Privacy Policy – TSG Invest Investor Portal
Last Updated: October 21, 2025
TSG Invest (d/b/a of The Spaventa Group LLC) (“we,” “us,” “our,” or “Company”) is committed to protecting the privacy and security of your personal and financial information. This Privacy Policy explains how we collect, use, disclose, and safeguard information you provide through the TSG Invest Investor Portal (the “Portal”).
This Privacy Policy applies exclusively to the Investor Portal. For information about our public website privacy practices, please refer to our Website Privacy Policy.
By creating an account and using the Investor Portal, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, use, and sharing of your information as described herein.
NOTICE: Information you provide through the Investor Portal will be shared with all TSG affiliates as described in the “Affiliates and Information Sharing” section below. This sharing is necessary to facilitate investment opportunities, ensure regulatory compliance, and coordinate financial services across our affiliate companies.
When you create an investor profile and use the Portal, we collect comprehensive information necessary for investment suitability assessment, regulatory compliance, and investment processing.
We collect your full legal name including first and last name, email address, home address including street, city, state, and ZIP code, cell phone number, citizenship status, date of birth, marital status, occupation or profession, and employer name and information if applicable.
We gather information about your annual income, net worth excluding primary residence, liquidity measured as average 90-day liquid assets, annual expenses, liquidity needs and timeline, and sources of investment funds such as employment income, sale of business, inheritance, investment returns, and other sources.
For each asset class, we collect your years of experience and estimated number of active investments per year. These asset classes include individual stocks, fixed income securities such as bonds and treasury securities, mutual funds and exchange-traded funds, Real Estate Investment Trusts, direct real estate investments, annuities and insurance products, venture capital and angel investing, hedge funds and private equity funds, private debt and lending investments, digital assets and cryptocurrency, commodities and futures, options and derivatives, and other investment types. We also collect information about your investment decision-making process, including whether you make independent decisions, consult with advisors, or rely on recommendations.
We collect information about your overall risk tolerance, which may be conservative, moderately conservative, moderate, moderately aggressive, or aggressive. We also gather information about your primary investment objectives, desired allocation to equity-based alternative investments such as venture capital, private equity, and hedge funds, desired allocation to income-based alternative investments such as private debt and real estate funds, investment time horizon, and investment monitoring frequency.
We collect information about your accredited investor status and the basis for your qualification, qualified purchaser status if applicable, Investment Company Act status for entity investors, and ERISA and employee benefit plan status for entity investors.
We gather your U.S. person or non-U.S. person classification, Form W-9 for U.S. persons or Form W-8 for non-U.S. persons, tax identification number or Social Security number, and tax residency information.
If you choose to provide this information, we collect your trusted contact’s first and last name, phone number and email address, and their relationship to you.
We collect copies of government-issued identification such as driver’s license, passport, or state ID, including the photograph and document number from your ID and the document expiration date.
For entity accounts such as corporations, LLCs, trusts, partnerships, or other legal entities, we collect the entity’s legal name and type, entity formation documents including articles of incorporation, operating agreements, partnership agreements, and trust documents, tax identification number, authorized person information and government-issued ID, corporate resolutions or trustee authorizations, certificates of good standing, and beneficial ownership information. For trusts, we additionally collect the trust agreement, certificate of trust, and grantor information. For tax-exempt organizations, we collect IRS determination letters. For employee benefit plans, we collect plan documents and ERISA information.
We track and collect information about investment account creation and management activities, investment interests and indications, subscription documents and agreements, investment confirmations and transaction history, communications and correspondence with TSG and its affiliates, document uploads and downloads, and Portal usage data including login times, pages accessed, and features used.
We automatically collect your IP address, browser type and version, device information and operating system, Portal session data, and information through cookies and similar tracking technologies.
We collect information through direct input when you manually enter information into Portal forms and fields, or when our team members enter information on your behalf with your authorization. We receive information through document uploads when you provide documents for identity verification, entity documentation, and investment processing. Information is captured through electronic signatures during electronic signature processes. We collect data based on account activity, including actions you take within the Portal such as viewing offerings, submitting indications of interest, and managing your profile. We may obtain information from third-party verification services including identity verification, accreditation verification, and background check providers. We also collect technical information automatically through cookies and analytics tools.
