Privacy Policy

Introduction

Welcome to Capitellio Capital Partners, LLC (“Capitellio,” “we,” “us,” or “our”). This Privacy Policy explains how we collect, use, disclose, and protect personal information through our website at www.capitellio.com, our mobile applications, and any related services (collectively, the “Services”).

Throughout this Privacy Policy, we use “you” and “your” to refer to visitors and users of our Services who are at least 18 years of age. By using our Services, you agree to the collection, use, and disclosure of your personal information as described in this Privacy Policy and you agree to comply with our Terms of Use. If you do not consent to this Privacy Policy or our Terms of Use, please do not use our Services or provide us with any personal information.

Important Note: This Privacy Policy does not describe the privacy practices of any third party that may have access to your personal information. We encourage you to review the privacy policies of any third-party websites or services before providing them with your information.

Table of Contents

1. Information We Collect
2. How We Use Your Information
3. How We Share Your Information
4. How We Store and Protect Your Information
5. Your Choices and Rights
6. Do Not Track Signals
7. Children’s Privacy
8. Links to Third-Party Websites and Services
9. State-Specific Privacy Rights
10. International Data Transfers
11. Changes to This Privacy Policy
12. How to Contact Us

1. INFORMATION WE COLLECT

 Personal Information means information that identifies, relates to, describes, or could reasonably be linked to you or your household. We collect personal information that you provide directly to us, that we collect automatically, and that we receive from third parties.

A. Information You Provide to Us

Registration and Account Information: When you create an account or register for our Services, we collect your name, email address, phone number, physical address, company information, job title, and other contact details.

Investor Information: If you apply to join our Investor Club or invest with us, we may collect additional information including:

• Financial information (income, net worth, investment experience, accredited investor status)
• Employment and professional information
• Investment preferences and objectives
• Government-issued identification for verification purposes
• Tax identification numbers
• Banking and payment information

Communication Information: When you contact us via email, phone, forms, or other means, we collect the content of your communications, including any personal information you choose to include.

Event and Newsletter Registration: When you register for events, webinars, or subscribe to our newsletters, we collect your name, email address, company information, and areas of interest.

Employment Applications: If you apply for employment with us, we collect professional and employment-related information including your resume, work history, education, references, and other information you provide during the application process.

B. Information We Collect Automatically

Technical Information: We automatically collect certain technical information when you use our Services, including:

• Browser type and version
• Operating system
• Internet Protocol (IP) address
• Device identifiers
• Pages visited, time spent on pages, links clicked
• Referring to website addresses
• Bandwidth speed and connection information

Cookies and Similar Technologies: We use cookies, web beacons, pixels, and similar tracking technologies to collect information about your use of our Services. Cookies are small text files stored on your device that help us recognize you and remember your preferences. You can control cookies through your browser settings, though disabling cookies may limit your ability to use certain features of our Services.

We use the following types of cookies:

• Essential Cookies: Required for the Services to function properly
• Analytics Cookies: Help us understand how visitors use our Services
• Functional Cookies: Remember your preferences and settings
• Marketing Cookies: Track your activity for advertising purposes (with your consent where required)

We may use third-party analytics services, including Google Analytics, to help us understand how users interact with our Services. You can learn more about Google Analytics’ privacy practices at www.google.com/policies/privacy/partners/ and opt out at https://tools.google.com/dlpage/gaoptout.

Mobile Device Information: When you access our Services through a mobile device, we may collect unique device identifiers, mobile operating system information, and, with your permission, precise geolocation data. You can disable location services through your device settings.

C. Information We Receive from Third Parties

We may receive personal information about you from third parties, including:

• Background check providers and verification services
• Credit reporting agencies and financial institutions
• Professional references and previous employers
• Marketing and data analytics providers
• Public databases and records
• Social media platforms (if you connect your accounts)

2. HOW WE USE YOUR INFORMATION

We use the personal information we collect for the following purposes:

To Provide Our Services:

• Create and manage your account
• Process and manage your investments
• Verify your identity and accredited investor status
• Communicate with you about your investments and account
• Provide customer support and respond to your inquiries
• Process transactions and send transaction confirmations

For Business Operations:

• Analyze and improve our Services
• Conduct internal research and data analysis
• Develop new products and services
• Manage our relationships with investors, partners, and vendors
• Administer our business operations
• Conduct audits and financial reporting

For Marketing and Communications:

• Send you information about investment opportunities
• Provide newsletters, market updates, and educational content
• Notify you about events, webinars, and programs
• Conduct surveys and gather feedback
• Personalize your experience with our Services

For Legal and Compliance Purposes:

• Comply with legal and regulatory obligations
• Respond to legal process (subpoenas, court orders, government requests)
• Enforce our Terms of Use and other agreements
• Detect, prevent, and investigate fraud, security incidents, and illegal activities
• Protect our rights, property, and safety, and those of our users and others
• Perform background checks and due diligence
• Maintain records as required by securities laws and regulations

For Employment Purposes:

