Privacy Policy | Apex Scalers

01

Overview

Apex Scalers, LLC ("Apex Scalers," "we," "us," or "our") respects your privacy and is committed to protecting the personal information you share with us. This Privacy Policy explains what information we collect through the website at apexscalers.com (the "Site"), how we use and protect it, who we share it with, and what rights you have regarding your data. This policy applies to all visitors and users of the Site, regardless of location. By using the Site, you consent to the practices described in this Privacy Policy.

02

Information We Collect

Information you provide directly. When you submit our intake form, you may provide your full name, email address, company name, job title, intent (e.g., raising capital, seeking advisory services), stage of fundraise, target raise size, scope of engagement, and any additional context you choose to include. When you subscribe to our newsletter ("The Routing Report"), you provide your email address. When you use our contact form, you may provide your name, email, and message content.

Information collected automatically. We use Cloudflare Web Analytics, which is a privacy-first analytics service that does not use cookies, does not collect personal data, and does not track individual visitors across sites. It collects aggregate metrics only — page views, referral sources, browser types, device types, and country of origin — without identifying individual users. We do not use cookies, tracking pixels, or browser fingerprinting on this Site.

Information from third-party tools. Form submissions are processed through Formspree, Inc., a third-party form handling service. Formspree receives the data you submit and transmits it to us. Formspree's privacy practices are governed by their own privacy policy. As our services evolve, we may integrate additional tools such as customer relationship management (CRM) platforms, visitor intelligence services, or email marketing platforms. If we do, this Privacy Policy will be updated before those tools collect any personal information from you.

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How We Use Your Information

We use the information we collect for the following purposes: to evaluate, qualify, and route opportunities submitted through our intake form; to respond to your inquiries and communicate about potential engagements; to deliver our newsletter to subscribers; to improve the Site and our services based on aggregate usage data; to comply with legal obligations; and to enforce our Terms of Service. We process your information on the following lawful bases under applicable data protection law: your consent (e.g., subscribing to our newsletter), the performance of a contract or steps taken at your request prior to entering into a contract (e.g., evaluating your intake submission), our legitimate business interests (e.g., improving the Site, responding to inquiries), and compliance with legal obligations.

04

How We Share Your Information

We do not sell your personal information. We do not rent, trade, or otherwise make your personal information available to third parties for their own marketing purposes. We share your information only in the following circumstances:

Service providers. We share data with third-party services that help us operate the Site, including Formspree (form processing) and Cloudflare (hosting and analytics). These providers are contractually obligated to use your data only for the services they provide to us.

Opportunity routing. If you submit an opportunity through our intake form, the information you provide may be shared with downstream entities within our network — including licensed broker-dealers, investment advisers, real estate groups, government contracting teams, or consulting arms — as part of our qualification and routing process. This sharing is necessary to evaluate and connect your opportunity with the appropriate resource. We share only the information relevant to the routing decision. To be clear: data sharing for routing purposes is an operational function. Apex Scalers does not share your information for the purpose of soliciting securities, recommending investments, or facilitating transactions. Where a routed opportunity involves a licensed entity, that entity operates under its own registration, supervision, and privacy obligations.

Referral partners. If your opportunity does not fit any internal lane, we may refer it to a third-party partner. Before sharing your information with any external referral partner, we will notify you and obtain your consent unless the information has already been de-identified.

Legal requirements. We may disclose your information if required by law, subpoena, court order, or government request, or if we believe in good faith that disclosure is necessary to protect our rights, your safety, or the safety of others, investigate fraud, or respond to a government request.

05

Data Retention

We retain your personal information only for as long as necessary to fulfill the purposes for which it was collected, including satisfying legal, accounting, or reporting requirements. Intake form submissions are retained for the duration of any active evaluation or engagement, plus a reasonable period afterward for record-keeping and compliance purposes. Newsletter subscriber data is retained until you unsubscribe. When data is no longer needed, it is securely deleted or anonymized.

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Data Security

We implement reasonable administrative, technical, and physical safeguards to protect your personal information against unauthorized access, alteration, disclosure, or destruction. The Site is served over HTTPS with TLS encryption. Form submissions are transmitted over encrypted connections. However, no method of transmission over the internet or method of electronic storage is completely secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.

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Regulatory Context and Data Handling

Apex Scalers, LLC is not registered with the U.S. Securities and Exchange Commission ("SEC"), the Financial Industry Regulatory Authority ("FINRA"), or any state securities regulator. We are not a broker-dealer, investment adviser, or any other type of regulated securities entity. Our data collection and processing activities relate exclusively to marketing operations, opportunity qualification, and administrative routing — not to securities solicitation, investment advice, or transaction execution.