We use the information collected through the Investor Portal for the following purposes.
We use your information to evaluate your qualifications to invest in investment fund offerings and other investments offered by affiliates, assess investment suitability based on your financial situation, experience, and objectives, process investment subscriptions and manage investment accounts, facilitate investment transactions and fund distributions, provide investment-related communications and updates, and generate subscription documents and agreements.
Your information is used to conduct Know Your Customer verification, perform Anti-Money Laundering checks, verify accredited investor or qualified purchaser status, comply with federal and state securities laws and regulations, meet SEC, FINRA, and state securities regulator requirements, maintain books and records as required by law, respond to regulatory inquiries and examinations, and file required reports and notices with regulatory authorities.
We use your information to create and maintain your investor profile and accounts, provide customer support and respond to inquiries, send account notifications, confirmations, and updates, communicate investment opportunities from TSG and its affiliates, deliver tax documents and account statements, and facilitate communications with fund managers and issuers.
Your information helps us protect against unauthorized access to your account, detect and prevent fraudulent activity, verify your identity for account access, monitor for suspicious transactions or activity, and maintain the security and integrity of the Portal.
We use your information to enforce our Terms of Service and other agreements, resolve disputes and claims, protect our legal rights and interests, conduct internal audits and quality assurance, improve Portal functionality and user experience, analyze usage patterns and investor preferences, and develop new products and services.
IMPORTANT NOTICE: All information you provide through the Investor Portal is shared with TSG Invest’s affiliated companies. This information sharing is integral to our business operations and necessary to facilitate investment opportunities across our affiliate platforms, ensure comprehensive regulatory compliance across all entities, coordinate financial services and investment advisory services, maintain unified client records and relationship management, provide seamless service delivery across TSG companies, and enable our affiliates to communicate relevant investment opportunities to you.
TSG Affiliates include TSG Capital Advisors LLC (“TSGCA”) (CRD #147509), a FINRA/SIPC member broker-dealer registered with the Securities and Exchange Commission that provides broker-dealer services, private placement offerings, and securities transactions; TSG Alpha Partners LLC (“TSGA”) (CRD #319493), an SEC-registered investment advisor providing financial planning, investment advisory services, and portfolio management; and TSG Insurance Services LLC (“TSGIS”), a licensed insurance agency providing insurance products, annuities, and risk management solutions.
By creating an investor profile, you explicitly consent to this information sharing among TSG affiliates. Each affiliate will use your information in accordance with their own regulatory obligations and may contact you regarding their respective services and investment opportunities.
In addition to sharing with affiliates, we may share your information with other parties in the following circumstances.
We work with trusted third-party service providers who assist with Portal operations and investment processing. These include identity verification services to verify your identity and prevent fraud, accreditation verification services to confirm accredited investor or qualified purchaser status, background check providers to conduct AML and sanctions screening, document management services to securely store and manage uploaded documents, electronic signature platforms to facilitate document execution, payment processors to process investment funds and distributions, IT and security services to maintain Portal infrastructure and security, data analytics providers to analyze Portal usage and improve services, and customer support tools to provide assistance and respond to inquiries. These service providers are contractually obligated to protect your information, use it only for specified purposes, and comply with applicable privacy and security requirements.
When you express interest in or invest in an offering through the Portal, we share relevant information with the issuer or sponsor of the investment opportunity, fund managers and general partners, third-party administrators and custodians, and legal counsel representing the issuer or fund. This information is necessary to process your investment, maintain investor records, provide ongoing communications, and comply with fund governance and regulatory requirements.
We may disclose your information to comply with legal and regulatory obligations to entities including the Securities and Exchange Commission, Financial Industry Regulatory Authority, state securities regulators and administrators, Internal Revenue Service and tax authorities, law enforcement agencies, courts and legal proceedings including subpoenas, court orders, and discovery requests, and government agencies conducting investigations or audits.
We may share your information with other parties when you provide explicit consent, such as third-party financial advisors you authorize, co-investors in joint investment accounts, accountants or attorneys you designate, and other parties you specifically authorize.
