1. Purpose and Scope
Altss LLC (“Altss,” “we,” “us,” or “our”) operates the website and platform located at altss.com (together with all associated tools, databases, APIs, browser extensions, and services, the “Platform” or the “Service”). Altss provides an OSINT-powered limited-partner (“LP”) intelligence platform and research technology for participants in the private capital markets, including general partners (“GPs”), fund managers, family offices, institutional allocators, and their advisors.
This Broker-Dealer Registration Disclosure (this “Disclosure”) sets forth, in comprehensive detail, Altss’s regulatory status; the strictly technology-and-data nature of our Service; the boundaries of what we do and do not do; and the independent compliance obligations of our users. This Disclosure should be read together with our Terms of Service, Privacy Policy, and Acceptable Use Policy.
2. Regulatory Status
2.1 No Registration
Altss is not registered as, and does not act in the capacity of, any of the following:
- A “broker” or “dealer” as defined under Sections 3(a)(4) and 3(a)(5) of the Securities Exchange Act of 1934, as amended (the “Exchange Act”).
- An “investment adviser” as defined under Section 202(a)(11) of the Investment Advisers Act of 1940, as amended (the “Advisers Act”), or under any analogous state statute.
- A placement agent, finder, solicitor, capital introducer, or intermediary in any securities transaction, under federal or state securities laws.
- A “funding portal” as defined in Section 3(a)(80) of the Exchange Act.
- A municipal securities dealer, municipal advisor, transfer agent, clearing agency, alternative trading system, or securities information processor under the Exchange Act.
- A commodity pool operator, commodity trading advisor, introducing broker, or futures commission merchant under the Commodity Exchange Act.
- Any other entity required to register under U.S. federal or state securities laws, U.S. commodities laws, or the laws of any foreign jurisdiction in connection with the offer, sale, solicitation, negotiation, or purchase of securities or other financial instruments.
Altss is not registered with the U.S. Securities and Exchange Commission (“SEC”), the Financial Industry Regulatory Authority (“FINRA”), the National Futures Association (“NFA”), the Commodity Futures Trading Commission (“CFTC”), any state securities or insurance commission, or any non-U.S. regulatory authority in any of the foregoing capacities. No Altss officer, employee, contractor, or agent holds, in the course of their work for Altss, a Series 7, Series 63, Series 65, Series 66, Series 79, Series 82, or any other securities registration or license.
2.2 Verification
You may independently verify Altss’s non-registered status via:
- FINRA BrokerCheck: brokercheck.finra.org
- SEC EDGAR: sec.gov/edgar
- SEC Investment Adviser Public Disclosure (IAPD): adviserinfo.sec.gov
- NASAA: nasaa.org (for state regulator directories)
3. Nature of the Service — Technology, Data, and Research Only
Altss is a software and data-intelligence company. The Service is a research and workflow platform for participants in the private capital markets. Altss does not participate in any securities transaction, does not advise on any investment, and does not execute or facilitate any capital-raising activity on behalf of any party.
3.1 Research Database
Altss maintains a research database covering institutional allocators, family offices, endowments, foundations, pension plans, sovereign wealth funds, insurance companies, fund-of-funds, outsourced CIOs, wealth managers, consultants, general partners, and other private capital market participants. All records are derived from (a) publicly available information, (b) properly licensed third-party data, or (c) voluntary user submissions.
Altss does not use, solicit, or knowingly accept material non-public information (“MNPI”), confidential investor lists, misappropriated trade secrets, or data obtained in violation of any contract, confidentiality obligation, terms of service, computer-access law, or fiduciary duty.
3.2 Research Methodology
Altss applies open-source intelligence (“OSINT”) methodologies. All outputs are research signals, not representations of fact, and not advice or recommendations.
