These Terms of Service (the "Terms") constitute a legally binding agreement between you ("User," "you," or "your") and Alphaneo LLC ("Alphaneo," "we," "us," or "our"), a Delaware limited liability company. These Terms govern your access to and use of the Alphaneo platform, including all associated websites, mobile applications, data feeds, tools, and services (collectively, the "Platform").
By accessing or using the Platform, you represent that you have read, understood, and agree to be bound by these Terms in their entirety. If you do not agree to these Terms, you must immediately discontinue your use of the Platform. Alphaneo reserves the right to modify these Terms at any time; continued use of the Platform after notice of modification constitutes acceptance of the revised Terms.
Access to investment opportunities on the Platform is restricted exclusively to "accredited investors" as defined under Rule 501(a) of Regulation D promulgated under the Securities Act of 1933, as amended (the "Securities Act"). You must satisfy at least one of the following criteria to be eligible:
By registering on the Platform, you represent and warrant that you qualify as an accredited investor and that you will maintain such qualification for the duration of your use. Alphaneo reserves the right to verify your accredited investor status at any time and to suspend or terminate your account if you fail to maintain eligibility.
To access investment opportunities on the Platform, you must complete a registration process that includes identity verification (KYC) and accredited investor verification (AML). Alphaneo uses Persona Identity, Inc. and other third-party service providers to conduct verification in compliance with applicable law.
You agree to provide accurate, current, and complete information during the registration process and to promptly update such information if it changes. You are solely responsible for maintaining the confidentiality of your account credentials and for all activities that occur under your account. You agree to notify Alphaneo immediately at legal@alphaneo.ai of any unauthorized use of your account.
Alphaneo reserves the right to refuse registration, suspend, or terminate any account at its sole discretion, including for failure to complete verification, provision of false information, or suspected violation of these Terms or applicable law.
The Platform provides a technology-enabled marketplace that facilitates access to private market investment opportunities, including primary rounds, secondary transactions, and co-investment vehicles. Alphaneo is not a registered investment adviser under the Investment Advisers Act of 1940, nor is it a registered broker-dealer under the Securities Exchange Act of 1934.
Alphaneo acts solely as a facilitator and technology platform. We do not provide personalized investment advice, manage assets on your behalf, or recommend specific securities or investment strategies tailored to your individual circumstances. The availability of any investment opportunity on the Platform does not constitute an endorsement, recommendation, or representation that such investment is suitable for you.
All investment decisions are made solely by you. You are encouraged to consult with licensed financial advisors, attorneys, and tax professionals before making any investment decision. Nothing on the Platform constitutes an offer to sell or a solicitation of an offer to buy any security except through a definitive offering document provided in connection with a specific offering.
Alphaneo and its affiliates may charge fees in connection with the investment opportunities and vehicles offered through the Platform. Depending on the opportunity, these may include management fees, carried interest, vehicle formation or administration fees, and platform or transaction fees. Fee structures are not uniform and vary by opportunity and vehicle type.
The specific fees applicable to any investment are set out in the definitive offering documents for that opportunity — for example, the operating agreement, subscription agreement, side letter, or private placement memorandum — which control. You should review those documents carefully before committing capital. Fees are generally non-refundable once a transaction has completed, and additional service fees may apply and will be disclosed prior to the applicable transaction.
Nothing contained on the Platform, including analyst scores, company profiles, research summaries, financial projections, market data, or other content, constitutes investment advice, legal advice, tax advice, or any other professional advice. Analyst scores and research content are provided for informational purposes only and reflect the opinions of Alphaneo's research team at the time of publication; they are subject to change without notice and should not be relied upon as the sole basis for any investment decision.
Past performance of any investment or investment category described on the Platform is not indicative of future results. Forward-looking statements and projections involve known and unknown risks, uncertainties, and other factors that may cause actual results to differ materially from those expressed or implied.
Investing in private market securities involves significant risks, including the risk of total loss of your investment. Private securities are illiquid, are not listed on public exchanges, and may be subject to transfer restrictions that limit or prevent your ability to sell or otherwise dispose of them. Investment returns are not guaranteed and may be negative.