In the event of a merger, acquisition, financing, sale of assets, bankruptcy, or similar corporate transaction involving TSG Invest or its affiliates, your information may be transferred to the acquiring or successor entity. You will be notified of any such change in ownership or control of your information.
We may share aggregated, anonymized, or de-identified information that cannot reasonably be used to identify you for research, analytics, marketing, or other business purposes. This information is not considered personal information and is not subject to this Privacy Policy.
We implement comprehensive technical, administrative, and physical security measures to protect your information.
Our technical safeguards include encryption of data in transit using industry-standard SSL/TLS protocols, encryption of sensitive data at rest, secure authentication mechanisms and multi-factor authentication options, regular security testing and vulnerability assessments, intrusion detection and prevention systems, secure backup and disaster recovery procedures, and access controls and user authentication requirements.
Our administrative safeguards include employee training on data protection and security practices, confidentiality agreements with employees and service providers, role-based access controls limiting access to need-to-know basis, background checks for employees with access to sensitive information, regular security audits and compliance reviews, incident response and breach notification procedures, and data protection impact assessments.
Our physical safeguards include secure data center facilities with restricted access, environmental controls and monitoring, and secure disposal of physical documents containing personal information.
Despite our security measures, no method of transmission over the internet or electronic storage is completely secure. While we strive to protect your information using commercially reasonable means, we cannot guarantee absolute security. Risks include unauthorized access by hackers or cybercriminals, data breaches affecting third-party service providers, interception of data during transmission, and human error or insider threats.
You play a critical role in protecting your account. You must create strong, unique passwords and not share them with anyone. You should regularly review your account activity and report suspicious behavior immediately. You must log out after each session, especially on shared or public devices. You should be cautious of emails or communications requesting your login credentials. You must keep your devices and software updated with the latest security patches. You should avoid accessing your account on unsecured public Wi-Fi networks.
If you suspect unauthorized access to your account, contact us immediately at cr@tsginvest.com or (631) 210 – 7263.
We retain your information for varying periods depending on the purpose and legal requirements.
Information in active investor accounts is retained for the duration of your active account and investment holdings. Federal and state securities laws require us to retain certain records for specific periods. Investment records and subscription documents are retained for at least 6 years after the investment is liquidated. Communications and correspondence are retained for at least 3-6 years depending on the type. Identity verification and KYC documentation is retained for at least 5 years after account closure. Transaction records are retained for at least 6 years after the transaction. Information necessary for tax reporting and IRS compliance is retained for at least 7 years. Information may be retained longer if necessary to resolve disputes, enforce agreements, or defend legal claims. After you close your account, we retain your information as required by securities regulations, typically for at least 6 years from account closure.
We may retain anonymized, aggregated, or de-identified data indefinitely for research, analytics, and business intelligence purposes. This data cannot reasonably be used to identify you and is not subject to deletion requests.
When information is no longer required, we securely dispose of it through methods such as secure deletion or destruction of electronic files, shredding of physical documents, overwriting of data storage media, and decommissioning of hardware in accordance with data destruction standards.
Your information may be transferred to, stored, and processed in the United States and other countries where TSG Invest, its affiliates, or service providers operate. These countries may have data protection laws that differ from those in your country of residence.
When we transfer information internationally, we implement appropriate safeguards including standard contractual clauses approved by relevant authorities, adequacy decisions recognizing equivalent data protection, binding corporate rules for transfers within our corporate group, and your explicit consent for specific transfers when required.
By using the Investor Portal, you acknowledge and consent to the transfer of your information to the United States and other jurisdictions as necessary for the purposes described in this Privacy Policy.
Depending on your location and applicable law, you may have various rights regarding your personal information. However, please note that certain investor information must be retained to comply with securities regulations, even if you request deletion.
You have the right to access and request access to the personal information we hold about you, receive a copy of your information in a structured, commonly used format, and understand what information we collect, how it’s used, and with whom it’s shared. To exercise these rights, contact us using the information provided below. We will provide access to your information within the timeframe required by applicable law, typically within 30-45 days.