3.3 AI-Powered Research and Workflow Tools
The Platform provides software tools that generate research, drafting, and workflow outputs to support the user’s own independent activities. All AI-generated outputs are informational research aids only. They do not constitute investment recommendations, solicitations, endorsements, legal advice, tax advice, or compliance advice. All outreach communications must be reviewed, customized, approved, and transmitted by the user or the user’s authorized agent. The user is the sender, author, and controller of every message.
3.4 LP-GP Connect
LP-GP Connect is a research and discovery feature that surfaces potential thematic alignment between market participants based on publicly available or user-submitted profile attributes. It is strictly a data-matching and discovery surface. It is not a dealing, solicitation, or introduction service. Altss does not:
- Contact, solicit, or communicate with any party on behalf of any user;
- Negotiate, arrange, or facilitate any meeting, diligence session, or commitment;
- Act as a matchmaker, conduit, broker, finder, or intermediary in any capital-raising process; or
- Assume any role in, or receive any compensation contingent upon, any resulting relationship, subscription, or capital commitment.
Any outreach, meeting, diligence, negotiation, or commitment that follows is initiated, conducted, and controlled exclusively by the user.
3.5 User-Submitted Profiles
The Platform allows users to voluntarily submit profile information. Submissions are treated as user-generated content. Altss does not verify, endorse, rate, rank, or vouch for any self-submitted data. Presence of a user profile in the Platform does not constitute a recommendation, a solicitation, an endorsement, or a representation that the user is accredited, qualified, suitable, available, or interested in any particular opportunity. Users submitting information represent that they have the authority to do so and that the information is accurate at the time of submission.
3.6 Events Intelligence
The Platform aggregates publicly available information about industry conferences, summits, and gatherings relevant to the private capital markets (collectively, “Events”). Event data is presented as informational research output only. Events are organized and operated by independent third parties. Inclusion of any Event does not constitute an endorsement or imply any affiliation between Altss and the organizer, sponsors, speakers, or attendees.
In connection with Events, Altss does not:
- Organize, host, produce, sponsor, or co-sponsor any Event;
- Sell, resell, broker, or process payment for tickets, passes, sponsorships, or meeting slots;
- Arrange, schedule, facilitate, or broker meetings, cap-intro sessions, or private gatherings between any parties at or around any Event;
- Act as an agent or representative for any Event organizer, sponsor, speaker, or attendee;
- Solicit attendance, sponsorship, investment, or any securities transaction in connection with any Event;
- Distribute or serve as a conduit for offering materials in connection with any Event;
- Represent that any listed attendee, speaker, or sponsor is accredited, qualified, available, or interested in any opportunity;
- Verify or guarantee the accuracy, legality, safety, quality, or outcome of any Event; or
- Receive compensation from any party contingent upon user registrations, attendance, meetings, or any resulting relationship or transaction.
Information identifying participants in any Event is derived from public disclosures or voluntary user submissions. Altss does not confirm actual attendance. Presence of a name in connection with an Event is not an endorsement, a solicitation, a representation of accreditation, or an invitation to contact. Users are solely responsible for the securities-law implications of their own conduct at, in connection with, or arising from any Event, including any analysis under Rule 502(c), Rule 506(b), Rule 506(c), and any applicable registration requirements. Users are responsible for independently verifying all Event details directly with the organizer before making any decision.
3.7 No Bulk Export, No API Access, No Redistribution
Altss does not provide API access, bulk data exports, data feeds, or similar interfaces. Users may not extract, download, scrape, copy, redistribute, resell, sublicense, or otherwise remove data from the Platform in bulk. Data in the Platform is licensed solely for the user’s internal research use within the Platform’s user interface. Violation of this restriction is grounds for immediate termination and may result in liability under applicable contract, copyright, database, and computer-access laws.
4. What Altss Explicitly Does NOT Do
For the avoidance of doubt, Altss does not, and will not:
4.1 Securities and Transaction Activity
- Solicit, negotiate, structure, or effect the purchase, sale, exchange, or transfer of any security, fund interest, token, or other financial instrument.
- Recommend that any LP, allocator, or other person commit capital to, purchase interests in, or participate in any fund, offering, vehicle, or investment opportunity.