A complete description of the material risks associated with investments available on the Platform is set forth in our Risk Disclosures, which are incorporated herein by reference. You should read the Risk Disclosures carefully before making any investment decision. Additional risk factors specific to each offering are described in the applicable offering documents.
You agree that you will not, directly or indirectly, engage in any of the following activities in connection with the Platform:
Violation of any provision of this Section may result in immediate termination of your account and may be reported to relevant regulatory authorities.
The Platform and all content, features, and functionality thereof, including but not limited to all text, graphics, logos, user interface designs, analyst research, scorecard methodologies, software, and data compilations, are owned by Alphaneo or its licensors and are protected by United States and international copyright, trademark, patent, trade secret, and other intellectual property laws.
Alphaneo grants you a limited, non-exclusive, non-transferable, revocable license to access and use the Platform for your personal, non-commercial investment purposes strictly in accordance with these Terms. You may not reproduce, distribute, modify, create derivative works of, publicly display, publicly perform, republish, download, store, transmit, or commercially exploit any content from the Platform without Alphaneo's prior written consent. Any feedback, suggestions, or ideas you provide regarding the Platform may be used by Alphaneo without restriction or compensation to you.
You agree to indemnify, defend, and hold harmless Alphaneo and its affiliates, directors, officers, employees, agents, licensors, and service providers from and against any and all claims, liabilities, damages, judgments, awards, losses, costs, expenses, and fees (including reasonable attorneys' fees) arising out of or relating to: (a) your violation of these Terms; (b) your use of the Platform; (c) any investment decision made by you; (d) your misrepresentation of your status as an accredited investor; or (e) your violation of any applicable law or the rights of any third party.
Alphaneo reserves the right, at your expense, to assume the exclusive defense and control of any matter for which you are required to indemnify Alphaneo. You agree to cooperate fully with Alphaneo's defense of such claims and not to settle any matter without Alphaneo's prior written consent.
Any dispute, controversy, or claim arising out of or relating to these Terms or the breach, termination, or validity thereof shall be finally settled by binding arbitration administered by the American Arbitration Association ("AAA") in accordance with its Commercial Arbitration Rules then in effect. The arbitration shall be conducted in Wilmington, Delaware, before a single arbitrator with experience in securities and commercial law. Judgment on the award rendered by the arbitrator may be entered in any court having jurisdiction thereof.
These Terms and any dispute arising hereunder shall be governed by and construed in accordance with the laws of the State of Delaware, without regard to its conflict of laws principles. The Federal Arbitration Act governs the interpretation and enforcement of this arbitration provision.
Class Action Waiver: YOU AND ALPHANEO AGREE THAT EACH MAY BRING CLAIMS AGAINST THE OTHER ONLY IN YOUR OR ITS INDIVIDUAL CAPACITY AND NOT AS A PLAINTIFF OR CLASS MEMBER IN ANY PURPORTED CLASS OR REPRESENTATIVE PROCEEDING. No arbitrator shall have authority to consolidate more than one person's claims or preside over any form of a class proceeding.
You may opt out of the arbitration agreement by providing written notice to legal@alphaneo.ai within thirty (30) days of first accepting these Terms. Opting out will not affect any other provision of these Terms.
Alphaneo reserves the right to modify these Terms at any time. We will provide notice of material changes by posting the revised Terms on the Platform with an updated "Last updated" date, and, where practicable, by email notification to your registered address. Your continued use of the Platform after the effective date of any modification constitutes your acceptance of the revised Terms.
If any provision of these Terms is held by a court of competent jurisdiction to be invalid, illegal, or unenforceable, the remaining provisions shall continue in full force and effect. The failure of Alphaneo to enforce any right or provision of these Terms shall not constitute a waiver of such right or provision.
For legal inquiries regarding these Terms of Service, please contact us at:
We aim to respond to all legal inquiries within five (5) business days. For urgent matters involving potential fraud or unauthorized account activity, please indicate "URGENT" in your subject line.
Alphaneo collects information necessary to verify your identity, assess your eligibility as an accredited investor, facilitate investment transactions, and comply with applicable law. The categories of information we collect include:
We use the information we collect for the following purposes:
Alphaneo does not sell, rent, or trade your personal information to third parties for their own marketing purposes. We may share your information in the following limited circumstances:
Alphaneo implements industry-standard technical and organizational measures to protect your information against unauthorized access, disclosure, alteration, and destruction. Specifically: all data stored at rest is encrypted using AES-256 encryption; all data transmitted between your browser and our servers is protected using TLS 1.3 or higher; access to personal and financial data is restricted to authorized personnel on a need-to-know basis and subject to multi-factor authentication requirements.