You have the right to correction, meaning you may request correction of inaccurate or incomplete information. For account updates, you may update your profile information, contact details, and preferences directly through the Portal. You are responsible for ensuring the accuracy of information you provide. Inaccurate information may affect investment suitability determinations and regulatory compliance.
You have the right to deletion, meaning you may request deletion of your personal information, subject to legal and regulatory exceptions. Important limitations apply: We may be unable to delete certain information if it is required by securities laws and regulations typically for 6 or more years, necessary to complete transactions or fulfill services you requested, required to detect and prevent fraud or security incidents, needed to comply with legal obligations or defend legal claims, or subject to ongoing regulatory examination or investigation. If we cannot delete your information due to legal requirements, we will inform you of the reasons and the retention period.
You have the right to object to certain processing of your information, particularly for direct marketing purposes, and the right to restriction, meaning you may request that we limit how we use your information in specific circumstances.
You have the right to opt out of marketing communications. For email, you may click “unsubscribe” in marketing emails or contact us to update preferences. For SMS, you may text “STOP” to opt out of text messages. For phone calls, you may request to be placed on our do-not-call list. For mail, you may contact us to opt out of postal mailings. Note that even if you opt out of marketing, we will still send transactional communications related to your account, investments, and legal obligations.
Where processing is based on your consent, you may withdraw consent at any time. However, this will not affect the lawfulness of processing based on consent before withdrawal, and we may continue processing for other lawful bases such as regulatory compliance.
To exercise any of these rights, contact us by email at cr@tsginvest.com, by phone at 631-210-7623, by mail at 3275 Veterans Memorial Highway Suite B9 Ronkonkoma New York 11779, or through the Portal by submitting a request through the Portal’s support feature. We will verify your identity before processing requests and respond within the timeframe required by applicable law. We do not charge a fee for exercising your rights unless your request is manifestly unfounded, excessive, or repetitive.
As a financial institution, TSG Invest and its affiliates are subject to the Gramm-Leach-Bliley Act (GLBA), which requires us to provide you with notice of our privacy practices.
We collect information from applications and forms including name, address, income, and assets. We collect information about your transactions with us including account balances, payment history, and investment activity. We collect information from consumer reporting agencies including credit reports and background checks. We collect information from other sources including identity verification services and public records.
We may disclose all categories of information we collect to our affiliates for their everyday business purposes, to nonaffiliated companies that perform services for us with confidentiality agreements, and to other parties as required or permitted by law.
Federal law gives you the right to limit some but not all sharing. Specifically, you cannot limit sharing for our affiliates’ everyday business purposes regarding information about your transactions and experiences, sharing for our affiliates to market to you, or sharing for nonaffiliates to market to you. This is because the information sharing described in this Privacy Policy is necessary for investment processing, regulatory compliance, and coordinated service delivery across TSG affiliates.
If we decide to share information in ways that would allow you to opt out under GLBA, we will provide you with a separate opt-out notice at that time.
We will provide you with an annual privacy notice as required by GLBA. This notice will be delivered electronically through the Portal or by mail.
California residents have additional rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA).
Under the right to know, you may request detailed information about categories and specific pieces of personal information collected, categories of sources from which information was collected, business or commercial purposes for collecting information, and categories of third parties with whom we share information.
Under the right to delete, you may request deletion of personal information, subject to exceptions for regulatory compliance, legal obligations, and security purposes.
Under the right to correct, you may request correction of inaccurate personal information.
Under the right to opt-out of sale or sharing, you have the right to opt out of the “sale” or “sharing” of personal information for cross-context behavioral advertising. Note that we do not sell personal information for monetary consideration. We may share information with affiliates and service providers as described in this policy, which is necessary for investment processing and not considered a “sale” under CCPA.
Under the right to limit use of sensitive personal information, you may request that we limit the use of sensitive personal information such as financial account information, precise geolocation, or SSN to purposes necessary to provide services. However, the information we collect is necessary for investment processing and regulatory compliance.
Under the right to non-discrimination, you will not be discriminated against for exercising your privacy rights.
