Privacy Policy

Privacy policy

Last updated 12 November 2026 Controller TwinMedia, LLC

1. Who we are

TwinMedia, LLC, a Texas limited liability company trading as Sycamore Capital ("Sycamore Capital", "we", "us" or "our"), is the controller of the personal information described in this policy. Our registered office is at 200 Crescent Court, Dallas, Texas 75201, United States, and our registration number is 00185238890002.

For privacy enquiries, contact info@sycamorecapital.com.

This policy describes how we handle personal information collected through this website. It does not replace any privacy notice given to you as an investor, prospective investor or representative of an investor, which will apply to information collected during onboarding and the course of our relationship.

2. Scope of this policy

This policy applies to personal information we collect when you:

  • visit or browse this website;
  • contact us by email, telephone or post, including investor relations enquiries;
  • are identified as a contact at an investor, prospective investor, adviser or service provider; and
  • apply to us for a role, where you submit information through the site.

It does not apply to third-party websites we link to, or to information held by fund vehicles or administrators that act as separate controllers.

3. Information we collect

Depending on how you interact with us, we may collect:

  • Identity and contact details — name, job title, firm, email address, telephone number and postal address.
  • Investor and compliance information — where you are an investor or prospective investor: identification documents, date of birth, tax residency and tax identification numbers, source of funds and source of wealth, beneficial ownership details, and the results of sanctions, politically exposed person and anti-money-laundering screening.
  • Correspondence — the content of enquiries and any records of our communications with you.
  • Technical information — IP address, device and browser type, operating system, referring page, pages viewed and the date and time of your visit. See section 5.
  • Recruitment information — a CV, employment history and other details you choose to send us.

We do not intentionally collect special category data through this site. Please do not send us sensitive information unless we have asked for it.

4. How and why we use it

We use personal information to:

  • respond to enquiries and manage our relationship with you;
  • assess and administer investor subscriptions, and meet our anti-money-laundering, sanctions, tax-reporting and record-keeping obligations;
  • operate, secure and improve this website, and understand how it is used;
  • send you information you have asked for, and manage any consent you have given;
  • consider job applications; and
  • establish, exercise or defend legal claims and comply with requests from regulators and courts.

Legal bases

Where the EU or UK General Data Protection Regulation applies, we rely on the following bases:

  • Contract — to take steps at your request before entering into a contract, and to perform it.
  • Legal obligation — including AML, sanctions, tax and regulatory record-keeping requirements.
  • Legitimate interests — to run and secure our business, respond to enquiries, and communicate with professional contacts, balanced against your rights.
  • Consent — where we ask for it, for example for certain marketing communications. You may withdraw consent at any time.

5. Cookies and similar technologies

This site sets no cookies, and we do not run our own analytics, advertising or tracking pixels. There is no cookie banner because we do not place anything non-essential on your device ourselves.

Server logs. Our hosting provider, Hostinger, keeps standard web server access logs for this site. Those logs record the IP address a request came from, the browser and device type your browser reports, the page or file requested, and the date and time of the visit. We use them to keep the site secure and available, to diagnose faults, and, in aggregate, to see which pages are used. They are not used to build a profile of you, to follow you across other websites or to target advertising. How long they are kept is set out in section 9.

The site runs no analytics of its own. Where a hosting provider also supplies summarised performance data, it is aggregated and cookieless: page loads and timings only, never information identifying an individual visitor.

The pages also load typefaces from Google Fonts. That request is made by your browser directly to Google's servers, which receive your IP address and standard request headers. We do not receive that data. See Google's privacy policy for how it is handled.

If we add our own analytics or any other non-essential technology, we will update this policy and ask for consent where the law requires it before anything is set. You can block or delete cookies, and block these scripts through your browser settings or an extension, at any time; the site will continue to work.

6. Who we share it with

We may share personal information with:

  • our affiliates and the general partner, manager or adviser of any fund or vehicle relevant to you;
  • fund administrators, transfer agents, custodians, prime brokers and depositaries;
  • auditors, legal advisers, tax advisers and other professional advisers;
  • providers of identity verification, sanctions screening and IT hosting services, acting under contract;
  • regulators, tax authorities, law enforcement and courts, where we are required or permitted to disclose; and
  • a buyer or successor in the event of a merger, acquisition, reorganisation or transfer of the firm or its assets.

We do not sell personal information, and we do not share it with third parties for their own marketing.

7. International transfers

We operate in the United States, and information collected through this site is processed there. If we are asked to handle information that is protected by EU or UK law, we will put appropriate transfer safeguards in place before doing so, and you can request details using the contact information in section 14.

8. How long we keep it

We keep personal information only as long as necessary for the purposes for which it was collected, including to meet legal, regulatory, accounting and reporting requirements. In practice:

  • website technical logs are kept for 12 months;
  • enquiries that do not lead to a relationship are kept for 24 months;
  • investor onboarding and transaction records are kept for the life of the relationship and for at least five years afterwards, as required by applicable anti-money-laundering and tax rules; and
  • unsuccessful job applications are kept for 12 months.

These periods are proposed defaults and will be confirmed against the firm's records-retention policy before publication.

9. How we protect it

We apply technical and organisational measures appropriate to the risk, including access controls, encryption in transit, restricted administrative access and staff confidentiality obligations. No method of transmission or storage is entirely secure, and we cannot guarantee that unauthorised access will never occur. Where a breach is likely to result in a risk to your rights, we will notify you and the relevant regulator as required by law.

10. Your rights

Depending on where you live, you may have some or all of the following rights:

  • Access — to obtain a copy of the personal information we hold about you;
  • Rectification — to have inaccurate information corrected;
  • Erasure — to have information deleted where we no longer have a lawful reason to keep it;
  • Restriction — to limit how we use it while a concern is investigated;
  • Portability — to receive information you provided to us in a structured, machine-readable format;
  • Objection — to object to processing based on legitimate interests, and to direct marketing at any time;
  • Withdraw consent — where we rely on consent, without affecting processing already carried out; and
  • Complain — to lodge a complaint with a supervisory authority.

California residents. Subject to the California Consumer Privacy Act, as amended, you may request to know the categories and specific pieces of personal information we have collected, request deletion or correction, and request to opt out of the sale or sharing of personal information. We do not sell or share personal information for cross-context behavioural advertising, and we do not use it for automated decision-making with legal or similarly significant effects. We will not discriminate against you for exercising these rights.

To exercise any right, contact us at info@sycamorecapital.com. We may need to verify your identity before responding, and we will respond within the period required by applicable law.

11. Marketing communications

We send investment and firm updates only where we are permitted to do so and, where required, with your consent. You can unsubscribe at any time using the link in the message or by contacting us. Opting out of marketing does not affect communications we must send you in connection with an investment or our legal obligations.

12. Children

This site is not directed at children, and we do not knowingly collect personal information from anyone under 18. If you believe a child has provided information to us, please contact us and we will delete it.

13. Changes to this policy

We may update this policy from time to time to reflect changes in our practices or the law. The "Last updated" date at the top of this page shows when it was last revised, and material changes will be highlighted on this page.

14. Contact and complaints

Contact us about privacy at info@sycamorecapital.com or by post at TwinMedia, LLC, Dallas, Texas, United States.

You have the right to complain to a supervisory authority. For US residents that is your state attorney general, and California residents may contact the California Attorney General. Where EU or UK data protection law applies to you, you may complain to your local supervisory authority (in the UK, the Information Commissioner's Office). We would welcome the chance to address your concern before you approach a regulator.

See also our Legal Notices.