Regulatory inquiries. If a regulatory body — including the SEC, FINRA, a state securities commissioner, or other government authority — requires information about our data collection practices, routing methodology, or the disposition of specific opportunities, we will cooperate fully. Regulatory requests should be directed to hello@apexscalers.com with "Regulatory Inquiry" in the subject line.

Routing ledger. All opportunity evaluations, dispositions, and handoffs are recorded in an internal routing ledger. This ledger documents the input channel, qualification criteria applied, routing decision, and final destination for each opportunity. It is maintained as part of our compliance practices and is available to support regulatory review upon lawful request. For a complete description of our regulatory posture, compensation structure, and handoff protocols, see our Compliance Posture page and our Terms of Service.

08

Your Rights Under California Law (CCPA/CPRA)

If you are a California resident, the California Consumer Privacy Act as amended by the California Privacy Rights Act ("CCPA") provides you with specific rights regarding your personal information:

Right to know. You have the right to request that we disclose the categories and specific pieces of personal information we have collected about you, the categories of sources from which it was collected, the business purposes for collecting it, and the categories of third parties with whom it was shared.

Right to delete. You have the right to request that we delete the personal information we have collected from you, subject to certain exceptions (such as legal compliance or completing a transaction you requested).

Right to correct. You have the right to request that we correct inaccurate personal information we maintain about you.

Right to opt out of sale or sharing. We do not sell your personal information, and we do not share your personal information for cross-context behavioral advertising. Therefore, there is no need to opt out. If this practice ever changes, we will provide a clear opt-out mechanism before any such sharing begins.

Right to limit use of sensitive personal information. We do not collect categories of information classified as "sensitive personal information" under the CCPA.

Non-discrimination. We will not discriminate against you for exercising any of your CCPA rights.

To exercise any of these rights, contact us at hello@apexscalers.com. We will verify your identity before processing your request and respond within 45 days as required by law.

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Your Rights Under European Data Protection Law (GDPR)

If you are located in the European Economic Area (EEA), the United Kingdom, or Switzerland, you have additional rights under the General Data Protection Regulation ("GDPR") and equivalent legislation:

Right of access. You can request a copy of the personal data we hold about you.

Right to rectification. You can request that we correct any inaccurate or incomplete personal data.

Right to erasure. You can request that we delete your personal data where there is no compelling reason for us to continue processing it.

Right to restrict processing. You can request that we restrict the processing of your personal data in certain circumstances.

Right to data portability. You can request that we provide your personal data in a structured, commonly used, machine-readable format.

Right to object. You can object to our processing of your personal data where we are relying on a legitimate interest as the legal basis.

Right to withdraw consent. Where we process your data based on your consent (such as newsletter subscriptions), you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out before you withdrew consent.

To exercise any of these rights, contact us at hello@apexscalers.com. We will respond within 30 days. If you believe we have not adequately addressed your concerns, you have the right to lodge a complaint with your local data protection supervisory authority.

International data transfers. If you are located outside the United States, your personal data will be transferred to and processed in the United States, where Apex Scalers is based. The United States may not provide the same level of data protection as your home jurisdiction. By submitting your data, you consent to this transfer. We take steps to ensure your data is treated securely and in accordance with this Privacy Policy regardless of where it is processed.

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Additional U.S. State Privacy Rights

Residents of Virginia (VCDPA), Colorado (CPA), Connecticut (CTDPA), Utah (UCPA), Texas (TDPSA), Oregon (OCPA), Montana (MCDPA), and other states with comprehensive privacy laws may have additional rights including the right to access, correct, delete, and obtain a copy of their personal data, as well as the right to opt out of targeted advertising and profiling. We do not engage in targeted advertising or profiling based on personal information collected through this Site. To exercise your rights under any applicable state privacy law, contact us at hello@apexscalers.com.

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Children's Privacy

The Site is not directed to individuals under the age of 16. We do not knowingly collect personal information from children under 16. If you are a parent or guardian and believe your child has provided us with personal information, please contact us at hello@apexscalers.com and we will promptly delete it.

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Do Not Track Signals

Our Site does not respond to "Do Not Track" browser signals because there is no industry-standard protocol for honoring such signals. However, our use of Cloudflare Web Analytics means we do not track individual users in the first place — the analytics are aggregated and anonymous by design.

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Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes, we will update the "Last updated" date at the top of this page. If changes are significant, we may provide additional notice such as a banner on the Site. We encourage you to review this page periodically. Your continued use of the Site after changes are posted constitutes your acceptance of the revised policy.

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Contact Us

If you have questions about this Privacy Policy, wish to exercise your data rights, or have a privacy concern, contact us at:

Apex Scalers, LLC
Email: hello@apexscalers.com
Website: apexscalers.com/contact/

For privacy-specific requests, please include "Privacy Request" in your subject line so we can route your inquiry appropriately.