Privacy Policy

1. Who We Are; Related Entities

1.1 The Platform is operated by Acquisition Lab Ops LLC, and this Privacy Policy is issued by Acquisition Lab Ops LLC as the entity responsible for personal information collected through the Platform.

1.2 The Acquisition Lab brand is operated by more than one legal entity. This Privacy Policy describes when information is shared with the following affiliated entities: (a) AL Marketplace LLC (“AL Marketplace”), which operates off-market (Direct) deal sourcing and is the counterparty to each per-deal Direct Deal Access Agreement; (b) SHV Management LLC (“SHV Management”), whose capital team reviews deals users submit for potential investment; and (c) SHV Fund I LP (“SHV Fund I”), an affiliated fund that may, at a user’s request, evaluate co-investment in a user’s deal. When these entities receive personal information as described in Section 4.2, they use it only for the purposes described in this Privacy Policy and, where applicable, under the separate agreement governing the relevant Direct Deal, capital submission, or co-investment evaluation.

2. Information We Collect

2.1 Information you provide directly. Depending on how you use the Platform, this may include:

• (a) Identity and contact information, such as your full name, mailing address, phone number, email address, and LinkedIn profile URL.
• (b) Account credentials and account settings.
• (c) Buyer profile information, such as your acquisition criteria, investment thesis, available capital ranges, experience, and background.
• (d) Financial information you enter in the personal financial statement tool (the “PFS Tool”), and related financing readiness information.
• (e) Membership application and enrollment information.
• (f) Payment information, which is collected and processed by our third-party payment processor. We do not store or have access to your full credit card numbers.
• (g) For capital program (fund) applicants only: additional diligence information such as government-issued identification, tax forms, financial statements, and Social Security Number or Taxpayer Identification Number, collected solely for credit and background check purposes with your separate written authorization, as described in Section 3.2(e).
• (h) Citizenship or immigration status, where relevant to eligibility criteria, for example financing programs such as SBA-guaranteed loans that have eligibility requirements.
• (i) Communications and community content, such as forum posts, comments, messages, and support requests.
• (j) Recordings of video-conferencing calls, live sessions, and events, as described in the Terms.
• (k) Information you provide to form a business entity through the entity setup tool, which we pass to the third-party formation service at your direction.
• (l) Deal submissions, transaction reports, and acquisition disclosures.

2.2 Information collected automatically. When you use the Platform, we and our service providers automatically collect log data (such as IP address, browser type, pages visited, and time spent on pages), device identifiers, and information collected through cookies, pixels, and similar technologies, as described in Section 5.

2.3 Information from other sources. We may receive: (a) preapproval results, including preapproval amounts, from lenders or financing partners with whom you elected to share your PFS data, which we use to display your preapproval badge if you choose; (b) information from service providers, such as analytics providers and communication platforms; (c) publicly available information and information from third-party data feeds used to compile Aggregated deal listings, which may include business contact information of business owners, brokers, and their representatives; and (d) information from referral or marketing partners.

2.4 No biometric identifiers. We do not collect biometric identifiers.

3. How We Use Information

3.1 To provide the Platform. We use personal information to create and administer accounts, host and format buyer profiles, operate the community forum, deliver the membership programs and events, provide the deal marketplace, operate the PFS Tool and other tools, process payments through our processor, and provide support.

3.2 Specific uses connected to Platform features:

• (a) Buyer profiles. We display and share your profile according to your visibility settings and the sharing choices you make, as described in the Terms. Profiles are private by default.
• (b) PFS Tool and preapproval badge. We use PFS data to operate the PFS Tool, to share your PFS data with lender partners you select, and, if a lender or financing partner issues a preapproval, to display a preapproval badge on your profile at your election. Some lender partners have a general sponsorship or other commercial relationship with the Company that is independent of any particular referral or per-referral compensation. Lender partners do not pay the Company per-referral compensation for these introductions.
• (c) Deal marketplace. When you request access to a Direct deal, we share information with AL Marketplace LLC as described in Section 4.2 to administer your Direct Deal Access Agreement and your access to that deal.
• (d) Capital program. When you submit a deal for investment consideration, the capital team at SHV Management LLC reviews your submission, and the capital team may review PFS data internally in connection with evaluating capital program fit.
• (e) Credit and background checks (fund applicants). For fund applicants, we or the capital team obtain consumer credit reports or background reports only with your separate written authorization at the point of collection, as required by the Fair Credit Reporting Act and other applicable law. The Privacy Policy does not itself authorize any report. Social Security Numbers and Taxpayer Identification Numbers are collected only for this purpose and handled as described in Sections 6.4 and 7.3.
• (f) Fund co-investment. If you ask SHV Fund I LP to evaluate a co-investment, we share the information needed for that evaluation.
• (g) Program analytics, case studies, and marketing. We may use program participation and disclosed acquisition information for program analytics, case studies, and marketing, subject to the confidentiality and persona release provisions of the Terms.
• (h) Program fit. We may use Platform data, including PFS-derived attributes and usage data, internally to identify users who may be a fit for Acquisition Lab programs, such as the EIR and capital programs, and to tell those users about them.