• Evaluate job applications and qualifications
• Conduct interviews and background checks
• Make hiring decisions
• Manage our workforce

3. HOW WE SHARE YOUR INFORMATION

We may share your personal information with third parties in the following circumstances:

Service Providers: We share personal information with third-party vendors and service providers who perform services on our behalf, including:

• Technology and hosting providers
• Payment processors and financial institutions
• Customer relationship management platforms
• Marketing and analytics providers
• Legal, accounting, and professional advisors
• Background check and verification services
• Document management and compliance platforms

Business Partners: We may share information with:

• Property management companies
• Construction and renovation contractors
• Real estate brokers and agents
• Co-investment partners
• Other real estate operators and sponsors

Affiliates: We may share personal information with our parent company, subsidiaries, and affiliated entities under common ownership or control. These entities will use your information in accordance with this Privacy Policy.

Legal Requirements: We may disclose personal information when required by law or in response to:

• Subpoenas, court orders, or other legal process
• Requests from government or regulatory authorities
• National security or law enforcement requirements
• Legal claims, investigations, or litigation

Business Transfers: If we are involved in a merger, acquisition, sale of assets, financing, bankruptcy, or other business transaction, your personal information may be transferred as part of that transaction.

With Your Consent: We may share your information with third parties when you have given us permission to do so.

Aggregated and De-Identified Information: We may share aggregated, anonymized, or de-identified information that cannot reasonably be used to identify you for any lawful business purpose.

Important Note: We do not sell your personal information to third parties for monetary consideration. We do not share personal information with third parties for their own direct marketing purposes without your consent.

4. HOW WE STORE AND PROTECT YOUR INFORMATION

 Data Security: We implement reasonable technical, administrative, and physical security measures designed to protect your personal information from unauthorized access, disclosure, alteration, and destruction. These measures include:

• Encryption of data in transit and at rest
• Access controls and authentication requirements
• Regular security assessments and audits
• Employee training on data protection
• Secure data centers and infrastructure
• Incident response and breach notification procedures

Data Retention: We retain your personal information for as long as necessary to fulfill the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law. Factors we consider in determining retention periods include:

• Legal and regulatory requirements (including securities laws requiring record retention)
• Contractual obligations
• Litigation and dispute resolution needs
• Business operational needs
• Your account status and activity

Limitations: While we strive to protect your personal information, no security system is impenetrable. We cannot guarantee the absolute security of your information, and we disclaim liability for unauthorized access, disclosure, or loss of data except as required by applicable law.

Incident Response: In the event of a data breach or security incident affecting your personal information, we will take appropriate steps to investigate, mitigate the situation, and provide required notifications in accordance with applicable laws.

5. YOUR CHOICES AND RIGHTS

 Account Information: If you have an account with us, you may access, update, or correct your account information by logging into your account or contacting us at legal@capitellio.com.

Marketing Communications: You may opt out of receiving promotional emails and marketing communications by:

• Clicking the “unsubscribe” link in promotional emails
• Adjusting your communication preferences in your account settings
• Contacting us at legal@capitellio.com

Please note that even if you opt out of marketing communications, we will still send you transactional and account-related communications.

Cookies: You can control cookies through your browser settings. Most browsers allow you to refuse or delete cookies. Please note that disabling cookies may affect your ability to use certain features of our Services.

Mobile Device Permissions: You can control mobile device permissions (such as location access, camera, contacts) through your device settings.

6. DO NOT TRACK SIGNALS

Some web browsers have “Do Not Track” features that allow you to tell websites not to track your online activities. At this time, our Services do not respond to Do Not Track signals from browsers.

7. CHILDREN’S PRIVACY

Our Services are not directed to individuals under the age of 18, and we do not knowingly collect personal information from children. Our Terms of Use require that users be at least 18 years of age. If we learn that we have collected personal information from a child under 18, we will delete that information promptly. If you believe we have collected information from a child under 18, please contact us at legal@capitellio.com.

8. LINKS TO THIRD-PARTY WEBSITES AND SERVICES

Our Services may contain links to third-party websites, applications, and services that are not controlled by us. This Privacy Policy does not apply to those third-party services. We are not responsible for the privacy practices of third parties, and we encourage you to review their privacy policies before providing them with any personal information.

9. STATE-SPECIFIC PRIVACY RIGHTS

A. California Residents

California Consumer Privacy Act (CCPA) / California Privacy Rights Act (CPRA):

If you are a California resident, you have specific rights under California law regarding your personal information.

