What we hold, and why.

The short version

• This site sets one cookie, and only after you sign in — a copy of your sign-in token, so our server can check you are an investor. No advertising, no analytics, no pixels, no third-party scripts of any kind.
• Apart from that cookie we store six things in your browser, all of them first-party, all of them listed below.
• The only public page that asks for anything is the sign-in page, and it is for people ADJL Capital has already given an account. We hold information about you only if you have an account with us, if you joined the former waitlist, or if you email us — and, if you sign in through our sign-in system without having an investor account, the brief network-and-device record described under "When you sign in", which is deleted 90 days after the last sign-in from that network and device.
• We do not sell your information, share it for advertising, or use it to build a profile of you.
• You can ask us for a copy of what we hold, or ask us to delete it, and we will do it.

Who we are

ADJL Capital, LLC is a private investment firm. For anything in this policy we are the party responsible for the information described — the "controller", in the language of data protection law.

Write to us at daniel@adjlcapital.com.

What we collect, and when

These are the points where information reaches us, and they are the only ones.

The sign-in page. One public page has a form: the sign-in page at /invest/. It is for people ADJL Capital has already given an account, and it is there so they can sign in. It collects:

• your email address and password, when you sign in. They go to our sign-in provider, which checks them. Our own servers never receive your password;
• a new password, if you arrive from an invitation or a password reset email and choose one. It goes to our sign-in provider in the same way;
• your email address on its own, if you choose "Email me a sign-in link" or "Forgot your password?". It is used to send that one email. The page gives the same answer whether or not the address has an account, and asking for a sign-in link never creates one;
• the email address and name Google gives us, if you choose "Continue with Google" when that button is shown. Our sign-in provider keeps a record of that Google sign-in, but it opens nothing: access comes only from an account ADJL Capital has created for you.

The other public pages have no form and do not ask who you are.

If you are an investor and sign in. Your name and email address, whether you have opted in to update emails, and whatever is held in your account: information about your investment with us, material we share with you, and anything you choose to save in the portal's tools — the inputs you entered, the figures computed from them, and any notes you type.

If you list a holding of your own in the portal. A ticker symbol, and — only if you choose to type them — the security's name and how many shares you hold. That is the entire record. A symbol is all the feature needs; the quantity and the value are optional and it works without them.

Three things about that list, because it is the most sensitive thing this site holds:

• Nobody at ADJL can see it. Not even an administrator. That is enforced in the database rather than in the interface: the security rule on that table permits the owner of a row and nobody else, deliberately unlike every other table here, and we test that an administrator account reads zero rows before any release.
• We hold no account numbers, no credentials and no balances at your broker. There is no field for any of them.
• It is a list you type, not a connection to your account. We cannot see your account, cannot trade in it, and receive nothing from your broker.

When you sign in. Every sign-in to an investor account is recorded, and what is recorded is deliberately narrow: the first three parts of the network address you connected from, and the kind of device — iPhone, Mac, Windows. Not the whole address, not a city, not a country, not a coordinate, and nothing that identifies the particular machine. The reduction happens inside the database, so the full address never reaches our own code at all.

Separately, our sign-in provider keeps the full network address and the full browser description (the "user agent" your browser sends with every request) of each signed-in session, because it needs them to run and secure that session. They are held in the provider's own session table in our database, not in the sign-in record above, and our code reads them only through the same reduction. They last as long as that session does: signing out ends the session and removes them.

A sign-in through our sign-in system by somebody who turns out to have no investor account — an address that signed itself up without an invitation, for example — may be recorded in the same way, with the same two things and nothing more, and is deleted on the same 90-day schedule. It gives that person no access to anything.

It is there for one purpose: investor accounts are individual, and this is how we notice one being used by several people at once, or the sign-in system being used by people it was not meant for. It is not attendance, and we do not look at it to see when you are at your desk. Nothing about it is shared outside ADJL Capital.

If you email us. Whatever you put in the email.

Former waitlist. Until October 2026 this site had a waitlist. It is closed. If you joined it, we still hold what you gave us — your name, your email address and the choice you made — together with the page you signed up from, the date you joined, a record of the consent wording you agreed to and when you agreed to it, and the dates we emailed you, followed up with you or invited you, and when you unsubscribed, where any of those happened. We keep it until you ask us to delete it. The unsubscribe link in any email we sent you still works, and so does emailing daniel@adjlcapital.com.

We do not ask for, and have no use for, a date of birth, a telephone number, a postal address, or a financial account number through this website.

Cookies and browser storage

This site sets one cookie, and only after you sign in: __Host-adjl_at, a copy of your current sign-in token. It expires within an hour, is sent only to adjlcapital.com, and is used only so our server can check you are an investor before it sends a members' page. Signing out removes it. There are no advertising or analytics cookies.

Besides that cookie, we use your browser's own storage for six things. Every one is first-party, none of them identifies you to anybody else, and none of them follows you to another website.

You can clear all of them at any time from your browser's settings for this site. Nothing breaks; you will need to sign in again.

There is no consent banner on this site, and that is deliberate. Consent is required for storage that is not necessary for something you asked for. Everything above holds your sign-in, a note that this browser is signed in, the page you were on your way to when you asked to sign in by email or with Google, a piece of unfinished work, a guard that stops a page looping, or a presentational detail that stops a sentence repeating. A visitor who only reads the public pages gets none of it. Asking you to agree to that would be theatre, and it would train you to dismiss a banner that one day mattered. If we ever add anything that genuinely needs consent, the banner will arrive with it.

Why we hold it

We do not use any of it for automated decision-making that produces a legal or similarly significant effect. The portal's tools produce figures for a person to read; they do not decide anything about you.

Who else sees it

We do not sell your information, and we do not share it for anybody's advertising. We have no advertising.

These are the companies that process information on our behalf, and what each one gets. This is the complete list.

Two things worth being explicit about. The data providers and Anthropic are only ever contacted from our server, never from your browser — they receive no cookie of yours, no IP address of yours, and no way to associate a request with you. And commentary is written from what you entered, so whatever you typed into that piece of work leaves our systems with it. Signed-in investors can read which providers are used, and for which tool, in the members' disclosures.

The news headlines on the portal are fetched by our server from public feeds. Your browser never contacts those publishers.

We will also disclose information if the law requires it of us.

How long we keep it

Some of it is now deleted on a schedule, and some of it is not. This section used to say that nothing was deleted automatically, because that was true. A daily job now runs, and these are the periods it enforces:

• Records of tool use — which of our tools an investor opened and what they searched for — are deleted after 30 days. We keep them for two reasons: to stop any one account running up an unbounded bill against the data providers we pay, and so an administrator can see how the tools are being used. Neither reason survives a month.
• The IP hashes the former waitlist kept for its rate limit are cleared after 7 days. The waitlist accepts no new entries, so no new ones are being made.
• Sign-in records — the network and device described above — are deleted 90 days after the last sign-in from that network and device. A network and device used at least once every 90 days is therefore kept for as long as that keeps happening. Ninety rather than thirty because the thing worth noticing is a place that appears once and never again, and a shorter window would forget the first half of a quarter.
• The record of who invited whom is deleted after a year. It is an audit trail of account creation, which is a different kind of record and worth keeping longer.

The session record our sign-in provider keeps — the full network address and browser description of a signed-in session, described under "When you sign in" — lasts exactly as long as that session, and signing out removes it.

Everything else is kept until it is no longer needed or you ask us to remove it:

• Former waitlist entries are kept until you ask us to remove them. Using the unsubscribe link in any email marks you as unsubscribed and stops all mail; ask us and we will delete the record entirely.
• Investor accounts and their contents are kept for as long as you are an investor with us, and afterwards for as long as we are required to keep records of the relationship.
• Holdings you list in the portal are yours to remove at any time, from the portal itself, one at a time and without asking us. Deleting your account deletes them with it.

Who can see the records of tool use. Administrators can see, for each investor, when they were last active, how many times they used each tool, and the most recent thing they looked up — not a history of every search. It is shown to help us run the firm's provider costs and support our investors, and it is never shared outside ADJL Capital.

And the sign-in records. Administrators can see how many networks and device kinds an account has been used from, and whether more than one session is open at once. The screen states, beside every one of those figures, the ordinary explanation it cannot rule out — a phone on a mobile connection beside a laptop on wifi is two networks and is entirely normal. It is a reason to ask a question, never a conclusion, and there is no location on that screen because there is no location anywhere in this system.

Your rights

Whoever and wherever you are, you can ask us to:

• tell you what we hold about you, and give you a copy of it;
• correct anything that is wrong;
• delete it;
• stop emailing you, which you can also do yourself from the link at the bottom of any email;
• give you your information in a portable form, if you want to take it elsewhere;
• object to or restrict what we do with it.

Write to daniel@adjlcapital.com with enough detail for us to find you — the email address you gave us is usually enough. We may ask you to confirm who you are before we act, because handing somebody's information to the wrong person is the failure that matters most here.

We do not charge for this and we will respond within one month. If you are unhappy with how we handle it you can complain to your local data protection authority.

We do not sell personal information, and we do not share it for cross-context behavioral advertising — under any definition, including California's. There is no "do not sell" toggle on this site because there is nothing for it to switch off.

How it is protected

The measures below are real and specific, because a paragraph promising "industry-standard security" tells you nothing.

• Every page except the public landing page, the sign-in page, this privacy policy, the terms of use, the page-not-found page and the confirmation an email's unsubscribe link shows is sent only after our server has checked that the request comes from a signed-in investor. A page you are not signed in for is never sent to your browser at all.
• Every page is served over HTTPS, and the site sends a Content-Security-Policy that permits scripts only from our own origin. That is what stops a compromised third-party script from reading a signed-in investor's session token — and it is why this site carries no third-party scripts at all.
• Investor data is protected in the database by row-level security, so what one account may read is decided by the database itself rather than by the code that asks. Those rules are tested adversarially, as one account attempting to read another's records, rather than by reading the policy and believing it.
• The tables behind the former waitlist and the rate limiter carry no access policies at all, which means no browser can read them under any circumstances. Only our server-side code touches them.
• Passwords are handled by our sign-in provider and are never seen by our code.
• IP addresses used for rate limiting are hashed with a secret before they are stored, so the stored value cannot be turned back into an address.
• The sign-in record keeps only the first three parts of an address, reduced inside the database before anything reads it, and our own server code never receives the whole address of a sign-in. The one place a whole address is kept is the session record our sign-in provider needs while a session is open (see "When you sign in"), and signing out removes it.

No system is perfect, and we do not claim this one is.

Where your information goes

We are based in the United States and our service providers are principally in the United States. If you are in the United Kingdom or the European Economic Area, information you give us will be transferred to the United States, and our providers rely on standard contractual clauses for those transfers.

Children

Nothing here is meant for children. We do not knowingly collect information from anybody under 16, and if we learn that we have, we will delete it.

Changes

If we change this policy we will change the date at the top. If a change is significant and affects people on the former waitlist or already investing, we will email them rather than rely on you noticing.