Privacy Policy

1. Data Controller and Processor Roles

1.1 Controller. Llewellyn Systems acts as the Data Controller for personal information collected directly from visitors to our websites, marketing contacts, and prospective customers.

1.2 Processor. When processing Customer Data on behalf of our investment firm customers, Llewellyn Systems acts as a Data Processor. Our customers remain the Data Controller for their LP data, deal data, and portfolio company information.

1.3 Contact. Data Protection Officer: [email protected]

2. Information We Collect

2.1 Information You Provide. Account registration data (name, email, organization); billing and payment information; fund configuration settings; investment thesis parameters.

2.2 Investment Operations Data. When you use our AI agents, we process deal pipeline data, portfolio company metrics, LP communication records, and fund accounting data. This data is processed within your security perimeter.

2.3 Automatically Collected Information. Device identifiers, IP addresses, browser type; usage data, feature interactions, and performance metrics; cookies and similar tracking technologies.

3. AI and Machine Learning Disclosure

3.1 AI Agent Operations. ODE Boutique Equity employs 6 specialized AI agents (DEALFLOW, DILIGENCE, PORTFOLIO, INVESTOR, CAPITAL, SENTINEL-PE) that process data to provide investment operations automation services.

3.2 No Investment Advice. Our AI agents provide operational automation and analytics. They do not provide investment advice, recommendations, or solicitations.

3.3 Model Training. We do not use your deal data, portfolio information, or LP records to train our machine learning models.

4. Security Measures

• Encryption in transit (TLS 1.3) and at rest (AES-256)
• SOC 2 Type II certified infrastructure
• Role-based access control and principle of least privilege
• Regular security audits and penetration testing
• Data residency controls for sensitive fund information

5. Contact

Llewellyn Systems Inc
2601 Blanding Ave, Ste C248, Alameda, CA 94501
Privacy: [email protected]
DPO: [email protected]