Privacy Policy
Last Updated: August 2026
1. Introduction
Skylar Capital Management LP ("Skylar," "we," "us," or "our") is committed to protecting the privacy and security of your personal information. This Privacy Policy explains how we collect, use, disclose, retain, and safeguard your information when you visit our websites, including skylarcapitalmanagement.com, skylarcap.com, and skylaretfs.com (the "Websites"), access or use our platforms (including but not limited to virtual data rooms and file sharing accessed through Egnyte) or otherwise engage with our products and services (collectively, the "Services").
Skylar serves as investment manager of numerous energy-related funds, sub-advisor to an exchange traded fund (ETF) (Ticker: MWHS), and is affiliated with several entities developing solar, battery energy storage (BESS), powered land, data center and other energy-related projects.
By accessing or using our Services, you acknowledge that you have read and understood this Privacy Policy. If you are accessing our Services on behalf of an organization, you represent that you have the authority to bind that organization to this Privacy Policy.
If you do not agree with the practices described in this Privacy Policy, please do not access or use our Services.
2. Scope
This Privacy Policy applies to personal information collected through:
- Our Websites (skylarcapitalmanagement.com, skylarcap.com, and skylaretfs.com)
- Our platforms, including but not limited to virtual data rooms and file sharing accessed through Egnyte
- Communications with us, including email, phone, and in-person interactions
- Trade shows, conferences, and industry events
- Business development and sales interactions
Where Skylar has entered into a separate written agreement with an investor, customer or vendor that governs the handling of data, that agreement controls with respect to the data covered by it. This Privacy Policy applies to personal information that is not otherwise governed by such an agreement. To the extent of any conflict between this Privacy Policy and a separate written agreement, the customer agreement prevails.
3. Information We Collect
3.1. Information You Provide Directly
We collect personal information that you voluntarily provide to us, including when you request information about our Services, create an account, receive our communications, contact us, apply for employment, enter into a business relationship, submit feedback, or attend events where Skylar is present.
The types of personal information we may collect include:
- Name, title, and professional affiliation
- Business or personal email address and phone number
- Company or organization name
- Mailing address
- Account credentials (username and password)
- Payment and billing information (processed through secure third-party payment processors such as Bill.com)
- Professional background and qualifications
- Communications and correspondence with Skylar
- Feedback, suggestions, or recommendations you provide
- Content you submit or upload through our platforms
- Any other information you choose to provide
3.2. Information Collected Automatically
When you access our Websites or use our platforms, we may automatically collect certain information, including:
- Device and Access Information: IP address, browser type and version, operating system, device identifiers, device model, screen resolution, and language preferences.
- Usage Data: Pages visited, time spent on pages, links clicked, referral URLs, and navigation patterns.
- Platform Usage Data: Search queries, data accessed, reports generated, API calls, feature usage, session logs, AI agent interactions, and analytics workflows.
- Log Data: Server logs, error reports, access timestamps, and authentication events.
- Location Data: Approximate geographic location derived from IP address.
- Cookies and Tracking Technologies: Information collected through cookies, web beacons, pixels and similar technologies (see Section 10).
3.3. Information from Third Parties
We may receive personal information about you from third-party sources, including business partners, publicly available sources, government and regulatory databases, data enrichment providers, event organizers, and third-party authentication providers (such as Google and Apple sign-in services).
3.4. Aggregated and Technical Data
Skylar collects and generates aggregated, de-identified, and anonymized data ("Aggregated Data") derived from usage patterns, platform interactions, and technical telemetry. Aggregated Data does not identify any individual user. Skylar owns all right, title, and interest in Aggregated Data and may use it without restriction for any lawful purpose.
3.5. Customer Content
Investors, customers and vendors who access our platforms under a written agreement may submit data through the platform ("Customer Content"). The handling of Customer Content is governed by the applicable contractual agreement. Skylar does not retain Customer Content beyond the period necessary for transient processing.
4. How We Use Your Information
4.1. Service Delivery and Operations
- Providing, operating, maintaining, and improving our Services
- Processing account registrations and managing user accounts
- Authenticating users and managing access permissions
- Responding to inquiries, support requests, and information requests
- Sending notices or communications to investors, customers, vendors and other third parties
4.2. Security and Compliance
- Monitoring and logging platform access and usage for security purposes
- Maintaining audit trails as required by contractual agreements and regulatory obligations
- Detecting, preventing, and investigating unauthorized access, data breaches, fraud, and other prohibited activities
- Enforcing platform terms of use and acceptable use policies
- Complying with export control regulations, including ITAR and EAR
- Complying with applicable sanctions laws and regulations
- Conducting security assessments and vulnerability testing
- Verifying user eligibility for access to controlled or restricted data
4.3. Platform Improvement and Analytics
- Generating and analyzing Aggregated Data to evaluate platform performance and usage trends
- Training, improving, and developing machine learning models using Aggregated Data
- Conducting research and development for new products, features, and services
- Incorporating feedback and recommendations into our platforms
4.4. Communications and Marketing
- Sending newsletters, research updates, and market analysis (with your consent where required)
- Providing product announcements and service updates
- Communicating about changes to our policies, terms, or Services
- Sending push notifications if you have opted in
4.5. Business Operations
- Conducting analytics and research to improve our Services
- Managing business relationships and partnerships
- Administering contracts and fulfilling contractual obligations
- Facilitating corporate transactions
4.6. Legal Obligations
- Complying with applicable laws, regulations, legal processes, and governmental requests
- Establishing, exercising, or defending legal claims
- Responding to lawful requests from public authorities
5. Legal Bases for Processing
If you are located in the European Economic Area ("EEA"), the United Kingdom ("UK"), or another jurisdiction that requires a legal basis for processing personal data, we rely on the following:
- Contract Performance: Processing necessary to perform our contractual obligations to you.