We conduct regular security assessments and penetration tests to identify and remediate vulnerabilities. Notwithstanding these measures, no data transmission over the internet or electronic storage system is 100% secure. You use the Platform at your own risk and are encouraged to use a strong, unique password for your account and to enable multi-factor authentication.
Alphaneo retains your personal and financial information for a minimum of seven (7) years following the closure or termination of your account. This retention period is required to comply with SEC recordkeeping requirements under Rule 17a-4, IRS record retention obligations, and applicable state securities laws.
Certain categories of information may be retained for longer periods if required by applicable law, regulation, or a pending legal or regulatory proceeding. We may also retain anonymized and aggregated data for analytical purposes indefinitely. Upon the expiration of the applicable retention period, we will securely delete or anonymize your personal information in accordance with our data destruction policy.
Subject to applicable law and the retention obligations described above, you have the following rights regarding your personal information:
Requests will be processed within thirty (30) days of receipt. We may require identity verification before processing any access, correction, or deletion request.
If you are located in the European Economic Area (EEA) or the United Kingdom (UK), the processing of your personal data by Alphaneo LLC is governed by the EU General Data Protection Regulation (GDPR) and the UK GDPR, as applicable. This section supplements the Privacy Policy above and sets out the additional rights and disclosures that apply to EEA and UK residents.
Legal Bases for Processing. We rely on the following legal bases to process your personal data:
Your GDPR / UK GDPR Rights. In addition to the rights described in Section 06, EEA and UK residents have the following rights, exercisable by contacting privacy@alphaneo.ai:
International Data Transfers. Alphaneo is incorporated in Delaware, USA. Your personal data is stored and processed in the United States, which the European Commission has not designated as providing an adequate level of data protection. Where we transfer personal data from the EEA or UK to the US, we rely on the EU Standard Contractual Clauses (SCCs) adopted by the European Commission (Decision 2021/914) and the UK International Data Transfer Agreement (IDTA), as applicable. Copies of the relevant SCCs or IDTA may be requested by contacting privacy@alphaneo.ai.
Supervisory Authority. If you are located in the EEA, you have the right to lodge a complaint with the supervisory authority in your EU member state of habitual residence, place of work, or the place of the alleged infringement. A list of EU supervisory authorities is available at edpb.europa.eu. If you are in the UK, you may contact the Information Commissioner's Office (ICO) at ico.org.uk. We would, however, encourage you to contact us at privacy@alphaneo.ai in the first instance so we have an opportunity to address your concerns directly.
Data Protection Contact. For all GDPR- and UK GDPR-related inquiries, including requests to exercise your rights and questions about our legal bases for processing, please contact: privacy@alphaneo.ai. We aim to respond within 30 days of receipt.
If you are a California resident, the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA), grants you specific rights regarding your personal information. This section supplements the Privacy Policy above and applies solely to California residents.
Categories of Personal Information Collected. In the past twelve months, we have collected the following categories of personal information (as defined by the CCPA):
We Do Not Sell or Share Your Personal Information. Alphaneo does not sell your personal information to third parties for monetary consideration, and does not share your personal information with third parties for cross-context behavioral advertising, within the meaning of the CCPA. You therefore need not submit an opt-out request. If our practices change in the future, we will update this policy and provide required disclosures before doing so.
Your California Rights. As a California resident, you have the following rights, subject to certain exceptions:
How to Submit a California Rights Request. To submit a verifiable consumer request, contact us at privacy@alphaneo.ai with the subject line "CCPA Rights Request." You may also designate an authorized agent to submit a request on your behalf; authorized agents must provide written authorization signed by you and may be required to verify their authority before we process the request. We will respond within 45 days of receiving a verifiable request; complex requests may receive a 45-day extension with prior notice. We may require you to verify your identity before processing a request.
