Privacy Policy

Circle Stone Capital ("Circle Stone Capital," "we," "us," or "our") respects your privacy and is committed to protecting your personal information. This Privacy Policy describes how we collect, use, disclose, and safeguard your information when you visit our website at https://circlestonecapital.com (the "Website"), use our investor portal (https://invest.circlestonecapital.com), use our mobile application (the "App"), subscribe to our communications, or otherwise interact with us (collectively, the "Services").

By using the Services, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with our practices, please do not use the Services.

1. Information We Collect

Information You Provide Directly

• Contact information: name, email address, mailing address, and phone number when you contact us, subscribe to our newsletter, or request information about investment opportunities.
• Account information: username, password, and profile details when you create an account on the Website, App, or investor portal.
• Investor information: if you invest with us or express interest in investing, we may collect information necessary to evaluate eligibility and process your investment, including accredited investor status and supporting documentation, date of birth, Social Security number or tax identification number, government-issued identification, banking and payment information, and information about your financial position and investment experience.
• Communications: the contents of messages you send us by email, contact form, or other channels.

Information Collected Automatically

When you use the Website or App, we and our service providers automatically collect:

• Device and usage data: IP address, browser type, operating system, device identifiers, pages viewed, links clicked, referring/exit pages, and date/time stamps.
• Cookies and similar technologies: we use cookies to operate the Website, analyze traffic, and improve your experience. You can control cookies through your browser settings; disabling cookies may limit some functionality. See Section 7 (Cookies) below.

Information from Third Parties

We may receive information about you from third parties, such as identity verification and accreditation verification services, referral partners, and publicly available sources, in connection with evaluating or processing an investment.

2. How We Use Your Information

We use your information to:

• Provide, operate, and improve the Services;
• Evaluate investor eligibility, including verification of accredited investor status;
• Process investments, distributions, and related transactions;
• Communicate with you, including responding to inquiries and sending investor communications, statements, and tax documents;
• Send newsletters, updates, and information about investment opportunities (you may opt out at any time);
• Comply with legal and regulatory obligations, including securities laws, anti-money-laundering (AML) requirements, and know-your-customer (KYC) requirements;
• Detect, prevent, and address fraud, security incidents, and technical issues; and
• Enforce our agreements and protect our legal rights.

3. How We Share Your Information

We do not sell your personal information. We may share your information with:

• Service providers who perform services on our behalf, such as our website hosting provider (Vercel), email and communications providers, payment processors, identity and accreditation verification services, and analytics providers. These providers are permitted to use your information only to perform services for us.
• Professional advisors, including attorneys, accountants, auditors, and fund administrators, in connection with the operation of our business and investment offerings.
• Regulators and legal authorities, where required by law, regulation, subpoena, or legal process, or to protect the rights, property, or safety of Circle Stone Capital, our investors, or others.
• Business transfers: in connection with a merger, acquisition, financing, reorganization, or sale of all or a portion of our assets, your information may be transferred as part of that transaction.
• With your consent or at your direction.

4. Third-Party Websites and Services

The Website contains links to third-party websites and embedded third-party content (for example, our investor portal hosted by InvestNext, embedded Vimeo videos, and Google Maps). Your use of those websites and services is governed by their own privacy policies, and we are not responsible for their practices. We encourage you to review the privacy policies of any third-party site you visit.

5. Data Retention

We retain personal information for as long as necessary to fulfill the purposes described in this Privacy Policy, including to satisfy legal, regulatory, tax, accounting, and reporting requirements. Records related to investments are retained for the periods required by applicable securities laws and regulations. When information is no longer required, we securely delete or de-identify it.

6. Data Security

We implement reasonable administrative, technical, and physical safeguards designed to protect your personal information from unauthorized access, use, or disclosure. However, no method of transmission over the internet or method of electronic storage is completely secure, and we cannot guarantee absolute security.

7. Cookies

We use the following categories of cookies on the Website:

• Essential cookies, required for the Website to function (for example, account sign-in);
• Analytics cookies, used to understand how visitors use the Website so we can improve it.

You can manage cookies through your browser settings. Most browsers allow you to refuse or delete cookies. If you disable cookies, some features of the Website may not function properly.

8. Your Privacy Rights

Depending on where you live, you may have the right to:

• Access the personal information we hold about you;
• Correct inaccurate or incomplete information;
• Delete your personal information, subject to legal retention requirements;
• Opt out of marketing communications at any time by using the unsubscribe link in our emails or contacting us directly.

California residents: if you are a California resident, you may have additional rights under the California Consumer Privacy Act (CCPA), as amended, including the right to know what personal information we collect, the right to request deletion, the right to correct, and the right not to receive discriminatory treatment for exercising your rights. We do not sell or share personal information as those terms are defined under the CCPA.

To exercise any of these rights, contact us using the information in Section 12. We may need to verify your identity before fulfilling your request. Please note that we may be required to retain certain information to comply with securities laws and other legal obligations, and some requests may be limited accordingly.

9. Account Deletion

If you have created an account with us through the Website, App, or investor portal, you may request deletion of your account and associated personal information at any time by contacting us at support@circlestonecapital.com or, where available, through the account deletion option within the App. We will process deletion requests promptly, subject to information we are legally required to retain (for example, records of completed investments required under securities and tax laws).

What deletion means

Deleting your account is permanent. Your account and all of your personal data are permanently deleted and cannot be recovered, not by you and not by Circle Stone Capital aside from records that are legally required to be maintained.

You will never be able to sign in to this account again. The email address on the account can never be used to register again.

Before you can delete

Because Circle Stone Capital manages real investments, two conditions must be met first:

1. Your portfolio must be fully liquidated, with a balance of $0. Contact us to arrange liquidation.
2. You must not be the only owner of an investor entity, such as a trust, that still holds investments. Add another owner or liquidate it first.

The app checks both when you start a deletion and tells you which one applies.

How to delete your account

• Website: sign in, open Settings, scroll to Danger Zone and choose Delete. Type DELETE, confirm that you understand the deletion is permanent, and choose Delete.
• Mobile app: open Settings, scroll to Danger Zone and tap Delete Account. Type DELETE, confirm that you understand the deletion is permanent, and tap Delete.
• By email: write to support@circlestonecapital.com from the email address on your account, with the subject "Delete my account". We confirm the request with you before acting on it, and reply when it is done.

Contact us

Questions about deleting your account: support@circlestonecapital.com.

10. Children's Privacy

The Services are not directed to individuals under the age of 18, and we do not knowingly collect personal information from children. If you believe a child has provided us with personal information, please contact us and we will delete it.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we do, we will revise the "Last Updated" date at the top of this page and, for material changes, provide additional notice (such as by email or a notice on the Website). Your continued use of the Services after changes take effect constitutes acceptance of the updated policy.

12. Contact Us

If you have questions about this Privacy Policy or our privacy practices, or wish to exercise your privacy rights, contact us at: