Privacy Policy

Effective May 1, 2026

Introduction

Texture Capital Inc. (“Texture,” “we,” “us” or “our”) has implemented this Privacy Policy (“our Privacy Policy” or “this Privacy Policy”) to set forth our practices for collecting, using, storing, sharing, protecting, and disclosing the personal information (“Personal Information”) that you may provide to us in connection with the services we offer. We value and respect your privacy and through compliance with this Privacy Policy, we are committed to protecting it.

Texture Capital Inc. is a FINRA-registered broker-dealer and operator of an SEC-registered Alternative Trading System (ATS); together with our affiliated SEC-registered transfer agent, Texture Transfer Services Inc., we are subject to federal privacy and information-security obligations including Regulation S-P, the Gramm-Leach-Bliley Act, and applicable state laws including New York General Business Law. These laws and regulations oblige us to gather personal information and underpin and inform our Privacy Policy.

Personal Information We Collect

We may collect Personal Information about you that is either provided to us by you or obtained by us with your authorization in connection with the services we provide. The Personal Information we collect, verify and authenticate, may include the following:

Registration Information

Individual Customers:

Full legal name;
Date of birth;
Proof of identity (g., driver’s license, passport or government-issued ID);
Social Security Number or comparable government-issued identification number;
Email address;
Mobile phone number;
Physical home address (not a mailing address or P.O. Box);
Additional Personal Information or documentation;
Bank account information;
Biometric or document-derived data (such as facial-image and document-image data captured solely for identity verification through our third-party identity-verification provider, retained only for the period required to complete and evidence verification); and
Source-of-funds and tax-residency information required by anti-money-laundering, know-your-customer, and tax-reporting rules.

Institutional Customers:

Institution legal name;
Employer Identification Number or comparable government-issued identification number;
Full legal name (of all account signatories and beneficial owners);
Email address (of all account signatories);
Mobile phone number (of all account signatories);
Address (principal place of business and/or other physical location);
Proof of legal existence (e.g., state certified articles of incorporation or certificate of formation, unexpired government-issued business license, trust instrument, or other comparable legal documents as applicable);
Contract information of owners, principals, and executive management (as applicable);
Proof of identity (e.g., driver’s license, passport or government-issued ID) for each individual beneficial owner that owns 10% or more of the institutional customer entity, as well as all account signatories;
Personal Information for each entity beneficial owner that owns 10% or more of the institutional customer entity (see the “Individual Customer” section above for details on what Personal Information we collect for individuals); and
Additional Personal Information or documentation.

Electronic Communication Information

When you use our services some information is automatically collected. Such information could include your operating system, IP address, general statistics about your activities on our website, the site from which you linked to us ("referring page"), the name of the website you choose to visit immediately after ours (called the "exit page"), information about other websites you have recently visited, browser (software used to browse the internet) type and language, device identifier numbers, your site activity, and the time and date of your visit. Because there is no industry-standard interpretation of “Do Not Track” signals, we do not respond to them at this time; we do, however, honor browser-level cookie controls and the third-party opt-outs described below.

Cookies

Cookies are alphanumeric identifiers that we may transfer to your computer’s hard drive through your web browser to help us identify you when you return to our services. You have choices with respect to cookies. By modifying your browser preferences, you have the choice to accept all cookies, to be notified when a cookie is set, or to reject all cookies. If you choose to reject all cookies you may be unable to use those aspects of our services that require registration in order to participate. You can always disable cookies through your browser settings. Doing so, however, may disable certain features on our services.

Analytics

We may use third parties, such as Google Analytics or other analytics providers, to analyze traffic to our services. Google Analytics does not create individual profiles for visitors and only collects aggregate data. To disable Google Analytics, please download the browser add-on for the deactivation of Google Analytics provided by Google.

Other Tracking Technologies

In addition to cookies, we may also use pixels, beacons, or other web tracking technologies to track the amount of time spent on our services and whether or not certain content, such as a video, was viewed. We may work with a third party to collect and process this information for us, based on our instructions and in compliance with this Privacy Policy.

Why Does Texture Collect Electronic Information?

Texture may use Electronic Information to improve the performance of the website, your experience on the site, and otherwise as deemed appropriate by Texture.

Personal Information Usage

We use information, including Personal Information, for internal and service-related purposes and may provide it to third parties to allow us to facilitate the services we offer. We may use and retain any data we collect to provide and improve our services. In addition, we use the Personal Information to enforce applicable Policies, Procedures, Agreements, to provide customer support, to provide services-related communications, to maintain legal and regulatory compliance records.

More specifically, we use Personal Information for the following permitted purposes, consistent with the use limitations of Regulation S-P and the Gramm-Leach-Bliley Act:

to open, administer, service, and close customer accounts;
to verify identity and to satisfy our anti-money-laundering, know-your-customer, sanctions-screening, suitability, and tax-reporting obligations;
to effect, administer, or enforce transactions in securities and to provide ancillary services such as cap-table maintenance and corporate actions;
to maintain books and records as required by SEC, FINRA, and other applicable regulators;
to detect, prevent, investigate, and respond to fraud, security incidents, and unauthorized access;
to comply with subpoenas, court orders, regulatory examinations, and other legal process; and
for any other purpose with your consent or as otherwise permitted or required by law.

