Privacy Policy
Effective Date:4/11/2025
Last Updated: 4/11/2025

SITG Capital (“SITG,” “we,” “our,” or “us”) values your privacy. This Privacy Policy outlines how we collect, use, disclose, and protect your information when you visit our website (www.sitgcapital.com) and engage with us through our investor portal or communication platforms such as HubSpot. This policy also includes disclosures required by the General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA).

1. Information We Collect

a. Information You Provide:

  • Name, email address, phone number, and any other information you submit via:

    • Contact forms

    • Newsletter sign-ups

    • Investor inquiry forms

    • Registration for the investor portal

b. Automatically Collected Information:

  • Browser type, IP address, referring URL, pages visited, time spent on pages, and other technical data collected via cookies and tracking tools.

c. Through Third-Party Platforms:

  • We use HubSpot for customer relationship management (CRM) and email marketing. Information submitted through our site or email campaigns may be collected and stored via HubSpot.

  • Our Investor Portal (powered by [appfolioim.com]) collects and stores information related to your investment activity, including account registration, subscription documents, and capital contributions.

2. How We Use Your Information

We use your information to:

  • Respond to your questions and requests

  • Send newsletters, updates, and relevant investment opportunities

  • Manage your investor account and provide access to the portal

  • Analyze website performance and user engagement

  • Comply with applicable legal obligations

3. Your Rights (GDPR & CCPA)

If you are an EEA resident, you have the right to:

  • Access your personal data

  • Request correction or deletion of your data

  • Object to or restrict data processing

  • Data portability

  • Withdraw consent at any time

If you are a California resident, you have the right to:

  • Know what personal information we collect, use, disclose, and sell (we do not sell your data)

  • Request deletion of your personal information

  • Opt out of the sale of personal data (again, we do not sell it)

  • Non-discrimination for exercising your CCPA rights

To exercise your rights, please contact us at: privacy@sitgcapital.com

4. Sharing of Information

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

  • HubSpot, for email marketing and communication workflows

  • Investor portal providers, for secure investor access and document management

  • Legal and regulatory authorities when required

  • Service providers under contract who assist with operations, hosting, and analytics

5. Cookies and Tracking Technologies

We use cookies to:

  • Improve site functionality and user experience

  • Track how visitors use our site (via HubSpot, Google Analytics, etc.)

You may disable cookies in your browser settings. However, this may affect the functionality of our website and portal.

6. Data Retention and Security

We retain your data only as long as necessary for the purposes outlined in this policy or as required by law.
We use administrative, technical, and physical safeguards to protect your data, including encryption and secure access controls.

7. Third-Party Links

Our website may contain links to third-party websites. We are not responsible for their privacy practices. We recommend reviewing their privacy policies before submitting personal data.

8. Children’s Privacy

Our services are not directed to individuals under 18. We do not knowingly collect personal information from children.

9. Changes to This Policy

We may update this Privacy Policy periodically. Any changes will be posted on this page, and the “Last Updated” date will be revised accordingly.

10. Contact Us

If you have questions or concerns about this policy or your data, please contact:

SITG Capital
Email: invest@sitgcapital.com
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