Policies & Notices
Legal
Privacy, website-use terms, disclosures, and other notices applicable to this website.
Effective and last updated: September 27, 2026
Section 1
Privacy Policy
Randy Whitehead & Company, L.L.C. ("RWLLC," "we," "us," or "our") respects the privacy of visitors to this website. This Privacy Policy explains the types of personal information we may collect, how we may use and disclose it, and the choices available to you. It applies to this website and related online features that link to this policy. It does not govern third-party websites or services.
Information We May Collect
Information you provide. We may collect your name, organization, title, postal address, telephone number, email address, the contents of an inquiry or other communication, blog-subscription preferences, and other information you elect to provide through contact forms, subscription forms, account features, or correspondence.
Restricted-area accounts. If you request or receive access to a restricted area, we may retain your request details, approval status, account and login records, security events, and records concerning the materials made available to your account. Passwords are processed and stored in a non-readable cryptographic form; RWLLC does not retain your password in plain text.
Prospective-investor information. If you complete an accredited investor questionnaire or request information about potential investment opportunities, we may collect your applicant type, entity information, city and jurisdiction, claimed accredited-investor qualification categories, professional-license details you elect to provide, investment experience, areas of interest, indicative commitment range, geographic preferences, acknowledgments, electronic signature, communication choices, and the status and notes associated with our review. The preliminary questionnaire does not request Social Security numbers, tax returns, bank or brokerage statements, credit reports, or complete financial-account numbers. If project-specific verification is later required, additional information may be requested through a separate process with additional instructions.
Transaction information. If online payments are offered, we and our service providers may collect billing, payment, and transaction information needed to process and document the transaction. Payment-card information generally is submitted directly to a third-party payment processor; RWLLC does not intend to retain full payment-card numbers or security codes.
Information collected automatically. When you use the website, servers and analytics technologies may collect an Internet Protocol address, device and browser type, operating system, approximate location derived from an IP address, referring and exit pages, pages viewed, links selected, dates and times of visits, and similar usage or diagnostic information.
Cookies and related technologies. We may use cookies, pixels, tags, local storage, or similar technologies for essential website functions, preferences, analytics, security, and—if enabled—advertising or marketing measurement. Additional information appears in the Cookie Notice below.
How We May Use Information
We may use personal information to operate, secure, maintain, and improve the website; respond to inquiries; provide requested information or services; administer blog subscriptions; evaluate prospective-investor questionnaires; maintain qualification, review, and relationship records; match stated interests with potential future projects; conduct project-specific eligibility or verification procedures; process and document payments; communicate about our business and, when separately authorized, future opportunities; measure website performance and readership; prevent fraud or misuse; comply with securities, tax, accounting, legal, and recordkeeping obligations; enforce our agreements; protect RWLLC, our users, and others; and carry out other purposes disclosed when information is collected or with your consent.
How We May Disclose Information
We may disclose information to vendors and professional advisers that support hosting, website administration, analytics, communications, subscriptions, payment processing, security, records management, investor verification, legal and regulatory compliance, and other business operations. Prospective-investor information may also be disclosed to an applicable project sponsor, issuer, fund, affiliated project entity, placement agent, administrator, or their professional advisers when reasonably necessary to evaluate eligibility, provide requested project information, or administer a potential transaction. We may also disclose information when reasonably necessary to comply with law or legal process; respond to governmental requests; investigate fraud, security incidents, or violations; protect rights, property, or safety; or evaluate or complete a merger, financing, reorganization, sale, or other business transaction. We do not sell personal information for money. If advertising or marketing technologies are enabled, certain disclosures involving online identifiers may be treated as a "sale," "sharing," or targeted advertising under some state privacy laws, and applicable opt-out rights will be honored as required by law.
Analytics
We may use Google Analytics or similar analytics services to understand how visitors use the website. Those providers may collect information through cookies and related technologies and process it under their own privacy terms. Browser settings, privacy extensions, and provider opt-out tools may allow you to limit certain analytics collection.
Your Choices and Privacy Rights
You may decline to provide optional information, unsubscribe from blog or marketing communications by using the instructions in the applicable message, and adjust your browser to block or delete cookies. Blocking cookies may affect website operation. Depending on your residence and applicable law, you may have rights to request access to, correction of, deletion of, or a copy of certain personal information; to appeal a denied request; or to opt out of certain targeted advertising, sales, sharing, or profiling. We may need to verify your identity and may retain information where permitted or required by law. Requests may be submitted through an applicable website contact or privacy-choice form when available, or by mail at the address below.