California "Shine the Light" Law. Under California Civil Code § 1798.83, California residents who provide personal information in obtaining products or services for personal, family, or household use are entitled to request disclosure of the categories of personal information shared with third parties for their own direct marketing purposes. Alphaneo does not share personal information with third parties for direct marketing purposes, so no such disclosure is required.
The Platform uses two categories of cookies: (1) Essential Cookies, which are strictly necessary for Platform functionality, including maintaining your login session, remembering your preferences, and ensuring security; and (2) Analytics Cookies, which we use to understand how users interact with the Platform, identify areas for improvement, and measure the effectiveness of our features. Analytics cookies are provided by third-party analytics services and do not contain personally identifiable information.
You may disable cookies through your browser settings. Disabling essential cookies may impair your ability to use the Platform, including preventing you from logging in or completing transactions. Disabling analytics cookies will not affect your core Platform experience. We do not use advertising or cross-site tracking cookies.
For privacy-related inquiries, including requests to exercise your rights, questions about our data practices, or concerns about how your information is being used, please contact our privacy team at:
The investments available on the Alphaneo platform involve substantial risk, including the risk of complete loss of your invested capital. These are not suitable investments for all investors, and you should invest only capital you can afford to lose entirely.
Private market securities differ fundamentally from publicly traded securities in their liquidity profile, disclosure obligations, regulatory oversight, and investor protections. You should read these Risk Disclosures carefully and in their entirety, and consult with qualified legal, financial, and tax advisors before making any investment decision. Nothing in these disclosures is exhaustive; additional risks specific to each offering are described in the applicable offering documents.
Private company investments are speculative in nature. A significant majority of early-stage and growth-stage private companies fail to achieve the financial milestones necessary to generate returns for investors, and many are wound down with little or no return of investor capital.
Unlike publicly traded equities, private company securities are not subject to the same ongoing disclosure and reporting requirements, making it difficult to monitor the financial health of your investment in real time. You should assume that any investment made through the Platform could decline to zero and should size your positions accordingly.
Private market securities are highly illiquid. There is no established public market for these securities, and there can be no assurance that a secondary market will develop or that you will be able to sell your investment at a price that reflects its fundamental value, or at all.
Transfer of private securities is typically subject to contractual restrictions set forth in the company's charter documents, stockholder agreements, and right-of-first-refusal provisions. Even where secondary transactions are facilitated through the Platform, execution is not guaranteed, and transaction timelines may be extended. Investors should treat all private market investments as potentially permanent commitments.
Investments in private companies typically require holding periods of five to ten years or more before a liquidity event — such as an IPO, strategic acquisition, or secondary tender offer — may occur. There is no guarantee that any such liquidity event will occur within your expected investment horizon, or at all.
During the holding period, your capital will be unavailable for other uses, and you will receive no current income unless the investment specifically provides for distributions. Changes in your personal financial circumstances during a multi-year holding period may be difficult or impossible to accommodate given the illiquid nature of these investments.
Private companies routinely raise additional capital through subsequent rounds of financing, which may result in the issuance of new equity securities and consequent dilution of your ownership percentage. Future financing rounds may also be conducted at valuations lower than the round in which you invested, resulting in both dilution and mark-to-market losses.
Anti-dilution protections, if any, vary by share class and are subject to negotiation among existing investors. Common stockholders and holders of SPV interests with limited negotiating leverage may have weaker anti-dilution protections than lead institutional investors. You should review the capitalization table and rights of each share class carefully before investing.
Private companies are not required to file periodic reports with the SEC and are not subject to the same financial disclosure requirements as public companies. As a result, the information available to you about a company's financial condition, operations, and prospects may be limited, incomplete, or out of date at the time you make your investment decision.
Alphaneo's analyst research is based on information provided by the companies themselves and publicly available sources; it is not independently audited and may not capture all material risks. You should conduct your own due diligence and not rely solely on information provided through the Platform before making any investment decision.
The success of a private company investment is often highly dependent on the skills, judgment, and continued involvement of its founders and key management personnel. The loss of one or more key executives through departure, illness, or other circumstances could have a material adverse effect on the company's operations and prospects.
Management teams of early-stage companies may lack experience in managing a scaling organization or navigating a complex regulatory environment. Strategic decisions made by management, including capital allocation, product direction, and hiring, may prove incorrect or suboptimal in ways that impair the value of your investment.