- Legitimate Interests: Processing necessary for our legitimate interests, provided those interests are not overridden by your rights.
- Legal Obligation: Processing necessary to comply with legal obligations, including export control laws and sanctions regulations.
- Consent: Where we rely on your consent, you have the right to withdraw consent at any time.
6. How We Share Your Information
Skylar does not sell personal information for monetary consideration. Like most companies, we use third-party analytics and advertising cookies on our Websites, and applicable law (including the CCPA/CPRA) may treat the resulting transfer of information as a "sale" or "sharing" of personal information. California residents and residents of other states with similar laws may opt out at any time through the "Do Not Sell or Share My Personal Information" link, by enabling the Global Privacy Control (GPC) signal, or by contacting privacy@skylarcapital.com.
6.1. Service Providers
We engage trusted third-party vendors and service providers to assist in operating our Websites, platforms and delivering our Services. These providers are contractually obligated to use personal information only for the purposes for which it was disclosed.
6.2. Government and Regulatory Bodies
We may disclose personal information to government agencies, regulators, or law enforcement authorities when required by law, regulation, legal process, or governmental request.
6.3. Licensors and Data Partners
To the extent required by our data licensing agreements, we may share limited information with our data providers for usage verification, audit compliance, and license administration.
6.4. Professional Advisors
We may share personal information with our attorneys, auditors, accountants, insurers, and other professional advisors.
6.5. Business Transfers
In the event of a merger, acquisition, reorganization, restructuring, financing, sale of assets, or similar corporate transaction, your personal information may be transferred or disclosed as part of that transaction.
6.6. Aggregated and De-Identified Data
We may share Aggregated Data that cannot reasonably be used to identify you. We maintain de-identified data in de-identified form and publicly commit not to attempt to re-identify it except as permitted by law.
6.7. With Your Consent
We may share your personal information for any other purpose with your affirmative consent.
7. International Data Transfers
Skylar is headquartered in the United States. Your personal information may be transferred to, stored in, and processed in the United States or other countries where our service providers operate. If you are located in the EEA or UK, we will ensure transfers are protected by appropriate safeguards, including European Commission adequacy decisions, Standard Contractual Clauses (SCCs), or other lawful transfer mechanisms.
8. Data Retention
We retain personal information for as long as necessary to fulfill the purposes for which it was collected. Specific considerations include:
- Account Information: Retained for the duration of the account relationship and a reasonable period thereafter.
- Platform Usage and Access Logs: Retained as required for security monitoring, audit compliance, and export control verification.
- Marketing and Communications Data: Retained until you opt out or withdraw consent.
- Contractual and Transaction Records: Retained in accordance with applicable statute of limitations periods.
- Aggregated Data: Retained indefinitely as it does not identify any individual.
9. Your Rights and Choices
9.1. General Rights
Depending on your location and applicable law, you may have rights including:
- Access: The right to request access to the personal information we hold about you.
- Correction: The right to request correction of inaccurate or incomplete personal information.
- Deletion: The right to request deletion of your personal information, subject to certain exceptions.
- Opt-Out of Marketing: The right to opt out of receiving marketing communications at any time.
- Data Portability: Where applicable, the right to receive your personal information in a structured, machine-readable format.
9.2. Rights for California Residents
If you are a California resident, you have additional rights under the CCPA and CPRA, including:
- The right to know what personal information we collect, use, disclose, and sell or share
- The right to delete personal information we have collected from you
- The right to opt out of the sale or sharing of your personal information
- The right to correct inaccurate personal information
- The right to limit the use and disclosure of sensitive personal information
- The right to non-discrimination for exercising your privacy rights
In the preceding 12 months, we have collected the following categories of personal information as defined by the CCPA: identifiers; professional or employment-related information; commercial information; internet or electronic network activity information; geolocation data; and inferences drawn from the foregoing. We do not collect sensitive personal information except account credentials, and we do not use or disclose sensitive personal information for purposes other than those permitted under the CPRA.
9.3. Rights for Texas Residents
If you are a Texas resident, you have rights under the Texas Data Privacy and Security Act (TDPSA), including the right to opt out of the processing of your personal data for purposes of targeted advertising, the sale of personal data, or profiling. To submit an opt-out request, contact us at privacy@skylarcapital.com.
9.4. Rights for Residents of Other U.S. States
Residents of other U.S. states with comprehensive privacy legislation (including Virginia, Colorado, Connecticut, Oregon, Montana) may have similar rights. Skylar will honor valid requests from residents of any state with applicable privacy laws.
9.5. Rights for EEA and UK Residents
If you are located in the EEA or UK, you have additional rights under the GDPR or UK GDPR, including the right to restrict processing, the right to object to processing, the right to withdraw consent, the right to data portability, and the right to lodge a complaint with a supervisory authority.
9.6. Exercising Your Rights
To exercise any of the rights described above, please submit a request to privacy@skylarcapital.com. We will verify your identity before processing your request and will respond within the timeframes required by applicable law.
Authorized Agents: You may designate an authorized agent to submit a request on your behalf.
10. Cookies and Tracking Technologies
10.1. Types of Cookies and Technologies We Use
We use cookies and similar tracking technologies to enhance your experience, analyze usage, and support our business operations. This Cookies Policy applies to all Skylar-operated websites. The categories include:
- Strictly Necessary Cookies: Essential for the operation of our Websites, including authentication, session management, and security. These cookies cannot be disabled.
- Functional Cookies: Enable enhanced functionality and personalization, such as remembering your preferences.
- Analytics Cookies: Help us understand how visitors use our Websites (e.g., Google Analytics).
- Marketing Cookies: Used to deliver relevant content and measure the effectiveness of marketing campaigns.
10.2. Managing Your Preferences
Our Websites use a consent management platform that allows you to accept or decline non-essential cookies. For visitors in the EEA and UK, non-essential cookies are not set unless you affirmatively consent. For visitors in California and other US states with applicable privacy laws, you may opt out through the consent banner, the "Do Not Sell or Share My Personal Information" link, or the Global Privacy Control signal.
10.3. Global Privacy Control and Do Not Track
Our Websites recognize and honor Global Privacy Control (GPC) signals as a valid request to opt out of the sale or sharing of personal information. When we detect a GPC signal, we automatically disable cookies and tracking technologies that involve the sale or sharing of personal information. Our Websites do not respond to other "Do Not Track" signals for which no uniform legal standard currently exists.
10.4. Third-Party Analytics
We use third-party analytics services (such as Google Analytics) to help analyze how users interact with our Websites. For more information on how Google uses data, visit https://policies.google.com/privacy.
11. Data Security
Skylar implements administrative, technical, and physical security measures designed to protect your personal information, including:
- Encryption of personal data in transit (TLS/SSL) and at rest
- Access controls and multi-factor authentication
- Role-based access restrictions
- Regular security assessments, penetration testing, and vulnerability scanning
- Employee security training and awareness programs
- Incident response procedures
- Physical security controls at our facilities
While we implement commercially reasonable security measures, no method of transmission over the internet is completely secure.
11.1. Data Breach Notification
In the event of a data breach affecting your personal information, we will notify you and applicable regulatory authorities as required by law, including within 72 hours where required under the GDPR.
12. Third-Party Links and Services
Our Websites may contain links to third-party websites or services not operated by Skylar. This Privacy Policy does not apply to those services. We encourage you to review their privacy policies.
13. Children's Privacy
Our Services are not intended for use by individuals under the age of 18. We do not knowingly collect personal information from children under 13. If we become aware that we have, we will delete it promptly. Contact us at privacy@skylarcapital.com if you believe we have inadvertently collected such information.
14. Automated Decision-Making and AI Processing
Skylar may use automated processes and artificial intelligence technologies in connection with its Services, including automated verification under export control regulations, security monitoring, AI-powered analytics, and machine learning models trained on Aggregated Data. Where required by applicable law, you have the right to request human review of automated decisions. Contact us at privacy@skylarcapital.com.
15. California "Shine the Light" Law
Under California Civil Code Section 1798.83, California residents may request information about the categories of personal information shared with third parties for direct marketing purposes. Skylar does not share personal information with third parties for their direct marketing purposes. Requests may be sent to privacy@skylarcapital.com.
16. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. When we make material changes, we will post the updated Privacy Policy with a revised effective date and provide notice at least thirty (30) days before the changes take effect. Your continued use of our Services after the effective date constitutes acceptance of the changes.
17. Contact Us
If you have questions, comments, or concerns about this Privacy Policy or our data practices, please contact us at:
Skylar Capital Management LP
Attn: Privacy
5847 San Felipe St, Ste 4450
Houston, Texas 77057, USA
Privacy Inquiries: privacy@skylarcapital.com
General Inquiries: notices@skylarcapital.com
17.1. United Kingdom Contact
Inquiries regarding personal data from UK-based individuals may be directed to privacy@skylarcapital.com or to Skylar Energy Advisers LLP at 12 Hay Hill, W1J 8NR, London, United Kingdom.
17.2. Data Protection Officer
Skylar has determined, based on the nature and scope of its processing activities, that appointment of a Data Protection Officer under UK GDPR Article 37 is not required. If you have questions about how Skylar processes your personal data, please contact us at privacy@skylarcapital.com.