Categories of Personal Information We Collect:

In the past 12 months, we have collected the following categories of personal information:

• Identifiers (name, address, email, phone number, IP address, account credentials)
• California Customer Records information (financial information, payment card information)
• Protected classification characteristics (age, gender, veteran status – for employment purposes)
• Commercial information (transaction history, investment preferences)
• Internet/electronic activity (browsing history, interactions with our Services)
• Geolocation data (approximate location based on IP address, precise location with your consent)
• Professional or employment information (employer, job title, work history)
• Inferences (preferences, characteristics, behavior patterns)
• Sensitive personal information (financial account information, Social Security number, precise geolocation)

Your California Privacy Rights:

1. Right to Know: You have the right to request that we disclose:
   • Categories of personal information we collected about you
   • Categories of sources from which we collected personal information
   • Business or commercial purposes for collecting or selling personal information
   • Categories of third parties with whom we share personal information
   • Specific pieces of personal information we collected about you
2. Right to Delete: You have the right to request deletion of personal information we collected from you, subject to certain exceptions.
3. Right to Correct: You have the right to request correction of inaccurate personal information we maintain about you.
4. Right to Opt-Out of Sale/Sharing: We do not sell personal information or share it for cross-context behavioral advertising purposes. If our practices change, we will provide an opt-out mechanism.
5. Right to Limit Use of Sensitive Personal Information: We use sensitive personal information only for permitted purposes under California law. You have the right to limit our use of sensitive personal information.
6. Right to Non-Discrimination: We will not discriminate against you for exercising your California privacy rights.

How to Exercise Your Rights:

To exercise your rights, contact us at:

• Email: legal@capitellio.com
• Phone: +1 (725) 208-3133
• Mail: Capitellio Capital Partners, LLC, 3225 McLeod Dr. Suite 100, Las Vegas, NV 89121

You may also designate an authorized agent to make requests on your behalf. We will verify your identity before responding to your request.

California “Shine the Light” Law:

California residents may request information about our disclosure of personal information to third parties for direct marketing purposes. To make such a request, please contact us at legal@capitellio.com.

B. Colorado, Connecticut, Montana, Oregon, Utah, and Virginia Residents

If you are a resident of Colorado, Connecticut, Montana, Oregon, Utah, or Virginia, you may have rights similar to those described above for California residents under your state’s privacy law. To exercise any applicable rights, please contact us using the contact information provided above.

C. Nevada Residents

We do not sell personal information as defined under Nevada law. If you are a Nevada resident and would like to opt out of any potential future sales of your personal information, please contact us at legal@capitellio.com.

D. Texas Residents

Texas Data Privacy and Security Act:

If you are a Texas resident, you have specific rights under the Texas Data Privacy and Security Act.

Consumer Rights:

1. Right to Confirm and Access: You have the right to confirm whether we are processing your personal data and to access that data.
2. Right to Correction: You have the right to correct inaccuracies in your personal data.
3. Right to Deletion: You have the right to request deletion of personal data we collected from you, subject to certain exceptions.
4. Right to Data Portability: You have the right to obtain a copy of your personal data in a portable format.
5. Right to Opt-Out: You have the right to opt out of:
   • The sale of your personal data (we do not sell personal data)
   • Processing for targeted advertising (we do not engage in targeted advertising)
   • Profiling in furtherance of decisions that produce legal or similarly significant effects (we do not engage in such profiling)

Sensitive Personal Data:

We collect and process sensitive personal data (such as financial information and Social Security numbers) only for the following lawful purposes:

• To perform services reasonably expected by consumers
• To prevent, detect, and investigate security incidents
• To resist malicious, fraudulent, or illegal actions
• To ensure the physical safety of natural persons
• To verify or maintain the quality of our services
• For compliance with legal obligations

How to Exercise Your Rights:

To exercise your Texas privacy rights, contact us at:

• Email: legal@capitellio.com
• Phone: +1 (725) 208-3133
• Mail: Capitellio Capital Partners, LLC, 3225 McLeod Dr. Suite 100, Las Vegas, NV 89121

We will respond to verified requests within 45 days, with a possible 45-day extension if needed.

Right to Appeal:

If we deny your request, you have the right to appeal our decision. To file an appeal, contact us at legal@capitellio.com. We will respond to your appeal within 60 days. If we deny your appeal, you may contact the Texas Attorney General at:

Office of the Attorney General
P.O. Box 12548
Austin, TX 78711-2548
Website: www.texasattorneygeneral.gov/consumercomplaintportal/

10. INTERNATIONAL DATA TRANSFERS

 Our Services are operated in the United States. If you are located outside the United States, please be aware that information we collect will be transferred to, stored, and processed in the United States. The data protection laws in the United States may differ from those in your country of residence. By using our Services, you consent to the transfer of your information to the United States.

11. CHANGES TO THIS PRIVACY POLICY

 We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes, we will update the “Last Updated” date at the top of this Privacy Policy and may provide additional notice (such as via email or a prominent notice on our website).

We encourage you to review this Privacy Policy periodically. Your continued use of our Services after any changes indicates your acceptance of the updated Privacy Policy.

12. HOW TO CONTACT US

If you have questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us at:

Capitellio Capital Partners, LLC
Attention: Legal Department – Privacy
3225 McLeod Dr., Suite 100

Las Vegas, NV 89121

Email: legal@capitellio.com
Phone: +1 (725) 208-3133

Last Updated: November 1, 2025