The valuations assigned to private companies at the time of an offering are determined through negotiation between the company and its investors and may not reflect the intrinsic value or future prospects of the business. Valuations for early-stage companies are inherently speculative and may be based on projections that do not materialize.
Unlike public market valuations, which are continuously updated through trading activity, private company valuations are only updated at subsequent financing rounds or in connection with secondary transactions. The absence of a continuous market price means that reported valuations may be stale and may not reflect adverse developments that have occurred since the last financing round.
The regulatory environment governing private securities offerings, digital platforms, and emerging industries is subject to change. New laws, regulations, or regulatory interpretations could increase compliance costs for the companies in which you invest, restrict their ability to operate in certain markets, or adversely affect their competitive position.
Alphaneo's ability to continue operating as a platform may also be affected by changes in securities laws or regulations governing exempt offerings, investment platforms, or related financial services. Any such changes could impair your ability to access secondary markets or receive reporting about your investments through the Platform.
Secondary market transactions facilitated through the Platform are subject to significant restrictions. Most private company equity is subject to a right of first refusal (ROFR) in favor of the company or existing stockholders, which may prevent or delay the transfer of your shares to a third-party buyer, even if you have identified a willing buyer at an agreed price.
Additional transfer restrictions may be imposed by the company's charter documents, stockholder agreements, or SPV governing documents. Secondary transactions may require consent from the company's board of directors or a majority of existing stockholders. Even where Alphaneo facilitates the listing of secondary interests, there is no guarantee of execution, and bids may not be available at prices you consider acceptable.
Investments made through the Platform are not bank deposits and are not insured or guaranteed by the Federal Deposit Insurance Corporation (FDIC), the Securities Investor Protection Corporation (SIPC), or any other government agency or insurance program. You could lose the entire amount of your investment without any recourse to insurance or government protection.
The Platform is not a bank, broker-dealer, or registered investment adviser. No investor protection or compensation scheme applies to your investments in private securities through the Platform. Alphaneo's own financial condition should not be confused with or relied upon as a guarantee of the performance of any investment offered through the Platform.
Investments in private companies, particularly through pass-through entities such as limited partnerships or LLCs structured as investment vehicles, may generate complex tax reporting obligations. Investors in such vehicles typically receive a Schedule K-1 reflecting their share of income, gains, losses, deductions, and credits, which may require filing in multiple states and can complicate your personal tax return.
Certain investments may qualify for favorable tax treatment under the Qualified Small Business Stock (QSBS) provisions of Section 1202 of the Internal Revenue Code, which may allow exclusion of up to 100% of gain on the sale of qualifying stock held for more than five years. QSBS eligibility is subject to specific requirements and limitations and should not be assumed without advice from a qualified tax advisor. Alphaneo does not provide tax advice, and you should consult your own tax counsel regarding the specific tax implications of any investment before committing capital.
The Alphaneo platform is operated by Alphaneo LLC, which owns the platform technology, research, and intellectual property. Investment vehicles offered through the platform are or will be managed by an Alphaneo affiliate acting as manager and/or general partner. These entities are under common ownership and control, and Alphaneo LLC provides technology and research services to the manager under an intercompany arrangement for which it is compensated.
These affiliations create conflicts of interest between Alphaneo and investors. The manager and its affiliates are compensated through management fees, carried interest, vehicle formation or administration fees, and platform or transaction fees, and therefore have a financial incentive in whether and how an opportunity is pursued, structured, and closed — incentives that may not always align with the interests of any individual investor. Alphaneo may also hold its own financial interest in the companies or vehicles presented. Research, scoring, and related materials are produced by an affiliated party and do not constitute independent investment advice. You should evaluate each opportunity, together with its fees and conflicts, on the basis of the definitive offering documents, which control.
Materials provided through the platform — including research, company summaries, market maps, and opportunity descriptions — may contain forward-looking statements regarding anticipated performance, development timelines, market opportunities, regulatory pathways, and financial projections. These statements are based on current expectations and assumptions and are subject to significant risks and uncertainties that could cause actual results to differ materially, including delays in development or certification, technical and execution challenges, changes in markets or regulation, availability of financing, and general economic conditions.
