Aquitania Capital Management, LLC
Privacy Policy
September 30, 2020

The privacy practices of this Privacy Policy apply to our services available under the domain and subdomains of (the “Site”). We recognize that privacy is important to our users, so we design and operate our Site with the protection of your privacy in mind. This Privacy Policy outlines the types of personal information we may gather when you visit our Site or use our services, as well as some of the steps we take to safeguard it. Please read this Privacy Policy to learn more about the ways in which we protect, use, and disclose your personal information.


By visiting the Site, you agree to be bound by the terms and conditions of this Privacy Policy. If you do not agree, please do not use or access the Site.

By accepting the Privacy Policy and the Terms of Use, you expressly consent to our use and disclosure of your personal information in accordance with this Privacy Policy. This Privacy Policy is incorporated into and subject to the terms of the Terms of Use. This Privacy Policy is effective on September 30, 2020 for all users.


We have adopted general policies and procedures concerning confidentiality, proprietary data, and privacy of customer personal information. The information we gather over the Site is protected by those policies and procedures. Generally, we collect non-public personal information about our clients and investors from the following sources:

Information we receive from clients and investors on applications or other forms, including the information we collect on the Site, and

Information about clients’ or investors’ transactions with us, our affiliates, or others.

Our policy is that:

We do not disclose any non-public personal information about our current or former clients or investors to anyone, except as permitted by law. We may voluntarily disclose non-public personal information about our current and former clients or investors to regulatory authorities in connection with our business or our affiliates. In addition, we share non-public personal information with certain service providers, to the extent permitted by law, and we require those service providers to keep the non-public information confidential. For example, we may provide such information to prime brokers, ISDA counterparties, attorneys, third-party marketing firms, fund administrators and auditors.

We restrict access to non-public personal information about our clients and investors to employees and service providers who need to know that information to provide services to our clients.

We maintain physical, electronic, and procedural safeguards that comply with federal standards to guard clients’ and investors’ personal information.

Collection of Information

In general, you can browse the Site without telling us who you are or revealing any personal information about yourself. We can automatically track certain information that your browser makes available whenever you visit a website. This information includes your Internet Protocol address, browser type, browser language and one or more files that may uniquely identify your browser. We may use this information to do internal research on our users’ demographics, interests, and behavior to better understand, protect and serve you and our clients. This information may include the URL from which you just came (whether this URL is on the Site or not), to which URL you next go (whether this URL is on the Site or not), your computer browser information and your IP address. We may use this information to operate, develop and improve our services.

We also may use data collection devices such as “cookies” on certain pages of the Site to help analyze our web page flow, measure effectiveness, and promote trust and safety. “Cookies” are small files placed on your hard drive that assist us in providing our services. We offer certain features that are only available through the use of a “cookie”. Cookies can also help us provide information that is targeted to your interests. Most cookies are “session cookies,” meaning that they are automatically deleted from your hard drive at the end of a session. You are always free to decline our cookies if your browser permits. We may use cookies to better understand how people interact with us.

Use and Disclosure of Information

We may use the information we collect from our browser and data collection devices such as cookies to improve our operations and facilitate the services you request. We may use information collected from you to measure interest, customize your experience and enforce our Terms of Use.We may also share information about you if we believe that disclosure is required by law. For example, we may need to disclose information in response to a subpoena or to cooperate with regulatory or law enforcement authorities.


Your information is stored on our servers located in the United States. We use procedural and technical safeguards to protect your personal information against loss or theft as well as unauthorized access and disclosure to protect your privacy, which may include encryption, “firewalls” and Secure Socket Layers. We treat data as an asset that must be protected against loss and unauthorized access. We employ security techniques to protect such data from unauthorized access by users inside and outside the company. However, “perfect security” does not exist on the Internet.


Persons under the age of 18 are not eligible to use the Site.

Conditions of Use

If you choose to visit the Site, your visit and any dispute over privacy is subject to this Privacy Policy and our Terms of Use, including limitations on damages and application of Texas law. If you have any concern about privacy, please send a thorough description to

Changes to this policy

Please note this Privacy Policy may change from time to time. We may amend this Privacy Policy at any time by posting the amended terms on the Site. All amended terms shall automatically be effective 30 days after they are initially posted on the Site.

If you have any additional questions, please feel free to contact us any time at