3.3 Communications. We use contact information to send transactional communications, and, with your consent or as otherwise permitted by law, marketing and promotional communications. You can opt out of marketing email at any time using the unsubscribe link, and out of SMS by replying STOP, as described in the Terms.

3.4 AI features. The Platform includes AI-generated features such as deal summaries, matching, and PFS feedback. We train and improve models using only aggregated or de-identified data, meaning data that does not identify you or any other individual. We do not use materials submitted under a non-disclosure agreement to train models, and we do not train models on your identifiable content.

3.5 Aggregated and de-identified data. We create and use aggregated or de-identified data for analytics, research, benchmarking, industry reporting, and content, and we maintain and use such data in de-identified form only.

3.6 Security, legal, and safety. We use information to secure the Platform, prevent fraud and abuse, enforce our agreements, comply with legal obligations, and protect the rights and safety of users and others.

4. How We Share Information

4.1 At your direction. We share information when you direct us to: when you share your profile link or enable a visibility setting (in-platform discoverability or a fully public profile); when you opt in to share PFS data with a lender partner; when you display or share your preapproval badge; when you submit a deal to the capital team; and when you send information to another user. Anyone who can view your profile may save or forward it.

4.2 Affiliated entities. We share information with the entities identified in Section 1.2 as follows: with AL Marketplace, the account and profile information reasonably needed to administer your Direct Deal Access Agreements and your access to Direct deals; with SHV Management, your capital submissions and related information, including PFS data as described in the Terms; and with SHV Fund I, information needed to evaluate a co-investment you request. Each entity uses the information only for the purposes described in this Privacy Policy and, where applicable, under the separate agreement governing the relevant transaction, submission, or co-investment evaluation.

4.3 Service providers. We share information with service providers that host and operate the Platform on our behalf, including hosting, analytics, payment processing, email and SMS delivery, video conferencing and recording, community platform, and customer support providers, in each case under agreements that limit their use of the information to providing services to us.

4.4 Entity formation service. If you use the entity setup tool, we pass the information you provide to the third-party formation service at your direction. The formation service processes that information under its own terms and privacy policy.

4.5 Consumer reporting and background check providers. For fund applicants who have provided separate written authorization, we share the information needed to obtain credit reports or background reports with the applicable consumer reporting agencies or background check providers.

4.6 Community visibility. Information you post in forums, comments, or other collaborative areas is visible to other participants in those areas, as described in the Terms.

4.7 Advertising partners. We use advertising cookies and pixels from ad platforms as described in Section 5. Disclosures of information through these technologies may constitute “sharing” or, in some states, a “sale” or use for “targeted advertising” as those terms are defined by applicable state privacy laws, even though we do not sell personal information for money. You can opt out of these disclosures and uses through the mechanisms described in Sections 5 and 6, including the “Do Not Sell or Share My Personal Information” link and recognized universal opt-out mechanisms.

4.8 Business transfers. Information may be disclosed or transferred as part of a merger, acquisition, financing, reorganization, or sale of assets, subject to reasonable confidentiality protections.

4.9 Legal and safety. We disclose information where required by law, regulation, or legal process, or where reasonably necessary to protect the rights, property, or safety of the Company, our users, or others.

4.10 SMS data. Your mobile phone number, SMS opt-in data, and SMS consent are excluded from all information-sharing categories described in this Privacy Policy. We do not share them with any third party, except for the delivery providers necessary to send the messages you have requested.

5. Cookies and Tracking Technologies

5.1 What we use. The Platform uses: (a) essential cookies, required for the Platform to function; (b) analytics cookies and tools, including Google Analytics, which help us understand how users interact with the Platform (you can opt out of Google Analytics at https://tools.google.com/dlpage/gaoptout/); and (c) advertising cookies and pixels from ad platforms, which help us measure and deliver marketing.

5.2 Your controls. You can manage cookies through your browser settings; opt out of sale, sharing, or targeted advertising associated with advertising technologies through the “Do Not Sell or Share My Personal Information” link on our website; and use a universal opt-out mechanism, including the Global Privacy Control (GPC) browser signal, where available. We recognize GPC and any other universal opt-out mechanism required by applicable law, and we treat a signal from any such mechanism as a valid request to opt out of sale, sharing, and targeted advertising, as applicable, for the browser, device, or account associated with the signal. We will process recognized signals in accordance with applicable law. Apart from recognized universal opt-out mechanisms, the Platform does not respond to “Do Not Track” signals.