- Advise on, negotiate, or arrange the terms of any securities offering, subscription agreement, limited partnership agreement, side letter, co-investment agreement, or similar instrument.
- Distribute, deliver, or serve as a conduit for private placement memoranda, subscription documents, pitch decks, or other offering materials on behalf of any user.
- Participate in any closing, allocation decision, capital call, or distribution.
- Express an opinion as to the suitability, merits, risk, expected performance, or investment quality of any fund, strategy, manager, or opportunity.
- Provide “capital introduction,” “placement,” “finder,” or “solicitor” services.
4.2 Custody, Funds Handling, and Settlement
- Handle, hold, custody, transmit, move, or exercise any control or discretion over investor funds, capital commitments, securities, digital assets, or other client property.
- Act as escrow agent, paying agent, transfer agent, custodian, or settlement intermediary.
- Process, facilitate, or route the movement of investor capital or securities in any manner.
4.3 Advisory, Fiduciary, and Professional Services
- Provide investment advice, portfolio construction, asset allocation, or manager-selection recommendations.
- Act in any fiduciary, agency, trustee, or similar capacity for any user, investor, or third party.
- Perform due diligence on any fund, manager, or investor on behalf of another party.
- Provide legal, tax, accounting, regulatory, or compliance advice. Users must retain qualified independent counsel and other advisors.
4.4 Representations About Users
- Rate, rank, endorse, certify, or vouch for any user, fund, LP, GP, family office, or institution listed in, or using, the Platform.
- Represent that any person listed in the database is accredited, qualified, suitable, available, solicitable, or interested.
5. Compensation Structure — Technology-Only Defense
5.1 Subscription Fees
Altss’s business model is a fixed, subscription-based software and data license. Fees are charged for access to the Platform’s tools, database, and features. Subscription fees are payable regardless of whether any meeting occurs, any relationship is formed, any fund is raised, or any capital commitment is made by or to any user.
5.2 No Transaction-Based Compensation
Altss does not receive, and will not accept:
- Commissions, success fees, placement fees, finder’s fees, referral fees, or capital-raise fees;
- Any compensation that is contingent upon, calculated by reference to, or otherwise tied to the consummation, size, terms, or outcome of any securities transaction, capital commitment, subscription, or fundraising result;
- Any payment, rebate, or economic benefit from any party based on introductions, meetings, allocations, or the identity of any investor.
Our subscription structure is consideration solely for access to technology and research tools. This compensation design is a core structural component of our non-broker status.
5.3 No Revenue Share with Users
Altss does not enter into revenue-sharing, profit-sharing, or carry-sharing arrangements with GPs, LPs, or other users tied to any fund or transaction.
6. No Offer or Solicitation
Nothing contained on the Platform, in our database records, in AI-generated outputs, in LP-GP Connect suggestions, in self-reported profiles, in events listings, in marketing materials, or in any communication from Altss constitutes:
- An offer to sell, or a solicitation of an offer to buy, any security, fund interest, token, or investment product;
- An endorsement, recommendation, or certification of any GP, LP, fund, strategy, manager, or opportunity;
- The distribution of offering materials on behalf of any user; or
- Investment, legal, tax, accounting, or compliance advice.
Any fund-, strategy-, or manager-related information displayed on the Platform that originated with a user is user-generated content for which the submitting user is solely responsible. Altss does not independently verify, endorse, or guarantee the accuracy or completeness of such information.
7. Data Sourcing, Accuracy, and Non-Endorsement
7.1 Lawful Sourcing
All data in our database is sourced from (a) publicly available information, (b) properly licensed third-party data providers, or (c) users via voluntary self-submission. Altss does not use MNPI, misappropriated trade secrets, data obtained through unauthorized access, or data obtained through breach of contract, NDA, or fiduciary duty.