You may designate an authorized agent to submit requests on your behalf. We will require verification of the agent’s authority. We will respond to verifiable requests within 45 days, extendable by an additional 45 days if necessary. California residents may request information about our data practices, including the number and type of requests received and our response times.
To exercise California privacy rights, contact us at cr@tsginvest.com or call 631-210-7623.
Residents of Virginia under VCDPA, Colorado under CPA, Connecticut under CTDPA, and Utah under UCPA have similar rights including the right to access personal data, correct inaccuracies, delete personal data, obtain a copy of personal data, and opt out of targeted advertising, sale of personal data, and profiling for certain decisions.
To exercise these rights, contact us using the information provided in the Contact section.
We comply with all applicable state privacy laws. If your state has enacted comprehensive privacy legislation, contact us to understand and exercise your rights.
The Investor Portal is not intended for individuals under 18 years of age. We do not knowingly collect personal information from minors. To invest through the Portal, you must be at least 18 years old or the age of majority in your jurisdiction and legally capable of entering into binding contracts.
If we become aware that we have collected information from a minor without proper authorization, we will take steps to delete such information promptly. If you believe we have collected information from a minor, contact us immediately at cr@tsginvest.com.
The Investor Portal may contain links to third-party websites, services, or resources, such as fund manager websites, issuer information pages, due diligence materials hosted externally, and third-party research or news sources.
We are not responsible for the privacy practices, content, or security of these external sites. Third-party sites are governed by their own privacy policies. We encourage you to review their privacy practices before providing any personal information.
Some Portal features may integrate with third-party services such as identity verification or electronic signature platforms. When you use these features, you may be subject to the third party’s terms and privacy policy in addition to ours.
The Investor Portal uses cookies and similar tracking technologies to provide functionality and enhance your experience.
Essential cookies are necessary for Portal operation, including authentication and session management, security features and fraud prevention, remembering your preferences and settings, and enabling core Portal features.
Analytics cookies help us understand how you use the Portal by tracking pages visited and features used, time spent on the Portal, navigation patterns and user flows, and error tracking and performance monitoring.
Functional cookies enhance Portal functionality by remembering your language preferences, customizing your user interface, and saving your progress on forms.
Essential cookies cannot be disabled as they are necessary for Portal operation. Optional cookies including analytics and functional cookies may be controlled through your browser settings, as most browsers allow you to refuse or delete cookies, through Portal preferences if available, or through opt-out tools provided by analytics providers. Note that disabling certain cookies may limit Portal functionality or require you to re-enter information.
For more information about cookies, visit www.allaboutcookies.org.
We may use automated systems to assist with certain decisions, such as initial screening for investor qualification requirements, risk assessment and suitability scoring, fraud detection and prevention, and identity verification.
However, significant investment decisions and suitability determinations involve human review and oversight. You have the right to obtain information about the logic involved in automated decisions, contest automated decisions, and request human review of automated determinations.
We may update this Privacy Policy periodically to reflect changes in our data practices or Portal features, new legal or regulatory requirements, technological developments or security enhancements, changes in our corporate structure or affiliates, and feedback from users, regulators, or auditors.
When we make material changes to this Privacy Policy, we will update the “Last Updated” date at the top of this policy, post the revised policy on the Portal, notify you through the Portal notification system, send email notification to your registered email address, and for significant changes, require your affirmative consent before continuing to use the Portal.
If you disagree with changes to this Privacy Policy, you may close your account subject to any ongoing investment obligations, exercise your rights to restrict processing where applicable, or contact us to discuss your concerns.
Continued use of the Portal after changes constitutes acceptance of the updated Privacy Policy. We encourage you to review this Privacy Policy regularly to stay informed about how we protect your information.
If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, contact TSG Invest by email at cr@tsginvest.com, by phone at 631-210-7623, or by mail at 3275 Veterans Memorial Highway Suite B9 Ronkonkoma New York 11779.
For Portal support including technical support or account assistance, email support@tsginvest.com or use the “Help” or “Contact Us” feature within the Portal.