6. Your Privacy Rights and Choices

6.1 Rights. We extend the following rights to all users, regardless of state of residence: the right to know and access the personal information we have collected about you; the right to correct inaccurate personal information; the right to delete your personal information; the right to receive a copy of your personal information in a structured, machine-readable, and commonly used format; the right to opt out of the sale or sharing of your personal information or the use of your personal information for targeted advertising, as those terms are defined by applicable law; the right to limit the use and disclosure of your sensitive personal information to what is necessary to provide the Platform or for the specific purposes described in this Privacy Policy; the right to appeal a denial of a privacy request; and the right not to be discriminated against for exercising any of these rights. We will not deny you services, charge different prices, or provide a different level of service because you exercised a privacy right.

6.2 How to exercise your rights. Submit a request through our privacy request form at acquisitionlab.com/privacy-request or by email to support@acquisitionlab.com. We will verify your request using information associated with your account, and we may ask for additional verification. You may use an authorized agent, in which case we may require proof of the agent’s authority. We will respond within 45 days; if additional time is needed, we will notify you and explain why, up to a maximum of 90 days, unless applicable law requires a shorter period. If we decline a request, in whole or in part, we will explain the basis for the decision and inform you of your right to appeal. You may appeal by replying to our decision or through the privacy request form within 45 days after we notify you of the decision. A reviewer who was not involved in the original decision will consider the appeal, and we will respond in writing within 60 days or within the period required by applicable law. If we deny your appeal, we will explain the basis for that decision and, where required by applicable law, provide information about how to submit a complaint to the applicable state attorney general or other regulator.

6.3 Opt-outs and profile controls. You can: opt out of sale, sharing, and targeted advertising through the website link, GPC, or another recognized universal opt-out mechanism (Section 5.2); opt out of marketing email via the unsubscribe link; opt out of SMS by replying STOP; change your profile visibility settings at any time, including reverting a discoverable or public profile to private; reset your profile link to revoke access by anyone holding the old link; and deactivate your account, which ends profile availability.

6.4 Sensitive personal information. We collect sensitive personal information only where reasonably necessary for the specific purposes described in Sections 3 and 4 and subject to your choices and any required consent or authorization. We do not use or disclose sensitive personal information beyond those purposes, including to infer characteristics about you. We collect Social Security Numbers and Taxpayer Identification Numbers from fund applicants only to obtain authorized credit or background reports and only with the separate written authorization required by Sections 3.2(e) and 4.5.

7. Retention

7.1 Account and profile data are retained for the duration of your account and for up to 24 months after account closure, unless a longer period is required by law. Log and usage data are retained for up to 12 months for operational and security purposes.

7.2 When you replace or update your personal financial statement, superseded PFS versions and associated sensitive records are securely deleted within 30 days of replacement, except where retention is required by law.

7.3 For fund applicants, credit and background check records, including Social Security Numbers and Taxpayer Identification Numbers, are retained for the period necessary to complete the evaluation and for at least five (5) years after the final decision on the application, subject to any longer period required by applicable law, including applicable requirements under the Fair Credit Reporting Act and state law and applicable EEOC record-retention guidance, and are then securely deleted.

7.4 Recordings of group sessions, programming, and events may be retained as part of the program library for the life of the applicable program. Payment records are retained by our payment processor and as required for tax and accounting purposes.

8. Security

We use reasonable administrative, technical, and physical safeguards designed to protect personal information, including HTTPS, encryption of data in transit and at rest, and access controls limiting internal access to personal information on a need-to-know basis. Where required by applicable law, we conduct and document data protection assessments for processing activities that present heightened risks, including processing sensitive personal information, profiling, targeted advertising, and the sale or sharing of personal information. If we determine that a data security incident has affected your personal information, we will notify you and any applicable regulators as required by applicable law, including within any timeframe required by law. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

9. International Users

The Platform is operated from the United States and is intended for US users. If you access the Platform from outside the US, you understand that your information will be transferred to, stored, and processed in the US, where privacy laws may differ from those in your jurisdiction. Depending on the circumstances and applicable law, we rely on your consent, the necessity of the transfer to perform a contract with you or take steps at your request before entering into a contract, compliance with legal obligations, or another lawful basis for the transfer and processing. We will obtain any consent or provide any notice required by applicable law.

10. Children’s Privacy

The Platform is intended for adults and is not directed to anyone under 18 years of age. We do not knowingly collect personal information from children under 13, and we comply with the Children’s Online Privacy Protection Act. If we learn that we have collected personal information from a child under 13, we will promptly delete it from our systems, unless retention is required by law. If you believe a child has provided us personal information, contact us.

11. Social Media Interactions

If you interact with us on social media platforms, or use social features that connect the Platform to social media, the social media platform’s own privacy policy applies to its collection and use of your information. Content you post publicly on social media is public.

12. Changes to This Policy

We may update this Privacy Policy from time to time. When we make material changes, we will notify you by email to the address associated with your account and will post the updated policy on the Platform with a new effective date. Non-material changes take effect when posted.

13. Contact Us

Questions, concerns, or requests regarding this Privacy Policy or your personal information may be directed to support@acquisitionlab.com, or submitted through our privacy request form at acquisitionlab.com/privacy-request. Mail may be sent to [Company notice address].