Forward-looking statements speak only as of the date made, and Alphaneo undertakes no obligation to update them except as required by law. Certain information may be provided by third parties or the subject companies, has not been independently verified, and should not be relied upon as a guarantee of future performance or outcomes. Do not place undue reliance on forward-looking statements.
Certain opportunities may involve companies developing defense, dual-use, or other technology subject to U.S. export controls, including the International Traffic in Arms Regulations (ITAR) and the Export Administration Regulations (EAR). Confidential or controlled information relating to such companies must not be shared with, or exported to, any foreign person or destination in violation of applicable law. By accessing such materials, you agree to comply with all applicable U.S. export control laws and restrictions.
Investment offerings facilitated through the Alphaneo platform are conducted in reliance upon the exemption from registration provided by Section 4(a)(2) of the Securities Act of 1933, as amended, and Rule 506(c) of Regulation D promulgated thereunder by the Securities and Exchange Commission (SEC). These offerings are not registered with the SEC and are not subject to the disclosure or other requirements that apply to registered securities offerings.
Because these offerings are made under an exemption from registration, investors do not receive the protections afforded by a registered offering, including SEC review of the offering documents, mandatory prospectus disclosure, or the rights and remedies available under Sections 11 and 12(a)(2) of the Securities Act. You should review all offering documents carefully and consult qualified legal counsel before investing.
Under Rule 501(a) of Regulation D, an "accredited investor" includes individuals and entities meeting any of the following criteria:
Rule 506(c) requires that issuers and platforms take reasonable steps to verify that all purchasers of securities qualify as accredited investors. Alphaneo uses the following verification methods, consistent with SEC guidance under Rule 506(c) and the SEC's Compliance and Disclosure Interpretations:
Alphaneo will not process any investment commitment until accredited investor verification has been satisfactorily completed. Verification is valid for twelve (12) months; reverification will be required for subsequent investment commitments made after the expiration of the verification period.
Offerings conducted under Rule 506(c) are expressly permitted to involve general solicitation and general advertising, including through public websites, social media, and advertising. This represents a key distinction from offerings conducted under Rule 506(b), which prohibit general solicitation but permit up to 35 non-accredited-investor purchasers.
Because the Alphaneo Platform is publicly accessible and describes available investment opportunities to the general public, all offerings made through the Platform are conducted under Rule 506(c). As a consequence, all purchasers of any security offered through the Platform must be verified accredited investors; no exceptions are available for sophisticated but non-accredited purchasers. Alphaneo will not permit any investment commitment by any person who has not completed and passed the accredited investor verification process.
Neither the SEC nor any state securities regulator has approved, disapproved, or reviewed the merits of any offering made through the Platform. The SEC has not reviewed or passed upon the adequacy or accuracy of any offering document, financial projection, analyst report, or other material published on the Platform. Any representation to the contrary is a criminal offense.
Issuers conducting Rule 506(c) offerings are required to file a Form D with the SEC no later than fifteen (15) calendar days after the first sale of securities in the offering. Alphaneo requires all issuers to confirm that a Form D has been filed or will be filed within the required period as a condition of listing on the Platform. Copies of Form D filings are publicly available through the SEC's EDGAR database.
Certain offerings on the Platform may be restricted to "qualified purchasers" as defined in Section 2(a)(51) of the Investment Company Act of 1940. A qualified purchaser is an individual who owns not less than $5,000,000 in investments, a family-owned company that owns not less than $5,000,000 in investments, a trust that is not formed for the specific purpose of acquiring the offered securities and whose trustee or grantor is a qualified purchaser, or an entity (other than a trust) acting for its own account or for the accounts of other qualified purchasers, that in the aggregate owns and invests on a discretionary basis not less than $25,000,000 in investments.
The qualified purchaser distinction is relevant because investment companies relying on Section 3(c)(7) of the Investment Company Act may have no limit on the number of beneficial owners, provided all such owners are qualified purchasers. Offerings designated as "QP-only" on the Platform are available solely to investors who have completed both accredited investor verification and qualified purchaser verification.
Securities offered under Rule 506 of Regulation D are "covered securities" under Section 18(b)(4)(D) of the Securities Act, which means they are exempt from state securities registration (also known as "blue sky") requirements. States are preempted from requiring registration of covered securities but retain authority to investigate and bring enforcement actions for fraud, require notice filings, and collect fees.