7.2 Data Accuracy
The Platform and all data, outputs, and analytics are provided “as is” and “as available,” without warranties of any kind, whether express, implied, statutory, or otherwise, including warranties of merchantability, fitness for a particular purpose, accuracy, completeness, currency, non-infringement, or results. Users are responsible for independently verifying any data before relying on it for business, regulatory, or investment decisions.
7.3 No Endorsement by Inclusion
The inclusion of any allocator, family office, GP, LP, fund, manager, or other party in the Platform does not constitute an endorsement, a recommendation, or an indication that the party is available, accredited, qualified, or interested in any particular opportunity.
8. User Responsibilities and Independent Compliance Obligations
Users are solely responsible for their own compliance with all applicable laws and regulations. By using the Service, you acknowledge and agree to the following.
8.1 Securities Law Compliance
- You are solely responsible for compliance with the Securities Act of 1933, the Exchange Act, the Advisers Act, the Investment Company Act of 1940, and all rules thereunder.
- If conducting a private placement, you are solely responsible for compliance with Regulation D (including the restrictions on general solicitation under Rule 506(b) and the accredited-investor verification requirements under Rule 506(c)), Form D filings, and applicable state blue-sky notice filings.
- You are solely responsible for determining whether any communication you send using the Platform constitutes “general solicitation” or “general advertising” under Rule 502(c).
- You are solely responsible for compliance with the Advisers Act marketing rule (Rule 206(4)-1), including with respect to performance, testimonials, endorsements, and third-party ratings.
- You are solely responsible for determining whether you or your fund must register as an investment adviser, investment company, commodity pool operator, or broker-dealer, or whether an exemption is available.
8.2 Anti-Fraud
You shall not use the Service to:
- Make any untrue statement of material fact, or omit any material fact necessary to make statements not misleading, in violation of Section 10(b) of the Exchange Act, Rule 10b-5 thereunder, or Section 17(a) of the Securities Act;
- Engage in any fraudulent, deceptive, or manipulative act or practice; or
- Misrepresent your identity, authority, fund, strategy, track record, team, terms, or performance.
8.3 Communications, Privacy, and Data Protection
You are solely responsible for compliance with all laws governing commercial communications and personal data, including:
- The CAN-SPAM Act (15 U.S.C. § 7701 et seq.) and the Telephone Consumer Protection Act (“TCPA”);
- Canada’s Anti-Spam Legislation (“CASL”);
- The EU General Data Protection Regulation (“GDPR”), the UK GDPR, and the California Consumer Privacy Act / California Privacy Rights Act (“CCPA/CPRA”);
- All other applicable anti-spam, marketing, cold-outreach, data-protection, and electronic-communications laws of the jurisdictions of your senders and recipients.
You are responsible for providing accurate sender identification, a valid physical postal address, a functioning opt-out mechanism, and appropriate lawful bases for processing personal data. Altss provides technology only; you are the data controller for your outreach and the sender of all communications.
8.4 AML, KYC, OFAC, and Sanctions
You are solely responsible for compliance with the Bank Secrecy Act, the USA PATRIOT Act, applicable anti-money-laundering (“AML”) and know-your-customer (“KYC”) requirements, and all sanctions regimes administered by the U.S. Office of Foreign Assets Control (“OFAC”) and any other relevant authority, including screening against the Specially Designated Nationals and Blocked Persons List.
8.5 Content, Authority, and Approval
You represent and warrant that:
- You have all necessary rights and authority to use the Platform, transmit any communications, and submit any content;
- All information you provide (including self-reported profile data, fund information, and communication content) is accurate, complete, and not misleading;
- You, and not Altss, are the sender and author of every communication transmitted using the Platform; and
- You have reviewed, customized, and approved each communication before it is sent.
8.6 Acceptable Use
You shall not use the Platform to conduct unsolicited bulk communications in violation of applicable law, to harass, to infringe intellectual property, to circumvent the security or terms of use of any third-party system, or to engage in any activity prohibited by our Acceptable Use Policy.
