Privacy Policy
Aqua Advisors LLC (“Aqua,” “we,” “us,” or “our”) is committed to protecting the privacy and confidentiality of our clients’ and fund investors’ personal information. This Privacy Notice describes how we collect, use, and safeguard nonpublic personal information (“NPI”) about our prospective, current, and former clients and investors in private investment vehicles we advise or sub-advise, in accordance with the Gramm-Leach-Bliley Act and applicable regulations.
Information We Collect
We collect nonpublic personal information about you from the following sources:
• Information you provide to us on applications, subscription documents, questionnaires, advisory agreements, and other forms or documents, such as your name, address, date of birth, Social Security number or tax identification number, assets, net worth, income, bank account information, investment objectives, and occupation.
• Information about your transactions with us, our affiliates, or others, including account balances, investment history, subscription and redemption activity, and payment records.
• Information from other sources, such as broker-dealers, administrators, registrar and transfer agents, custodians, and other financial institutions with whom we work to service your account or investment.
How We Use and Share Your Information
We use your personal information primarily to provide investment management services, process subscriptions and transactions, and communicate with you about your account and our services.
We may disclose your NPI to nonaffiliated third parties as permitted or required by law, including:
• To affiliates and nonaffiliated third-party financial service providers that assist us in servicing your investments — such as broker-dealers, administrators, custodians, and registrar and transfer agents — to the extent necessary to perform services on our behalf.
• To nonaffiliated third-party non-financial service providers that assist us in processing or servicing transactions or products, such as word processors and printers.
• To regulatory authorities, law enforcement agencies, or other third parties as required or permitted by applicable law or regulation.
• To our attorneys, accountants, auditors, and compliance consultants as necessary for the operation of our business.
Any third-party service provider engaged by us will be contractually required to uphold and maintain our privacy standards when handling your personal information.
Information We Do Not Share
We do not sell your personal information to any third party. We do not share your NPI with nonaffiliated third parties for their own marketing purposes. Because we do not share yourinformation in a manner that triggers opt-out rights under federal law, no opt-out election is necessary.
Retention of Your Information
We retain your personal information for as long as necessary to provide our services and to comply with our legal and regulatory obligations. Under the Investment Advisers Act of 1940 (Rule 204-2), we are required to maintain certain books and records for a minimum of five (5) years from the end of the fiscal year in which the last entry was made. Certain records may be retained for longer periods as required by applicable law or regulation.
When your information is no longer required for these purposes, we will securely dispose of it in accordance with our information security policies.
Former Clients and Investors
If you close your account or your advisory or investment relationship with us otherwise ends, we will continue to adhere to the privacy policies and practices described in this notice with respect to your nonpublic personal information.
Safeguarding Your Information
We maintain physical, electronic, and procedural safeguards to protect your nonpublic personal information. Access to client and investor information is restricted to authorized individuals who have been advised as to the proper handling of such information and who need access to perform services on your behalf. All such personnel are required to maintain and protect its confidentiality.
Changes to This Notice
We reserve the right to modify this Privacy Notice at any time. If we make material changes, we will notify you by providing an updated notice.
Questions
If you have questions about this Privacy Notice or our privacy practices, please contact us at:
Aqua Advisors LLC
848 Brickell Avenue, PH-5, Miami, FL 33131 | (305) 877-7593 | milagros@aquaadvisors.com
Effective Date: May 1st, 2026
Last Revised: May 1st, 2026