Issuers conducting Rule 506(c) offerings are generally required to file Form D (or a similar notice form) with the securities regulator in each state where sales are made, along with any applicable filing fees. Alphaneo requires all listed issuers to represent that they are aware of and intend to comply with applicable state notice filing requirements as a condition of listing. Investors are encouraged to consult counsel regarding the securities laws of their state of residence.
Securities acquired in offerings conducted under Rule 506(c) are "restricted securities" as defined in Rule 144 under the Securities Act. Restricted securities may not be resold in the public markets without registration or an applicable exemption from registration. The most commonly relied-upon exemption is Rule 144, which generally requires that restricted securities be held for a minimum of one year prior to resale in any public market transaction (the "holding period"), and imposes additional conditions including volume limitations, manner of sale requirements, and current public information requirements.
In addition to federal resale restrictions, private company securities are subject to contractual transfer restrictions contained in the company's stockholder agreements, right-of-first-refusal provisions, and lock-up agreements. These contractual restrictions may be more stringent than, and operate independently of, the federal securities law restrictions described above. Investors should review all applicable transfer restriction provisions before purchasing any security through the Platform and should not assume that a secondary market will be available at any time or price.
Effective date: May 1, 2026. This SMS & Messaging Policy describes how Alphaneo LLC ("Alphaneo," "we," "us," or "our") uses SMS and text messaging to communicate with users of the Alphaneo platform (the "Platform"). By providing your mobile number and opting in to receive text messages from Alphaneo, you agree to the terms below.
Alphaneo may send the following categories of text message to your mobile number when you have provided prior express written consent to receive them:
Alphaneo does not send unsolicited marketing text messages. Any marketing or promotional SMS is sent only to users who have explicitly opted in to such communications.
Your provision of a mobile phone number during account registration or within account settings, combined with your affirmative selection of SMS notifications, constitutes your prior express written consent to receive text messages from Alphaneo at that number. Consent is not a condition of purchasing any security or accessing any feature of the Platform. You may withdraw consent at any time by texting STOP to any message received from Alphaneo or by disabling SMS notifications in your account settings.
You confirm that the mobile number you provide belongs to you, that you are the subscriber or customary user of that number, and that you are 18 years of age or older.
You may use any of the following commands at any time by replying to a message from Alphaneo:
These commands are supported on all shortcodes and long codes used by Alphaneo. To opt out of OTP and security messages only, disable two-factor authentication in your account security settings.
Message frequency varies based on your account activity and the notification settings you have enabled. Transactional and security messages are sent only when a relevant event occurs; they are not sent on a schedule. Alphaneo does not send recurring promotional SMS blasts.
Message and data rates may apply depending on your carrier and plan. Alphaneo is not responsible for charges from your mobile carrier. SMS and MMS messaging is available to users on all major U.S. carriers, including AT&T, Verizon, T-Mobile, and Sprint. Availability may vary by carrier and region; not all features may be available on all carriers.
Mobile phone numbers collected for SMS messaging are used solely for the purposes described in this policy. Alphaneo does not sell, license, or share your mobile number with third parties for their own marketing purposes. Your number may be shared with our SMS delivery provider (currently Twilio Inc.) solely for the purpose of delivering messages on our behalf, subject to Twilio's data processing terms and Alphaneo's Privacy Policy.
Message content may include your first name, account status indicators, and brief descriptions of platform events. No sensitive financial data (account balances, security holdings, investment amounts) is transmitted via SMS. Full details are available in the Alphaneo Privacy Policy.
For questions about SMS messaging or to request manual opt-out, contact:
We aim to respond to all support requests within two business days.
This GDPR Notice applies to individuals located in the European Economic Area (EEA) or the United Kingdom (UK) who access the Alphaneo Platform. The data controller is Alphaneo LLC, 251 Little Falls Drive, Wilmington, DE 19808, USA. For all data protection inquiries, contact privacy@alphaneo.ai.
Alphaneo LLC is incorporated in the United States. Processing of your personal data is governed by the EU General Data Protection Regulation (EU 2016/679) and, for UK residents, by the UK GDPR as retained in UK law following Brexit.