Retention and Security
We retain personal information for as long as reasonably necessary for the purposes described in this policy, including investor-relationship, securities-law, legal, accounting, security, and recordkeeping requirements. Prospective-investor records may be retained after a review decision or after an opportunity concludes where reasonably necessary for those purposes. We use reasonable administrative, technical, and physical safeguards appropriate to the nature of the information. No Internet transmission or storage system, however, can be guaranteed to be completely secure.
Children, External Links, and International Use
This website is intended for a general business audience and is not directed to children under 13. We do not knowingly collect personal information from children under 13. Links to third-party websites are provided for convenience; their privacy practices are governed by their own policies. The website is operated in the United States, and information may be processed and stored in the United States or other places where our service providers operate.
Changes to This Policy
We may revise this Privacy Policy as the website, our practices, or applicable law changes. The date above identifies the most recent revision. Material changes may also be communicated by an additional notice where appropriate.
Section 2
Terms & Conditions of Use
These Terms & Conditions of Use ("Terms") govern your access to and use of this website. By accessing or using the website, you agree to these Terms. If you do not agree, do not use the website.
Permitted Use
You may use the website for lawful, personal, and legitimate business-information purposes. You may not interfere with website operation or security; attempt unauthorized access; introduce malicious code; use automated means to scrape, harvest, or burden the website; impersonate another person; submit unlawful or misleading material; remove proprietary notices; or use website content in a manner that infringes another person's rights or violates applicable law.
Informational Use; No Professional Relationship
Website content is provided for general informational purposes only. It is not legal, investment, tax, accounting, engineering, technical, brokerage, or other professional advice and should not be relied upon as a substitute for advice based on your particular facts. Accessing the website, submitting an inquiry, or communicating through the website does not create an attorney-client, adviser-client, fiduciary, partnership, joint-venture, agency, or other professional relationship with RWLLC or any of its principals, affiliates, or representatives. Do not send confidential or time-sensitive information unless an authorized representative has agreed in writing to receive it on that basis.
RWLLC undertakes consulting, professional, development, and advisory engagements selectively and does not offer those capabilities to the general retail public through this website. Descriptions of past experience, capabilities, or representative activities are informational only and do not constitute an offer to undertake an engagement. RWLLC determines in its discretion whether to consider or accept any proposed relationship or transaction.
No Offer or Solicitation
Nothing on this website constitutes an offer to sell, a solicitation of an offer to purchase, or a recommendation concerning any security, investment product, real property interest, fund, transaction, or advisory service. Any offering or transaction may be made only through definitive written documents delivered to eligible recipients and is subject to the terms, qualifications, risk factors, and disclosures contained in those documents.
Accuracy and Availability
We may update, correct, remove, or change website content or functionality at any time. Although we seek to provide useful information, we do not warrant that content is complete, current, accurate, or suitable for a particular purpose, or that the website will be uninterrupted, secure, or free of harmful components.
Third-Party Services and Payments
The website may link to or interoperate with third-party websites, portals, analytics providers, payment processors, and other services. RWLLC does not control and is not responsible for third-party content, terms, privacy practices, availability, or performance. If online payments are offered, additional transaction terms presented at checkout or in a separate agreement also apply. In the event of a conflict, the specific written transaction agreement controls that transaction.
Disclaimers
TO THE FULLEST EXTENT PERMITTED BY LAW, THE WEBSITE AND ITS CONTENT ARE PROVIDED "AS IS" AND "AS AVAILABLE," WITHOUT WARRANTIES OF ANY KIND, EXPRESS OR IMPLIED, INCLUDING WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, TITLE, NON-INFRINGEMENT, ACCURACY, OR SECURITY.
Limitation of Liability
TO THE FULLEST EXTENT PERMITTED BY LAW, RWLLC AND ITS MEMBERS, MANAGERS, AFFILIATES, REPRESENTATIVES, SERVICE PROVIDERS, AND LICENSORS WILL NOT BE LIABLE FOR INDIRECT, INCIDENTAL, SPECIAL, EXEMPLARY, PUNITIVE, OR CONSEQUENTIAL DAMAGES, LOST PROFITS, LOST DATA, BUSINESS INTERRUPTION, OR LOSS ARISING FROM OR RELATED TO THE WEBSITE, ITS CONTENT, OR ANY LINKED SERVICE, EVEN IF ADVISED OF THE POSSIBILITY OF SUCH DAMAGES. ANY LIABILITY THAT CANNOT LAWFULLY BE EXCLUDED OR LIMITED WILL BE LIMITED TO THE MAXIMUM EXTENT PERMITTED BY LAW.