Sharing of Personal Information

We do not sell your Personal Information. We share Personal Information only as described below and only as permitted under Regulation S-P and other applicable law.

Affiliated Companies

We may share any information, including Personal Information, with affiliates and subsidiaries, as permitted by law or with your consent. Sharing among affiliates is conducted under intra-group resource-sharing agreements that require equivalent confidentiality and information-security protections.

Vendors and Service Providers

We may share any information we receive with vendors and service providers retained in connection with the provision of the services we offer. Such providers may include identity-verification, custody, payment, cloud-hosting, communications, analytics, and professional-services providers. We engage service providers only under written contracts that limit their use of Personal Information to the purposes for which it was disclosed, require them to maintain reasonable administrative, technical, and physical safeguards, require prompt notification to us of suspected security incidents, and require return or destruction of Personal Information at the conclusion of the engagement, consistent with the service-provider oversight requirements of Regulation S-P (17 CFR § 248.30(a)(5)).

Disclosures Required or Permitted by Law

We may disclose Personal Information without your authorization where permitted or required by law — including in response to subpoenas, court orders, regulatory examinations, and law-enforcement requests; in connection with the prevention or investigation of fraud, security incidents, or other unlawful activity; to protect our rights or those of our customers; and in connection with a merger, acquisition, financing, or sale of all or part of our business, in which case the recipient will be required to honor this Privacy Policy.

Updates to Our Privacy Policy

Your Right to Opt Out of Certain Information Sharing

Regulation S-P gives you the right to opt out of sharing your nonpublic personal information with nonaffiliated third parties for non-essential purposes. Texture does not currently engage in any such sharing. If that changes, we will notify you and provide an opt-out opportunity before it occurs.

Safeguarding Your Personal Information

Texture maintains a written information-security program, approved by senior management and reviewed at least annually, that is designed to protect the confidentiality, integrity, and availability of customer Personal Information and to comply with the Safeguards Rule under Regulation S-P and with the standards of state law. The program includes:

Administrative safeguards — designation of a qualified individual responsible for the program; risk assessments conducted at least annually and on material change; written policies and procedures for access control, change management, vendor due diligence, and personnel security; and ongoing security-awareness training for employees and contractors;
Technical safeguards — access controls based on least privilege; multi-factor authentication for remote access and privileged access; encryption of Personal Information in transit and at rest where reasonable; logging and monitoring of system activity; secure software-development practices; and timely application of security patches;
Physical safeguards — controls over physical access to facilities and devices that store Personal Information; secure media-handling and device-disposal procedures; and protections against environmental hazards.

Records Retention and Disposal

We retain Personal Information only for as long as reasonably necessary to provide the services, to comply with our legal and regulatory record-retention obligations, to resolve disputes, and to enforce our agreements. When Personal Information is no longer needed for these purposes, we dispose of it in a manner reasonably designed to prevent unauthorized access or use, consistent with the Disposal Rule and applicable state law.

Incident Response and Customer Notification

Texture maintains a written incident-response program reasonably designed to detect, respond to, and recover from unauthorized access to or use of customer Personal Information, as required by regulation. Following any incident involving the unauthorized access to or use of sensitive customer information, we will, without unreasonable delay and in any event no later than thirty days after we become aware that the incident has occurred or is reasonably likely to have occurred, provide notice to each affected individual whose sensitive customer information was, or is reasonably likely to have been, accessed or used without authorization. Our notice will describe plainly what happened, the categories of information involved, the steps we have taken in response, and the steps the affected individual can take to protect themselves, together with appropriate contact information — except in cases where the U.S. Attorney General has determined that such notification poses a substantial risk to national security or a substantive law-enforcement investigation.

Any contact concerning a known or suspected security incident affecting your information should be directed to security@texture.capital.

State-Specific Consideration

Texture's collection and use of customer Personal Information is exempt from state consumer privacy laws under applicable GLBA exemptions.

Children’s Privacy

Our services are intended for adults. We do not knowingly collect Personal Information from children under the age of 18. If we learn that we have collected Personal Information from a child without verified parental consent, we will delete it.

Changes to This Privacy Policy

We may update our Privacy Policy from time to time and such updates will be posted on our website. The effective date and the last revised dates of our Privacy Policy are identified on the top of the page. Where a change materially affects how we collect, use, or share your Personal Information, we will notify you by a prominent notice on our website prior to the change taking effect.

Contact Information

For any other questions, requests or concerns regarding the terms of our Privacy Policy or the way we utilize your Personal Information, please contact us by email at info@texture.capital. To report a known or suspected security incident affecting your information, contact security@texture.capital. The primary contact for Texture Capital Inc. is our Chief Compliance Officer.