No

We don't share

Non-affiliates to market to you

No

We don't share

4. How We Protect Your Information

To protect your personal information from unauthorized access and use, we implement a comprehensive Written Information Security Program (WISP) that complies with the 2026 GLBA Safeguards Rule:
● Encryption: All sensitive data is encrypted both at rest and in transit.
● Access Controls: We utilize Multi-Factor Authentication (MFA) and the “Principle of Least Privilege” to restrict data access to authorized personnel only.
● Oversight: We perform regular risk assessments and require all third-party servicers to contractually guarantee equivalent security standards.

5. Your Rights & State-Specific Disclosures (Texas & National)

Ascent Capital is headquartered in Houston, Texas, and complies with the Texas Data Privacy and Security Act (TDPSA).
● Texas Residents: You have the right to request access to, correction of, or deletion of your personal data.
● Nationwide Operations: Regardless of your state of residence, we provide a uniform standard of protection. Federal law gives you the right to limit only (1) sharing for affiliates’ everyday business purposes—information about your creditworthiness; (2) affiliates from using your information to market to you; and (3) sharing for non-affiliates to market to you.

6. Changes to This Policy

We will provide you with a revised notice if our sharing practices change. As required by the FAST Act, we will provide an annual notice only if we have changed our policies or practices or if we share NPI with non-affiliated third parties outside of standard GLBA exceptions.

7. Contact Us to Limit Sharing

If you wish to limit our sharing or exercise your rights under the TDPSA:
Ascent Capital
555-555-5555
info@AscentCapitalFund.com