Indemnification
To the fullest extent permitted by law, you agree to defend, indemnify, and hold harmless RWLLC and its members, managers, affiliates, representatives, service providers, and licensors from claims, liabilities, damages, judgments, losses, costs, and expenses, including reasonable attorneys' fees, arising from your unlawful use of the website, your violation of these Terms, or your infringement of another person's rights.
Governing Law and Venue
These Terms and any dispute arising from or relating to the website are governed by the laws of the State of Wyoming, without regard to conflict-of-laws principles. Subject to any nonwaivable law, exclusive jurisdiction and venue lie in the state or federal courts located in Laramie County, Wyoming, and each party consents to personal jurisdiction there.
General Terms
We may suspend access to the website and revise these Terms at any time. Continued use after revised Terms are posted constitutes acceptance of the revised Terms. If a provision is found unenforceable, it will be enforced to the maximum extent permitted and the remaining provisions will remain effective. Failure to enforce a provision is not a waiver. These Terms and any additional terms expressly applicable to a particular feature constitute the entire agreement concerning website use.
Section 4
Legal & Investment Disclosures
RWLLC engages in private equity real estate investment and development activities involving telecommunications, high-technology infrastructure, data centers, infrastructure real estate, and commercial triple-net real estate. Website descriptions are general and may be abbreviated, illustrative, historical, or forward-looking. They are not a representation that any opportunity is available or suitable for any person.
Completion, submission, or approval of an accredited investor questionnaire is preliminary only. It does not verify accredited investor status for every purpose, create a substantive investor relationship, reserve an allocation, establish suitability, grant access to confidential materials, or constitute acceptance for any offering. An issuer or project sponsor may require updated representations, documentary or third-party verification, confidentiality commitments, and additional project-specific review before providing offering materials or accepting an investment.
Investments involve risk, including possible loss of principal, illiquidity, market and tenant risk, regulatory change, construction and development risk, financing risk, technological change, and other risks. Past performance, project experience, or historical results do not guarantee future results. No statement on this website should be interpreted as a promise, projection, warranty, or guarantee of performance, value, income, tax treatment, legal outcome, governmental approval, or investment return.
Legal and regulatory observations are general information only and may become outdated as laws, regulations, agency practices, and facts change. Readers should consult their own qualified legal, financial, tax, engineering, and other advisers before acting.
Section 5
Intellectual Property
Unless otherwise identified, the website's text, graphics, photographs, designs, logos, arrangement, and other content are owned by or licensed to RWLLC and are protected by copyright, trademark, and other laws. You may view, print, or download a reasonable number of pages for your own lawful, noncommercial informational use, provided all proprietary notices remain intact. No other reproduction, publication, distribution, modification, creation of derivative works, public display, commercial exploitation, framing, or use of RWLLC names, marks, or branding is permitted without prior written authorization.
Names, logos, and marks belonging to third parties remain the property of their respective owners. Their appearance is for identification or informational purposes and does not imply endorsement, sponsorship, or affiliation unless expressly stated.
Section 6
Accessibility
RWLLC seeks to make its website usable by a broad audience, including people with disabilities, and will consider reasonable measures to improve access as the website develops. If you encounter an accessibility barrier, please identify the page, feature, and nature of the difficulty through an available website contact form or by writing to the address below. We will review the concern and, where reasonably feasible, provide the requested information through an alternative method.
Section 7
Equal Opportunity & Fair Housing
RWLLC supports equal opportunity and, where applicable, the principles of fair housing. RWLLC does not intend to discriminate in the availability of its services or business activities on a basis prohibited by applicable law.
Section 8
Legal Notices & Contact
Questions, privacy requests, accessibility concerns, and notices relating to this website may be submitted through an applicable website contact form or sent by mail to:
Randy Whitehead & Company, L.L.C.Attn. General Counsel
109 East Seventeenth, Suite 4602
Cheyenne, Wyoming 82001
Sending a communication does not create a professional or fiduciary relationship and does not obligate RWLLC to accept representation, an engagement, or a transaction.