9. No Fiduciary, Advisory, or Agency Relationship
Your use of the Service does not create, and shall not be deemed to create, any advisory, fiduciary, agency, partnership, joint venture, employment, or similar relationship between you and Altss. Altss is a technology service provider. The relationship between Altss and each user is solely that of a service provider and customer as set forth in our Terms of Service. Altss owes no fiduciary or trust duties to any user, any user’s investors, any LP, any GP, or any third party, and has no duty to act in the best interests of any investor or prospective investor.
10. No Reliance — Not Legal, Tax, or Investment Advice
Nothing provided by Altss — through the Platform, our website, documentation, AI outputs, data, analytics, communications, or otherwise — constitutes legal, tax, investment, accounting, or regulatory-compliance advice. All outputs are for informational and research purposes only.
You acknowledge and agree that:
- You will not rely on Altss, its personnel, or its contractors for legal, regulatory, tax, compliance, or investment advice;
- Altss makes no representations or warranties regarding the legal or regulatory implications of your use of the Service;
- Altss is not responsible for evaluating the compliance of your fundraising or investment activities; and
- All decisions regarding your capital-raising strategy, targeting, outreach, offering terms, investor selection, and regulatory posture are made at your sole discretion and risk.
Altss strongly recommends that every fund manager, GP, and institutional user engage qualified, independent legal counsel experienced in securities law, fund formation, and regulatory compliance before using the Service for any capital-raising or investor-outreach purpose. Areas warranting counsel include, without limitation, Regulation D compliance, general solicitation analysis, state blue-sky filings, broker-dealer and investment-adviser registration requirements and exemptions, the Advisers Act marketing rule, AML/KYC/OFAC programs, privacy law compliance, and the regulatory implications of using third-party technology platforms in a capital raise.
11. Regulatory Change Notice
The legal and regulatory framework governing capital raising, securities offerings, broker-dealer activity, investment-adviser activity, outreach, and data use is subject to change. New statutes, rules, no-action letters, interpretive releases, guidance, or enforcement actions by the SEC, FINRA, state regulators, CFTC, NFA, or foreign authorities may affect the characterization of Altss’s services or your use of them. Altss monitors regulatory developments but does not provide legal advice regarding their impact on you. Altss may modify the Service, pricing, features, or this Disclosure in response to regulatory developments and will post material updates to this page.
12. Reporting and Complaints
If you believe that Altss, or any user of the Platform, has engaged in activity that may violate federal or state securities laws, you may report such activity to:
- SEC — Tips, Complaints, and Referrals: sec.gov/tcr
- SEC Office of Investor Education and Advocacy
- FINRA Securities Helpline for Seniors: (844) 574-3577
- Your state securities regulator (directory at nasaa.org)
You may also contact Altss directly at the address in Section 14.
13. Limitation of Liability for Regulatory Matters
To the maximum extent permitted by law, Altss shall not be liable for any losses, damages, penalties, fines, sanctions, or other consequences arising out of or relating to:
- Your failure to comply with any applicable securities, commodities, privacy, data-protection, anti-spam, AML, KYC, OFAC, or other law or regulation;
- Any regulatory action or investigation commenced against you, your fund, or your affiliates by any governmental or self-regulatory authority;
- Any claim by an investor, prospective investor, or counterparty arising from your capital-raising or investment-related activities, including claims related to fraud, misrepresentation, unregistered offerings, or unregistered broker-dealer or investment-adviser activity;
- Any characterization by a regulatory authority of your use of the Service as regulated activity; or
- Any change in applicable law or regulatory interpretation.
This Section 13 is in addition to, and does not limit, any limitations of liability in our Terms of Service.
14. Contact
Questions regarding this Disclosure may be directed to:
Altss LLC 390 NE 191st St, STE 8906 Miami, FL 33179 Email: info@altss.com
This Disclosure may be updated from time to time. The “Last Updated” date at the top of this page reflects the current version. Material changes will be communicated through the Platform or by email to account administrators.