We rely on the following legal bases under Article 6 GDPR to process your personal data:
For special categories of personal data (biometric data processed for identity verification), we rely on Article 9(2)(a) (explicit consent) in jurisdictions where biometric processing requires a separate legal basis. Persona Identity, Inc. processes this data on our behalf under Article 28 GDPR data processing terms.
Subject to applicable conditions and exceptions, you have the following rights regarding your personal data, exercisable by contacting privacy@alphaneo.ai:
We will respond to all rights requests within one month of receipt. Where requests are complex or numerous, we may extend this period by a further two months, with prior notice. We may require identity verification before processing a request.
Alphaneo is incorporated in Delaware, USA. The European Commission has not adopted an adequacy decision with respect to the United States (note: the EU-US Data Privacy Framework adopted in 2023 covers self-certified entities; Alphaneo is not currently certified under the DPF). Accordingly, we rely on the following transfer mechanisms:
Copies of the relevant SCCs or IDTA may be requested by contacting privacy@alphaneo.ai. A list of current sub-processors and their locations is available on request.
We retain personal data for the minimum period necessary for the purposes for which it was collected, subject to legal retention obligations:
Upon expiry of the applicable retention period, data is securely deleted or anonymised in accordance with our data destruction policy. Anonymised data may be retained indefinitely for statistical purposes.
If you believe your data protection rights have not been upheld, you have the right to lodge a complaint with your local data protection supervisory authority:
We would, however, appreciate the opportunity to address your concerns directly before you contact a supervisory authority. Please email privacy@alphaneo.ai in the first instance.
For all GDPR and UK GDPR inquiries, including requests to exercise your rights, questions about legal bases, or requests for SCCs and sub-processor information:
We will acknowledge receipt of your request within 72 hours and provide a substantive response within 30 days.
This California Privacy Notice applies to California residents and supplements our Privacy Policy. It is issued pursuant to the California Consumer Privacy Act of 2018 (CCPA), as amended and expanded by the California Privacy Rights Act of 2020 (CPRA), codified at California Civil Code §§ 1798.100 et seq. Terms used but not defined herein have the meaning given to them in the CCPA/CPRA.
The business subject to this notice is Alphaneo LLC, 251 Little Falls Drive, Wilmington, DE 19808. For all California privacy inquiries: privacy@alphaneo.ai.
In the preceding 12 months, we have collected the following categories of personal information (as defined in Cal. Civ. Code § 1798.140):
We collect personal information from the following sources:
We use the personal information listed above for the following business and commercial purposes:
Alphaneo does not sell your personal information to third parties for monetary or other valuable consideration, within the meaning of Cal. Civ. Code § 1798.140(ad). Alphaneo does not share your personal information with third parties for cross-context behavioural advertising, within the meaning of § 1798.140(ah).
Because we do not sell or share personal information in these ways, you need not submit a "Do Not Sell or Share" opt-out request. We will not sell or share personal information in the future without providing conspicuous notice and updating this policy in advance.
We do disclose personal information to service providers (as defined in § 1798.140(ag)) for the purposes described above. Such disclosures are governed by written contracts that prohibit service providers from using your personal information for any purpose other than performing services for Alphaneo.
California residents have the following rights, subject to certain exceptions and verification requirements:
To submit a verifiable consumer request, email privacy@alphaneo.ai with the subject line "CCPA Rights Request" and specify the right(s) you wish to exercise. We will acknowledge your request within 10 business days and respond substantively within 45 days. If we require additional time (up to a further 45 days), we will notify you prior to the expiry of the initial period.
We will verify your identity before processing a request. Verification typically requires matching information you provide against information already on file. For deletion requests, we use a two-step process: an initial request plus a separate confirmation.
Authorised agents: You may designate an authorised agent to submit a request on your behalf. Authorised agents must provide: (1) written permission signed by you; and (2) verification of their own identity. We may still require you to confirm the agent's authority directly for deletion requests.
Household requests: We do not collect household-level personal information and do not respond to household requests.
California Civil Code § 1798.83 permits California residents to request information about personal information shared with third parties for their direct marketing purposes during the preceding calendar year. Alphaneo does not share personal information with any third party for that third party's own direct marketing purposes, and therefore no disclosure under § 1798.83 is required.