Legal

Privacy Policy

Last updated: April 24, 2026

This Privacy Policy explains how DXA Pearl LLC and its affiliates (“Dealboard,” “we,” “us,” or “our”) collect, use, disclose, and protect personal information when you visit our websites, create an account, or use the Dealboard platform and related services (collectively, the “Services”).

By using the Services, you agree to the practices described in this policy. If you do not agree, please do not use the Services.

1. Who we are

Dealboard is an investment technology platform that helps investors build and manage diversified portfolios of private market opportunities curated by professional advisors. The Services are operated by DXA Pearl LLC. For privacy inquiries, contact us at legal@dealboard.com.

2. Information we collect

2.1 Information you provide

  • Account and identity data: name, email address, phone number, password credentials, profile photo, and preferred language.
  • Know-your-customer (KYC) and onboarding data: date of birth, nationality, tax identification numbers, government-issued identification, address, proof of residence, source of funds, investor qualification information, and accredited or qualified investor status where applicable.
  • Financial and investment data: bank and wire instructions, investment amounts, allocations, subscription documents, capital call responses, distributions, and portfolio activity.
  • Communications: messages you send to us or to your advisor through the platform, support requests, and survey responses.

2.2 Information collected automatically

  • Device and usage data: IP address, browser type, operating system, device identifiers, referring URLs, pages viewed, and actions taken on the platform.
  • Cookies and similar technologies: see our Cookie Policy for details on what we set and how to control them.
  • Log and security data: authentication events, session timestamps, and security-related signals used to protect your account.

2.3 Information from third parties

  • Identity verification providers who help us confirm your identity and screen for sanctions, politically exposed persons, and adverse media.
  • Authentication providers (such as Clerk) used to secure sign-in.
  • Your advisor or financial institution, where they invite you to the platform or share portfolio data on your behalf.
  • Fund administrators and custodians who provide transaction, valuation, and tax reporting data.

3. How we use your information

We use personal information to:

  • Provide, operate, and maintain the Services, including creating your account, processing allocations, and displaying your portfolio.
  • Verify your identity, perform KYC/AML checks, and comply with applicable laws and regulations.
  • Communicate with you about your account, transactions, capital calls, distributions, and material platform updates.
  • Secure the Services, detect and prevent fraud, abuse, and unauthorized access.
  • Improve our products, analyze usage patterns, and develop new features.
  • Send marketing communications where permitted by law. You may opt out at any time through the unsubscribe link in our emails or by contacting us.
  • Comply with legal obligations and enforce our agreements.

4. Legal bases for processing

Where the EU or UK General Data Protection Regulation applies, we rely on one or more of the following legal bases: (a) performance of a contract with you; (b) compliance with a legal obligation; (c) our legitimate interests in operating and securing the Services; and (d) your consent, where required.

5. How we share information

We do not sell your personal information. We share it only as described below:

  • With your advisor and advisory firm, who use Dealboard to manage your portfolio and communicate with you.
  • With service providers that support the Services, including cloud hosting, authentication, analytics, identity verification, payment and banking partners, email delivery, and customer support, bound by confidentiality obligations.
  • With fund administrators, custodians, and issuers necessary to execute and record your investments.
  • With regulators, law enforcement, or other authorities when required by law, regulation, subpoena, or legal process, or to protect our rights, users, or the public.
  • In a corporate transaction such as a merger, acquisition, financing, or sale of assets, in which case we will require the recipient to honor this Privacy Policy.
  • With your consent or at your direction.

6. International transfers

Dealboard operates across multiple jurisdictions, and your personal information may be processed in countries other than your country of residence, including the United States and Brazil. Where required, we implement appropriate safeguards (such as standard contractual clauses) for international transfers.

7. Data retention

We retain personal information for as long as necessary to provide the Services, comply with legal and regulatory obligations (including recordkeeping requirements for investment and anti-money-laundering regulations), resolve disputes, and enforce our agreements. Retention periods may extend beyond the closure of your account where mandated by law.

8. Security

We apply administrative, technical, and organizational measures designed to protect your personal information, including encryption in transit, access controls, monitoring, and regular reviews. No system is fully secure, however, and you are responsible for keeping your account credentials confidential.

9. Your privacy rights

Depending on your jurisdiction, you may have the right to:

  • Access the personal information we hold about you.
  • Request correction of inaccurate or incomplete data.
  • Request deletion of your data, subject to legal retention.
  • Object to or restrict certain processing.
  • Request portability of your data.
  • Withdraw consent where processing is based on consent.
  • Lodge a complaint with your local data protection authority.

To exercise these rights, contact us at legal@dealboard.com. We may need to verify your identity before responding.

10. Children’s privacy

The Services are not directed to individuals under 18. We do not knowingly collect personal information from minors. If you believe a minor has provided us with personal information, please contact us and we will take appropriate steps to delete it.

11. Third-party links

The Services may contain links to third-party websites or services. Their privacy practices are governed by their own policies, and we are not responsible for their content or practices.

12. Changes to this policy

We may update this Privacy Policy from time to time. When we do, we will revise the “Last updated” date above. Material changes will be notified through the Services or by email.

13. Contact us

Questions, requests, or complaints about this Privacy Policy can be sent to:

DXA Pearl LLC
Attn: Privacy
legal@dealboard.com