To exercise your privacy rights including access, correction, and deletion, contact us by email at cr@tsginvest.com, by phone at 631-210-7623, through the Portal by submitting a request through the Portal’s privacy request feature, or by mail at 3275 Veterans Memorial Highway Suite B9 Ronkonkoma New York 11779.
Please include the following information in your request: your full name and contact information, description of your request, verification information for security purposes, and preferred method of response.
We will acknowledge receipt of your request within 5 business days and provide a substantive response within 30-45 days for most requests, or extended timeframes where permitted by law with notice to you.
To protect your information, we will verify your identity before processing requests. Verification may require matching information you provide with information in our records, answering security questions, providing government-issued identification, or confirming access to your registered email or phone number.
If you believe we have not adequately addressed your privacy concerns, you may request internal escalation to our Privacy Officer or senior management. You may file a regulatory complaint with your state Attorney General’s office, state securities regulator, Federal Trade Commission, California Attorney General for California residents, or your local data protection authority for EU/EEA residents. You may also consult with legal counsel about your rights and options.
We take privacy concerns seriously and will work diligently to resolve any issues.
This Privacy Policy is designed to comply with the Gramm-Leach-Bliley Act (GLBA) and its implementing regulations, SEC Regulation S-P governing privacy of consumer financial information, FINRA rules regarding customer information protection, state securities laws and regulations, California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA), state privacy laws including Virginia VCDPA, Colorado CPA, Connecticut CTDPA, and Utah UCPA, Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) requirements, USA PATRIOT Act customer identification program requirements, and other applicable federal and state privacy laws.
Our data practices are subject to examination by the Securities and Exchange Commission, Financial Industry Regulatory Authority, state securities regulators, state attorneys general, and other regulatory authorities with jurisdiction.
An accredited investor is an individual or entity meeting specific income, net worth, or professional criteria as defined under SEC Rule 501 of Regulation D. Affiliates are companies related by common ownership or control, specifically TSG Capital Advisors LLC, TSG Alpha Partners LLC, and TSG Insurance Services LLC. Personal information is information that identifies, relates to, describes, or is capable of being associated with you, either directly or indirectly. Portal refers to the TSG Invest Investor Portal, including web-based and mobile applications. A qualified purchaser is an individual or entity meeting higher financial thresholds as defined under Section 2(a)(51) of the Investment Company Act of 1940. Sensitive personal information includes information such as Social Security numbers, financial account information, precise geolocation, racial or ethnic origin, religious beliefs, or health information. Third party refers to any individual or entity that is not TSG Invest, its affiliates, or you.
This Privacy Policy is effective as of the “Last Updated” date shown at the top of this document.
By creating an account and using the Investor Portal, you acknowledge that you have read and understood this Privacy Policy, you consent to the collection, use, and sharing of your information as described, you understand that your information will be shared with all TSG affiliates, you agree to the terms and conditions set forth in this Privacy Policy, and you understand your rights and how to exercise them.
If you do not agree with this Privacy Policy, please do not create an account or use the Investor Portal.
For your convenience, this summary highlights key aspects of our privacy practices. Please read the full Privacy Policy for complete details.
We collect comprehensive personal, financial, and investment information necessary for investment processing and regulatory compliance. We use this information for investment suitability assessment, transaction processing, regulatory compliance, and account management. We share your information with all TSG affiliates, service providers, issuers, and regulators as necessary. Your rights include access, correction, deletion subject to legal limitations, and opt-out of marketing. We implement industry-standard technical and organizational measures to protect your information. Information is retained as required by securities laws, typically 6 or more years. For questions or requests, contact cr@tsginvest.com or 631-210-7623.
This Privacy Policy is governed by and construed in accordance with the laws of the State of New York, USA, without regard to its conflict of law principles.
Any disputes arising out of or relating to this Privacy Policy shall be subject to the exclusive jurisdiction of the state and federal courts located in New York.
Copyright © 2025 The Spaventa Group, LLC. All rights reserved.
TSG Invest | TSG Capital Advisors LLC | TSG Alpha Partners LLC | TSG Insurance Services LLC
This Privacy Policy applies to the TSG Invest Investor Portal. For our public website privacy practices, please refer to our Website Privacy Policy.
