Last Updated: January 20, 2025
Who we are
Welcome to www.stapleton.com (“Website”). We are committed to protecting your privacy and handling your personal information with transparency and care. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our Website.
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GDPR Applicability Statement
This Website is intended for use by individuals and entities located in the United States and other non-European Economic Area (non-EEA) countries. We do not actively target or market to individuals in the European Economic Area (EEA), and our services are not intended for use by EEA residents. By using our Website, you acknowledge and agree that your information may be processed in countries outside the EEA (including the United States) where data protection standards may differ.
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Information We Collect
Information You Provide to Us
- Contact information (name, email address, phone number)
- Account credentials (username and password)
- Billing information (credit card details, billing address)
- Investment-related information (accredited investor status, investment experience, financial goals)
- Any other information you choose to provide
Information Automatically Collected
- Device information (browser type, IP address, device type)
- Usage data (pages visited, time spent on pages)
- Cookies and similar tracking technologies
- Location information
Investor-Specific Information
Accredited Investor Verification
We collect additional information from individuals who wish to be verified as accredited investors, including:
- Income verification documentation
- Net worth statements
- Professional certifications
- Investment history
- Securities holdings information
Investment Communications
- We may send investment-related communications, including:
- Offering materials
- Investment opportunities
- Portfolio updates
- Risk disclosures
- Regulatory notices
Regulatory Compliance
We maintain records in accordance with applicable securities laws, including:
- Securities and Exchange Commission (SEC) requirements
- Financial Industry Regulatory Authority (FINRA) regulations
- State securities laws
- Bank Secrecy Act requirements
- Anti-money laundering (AML) regulations
How We Use Your Information
We use the collected information for:
- Providing and maintaining our services
- Processing your transactions
- Responding to your inquiries
- Sending promotional communications (with your consent)
- Improving our Website and user experience
- Analyzing usage patterns and trends
- Detecting and preventing fraud
- Verifying accredited investor status
- Maintaining regulatory compliance
- Processing investment transactions
Information Sharing and Disclosure
We may share your information with:
- Service providers and business partners
- Legal authorities when required by law
- Third parties in connection with a business transfer
- Investment advisors and managers
- Regulatory authorities
- Other parties with your consent
We do not sell your personal information to third parties.
Data Retention and Storage
All data is stored on servers located in the United States. We retain personal information for as long as necessary to:
- Comply with our legal obligations
- Enforce our agreements
- Resolve disputes
- Meet regulatory requirements
Data Security
We implement appropriate technical and organizational measures to protect your personal information. However, no method of transmission over the internet is 100% secure, and we cannot guarantee absolute security.
Cookies
Your Rights and Choices
You have the right to:
- Access your personal information
- Correct inaccurate information
- Request deletion of your information
- Opt-out of marketing communications
- Disable cookies through your browser settings
Children’s Privacy
Our Website is not intended for children under 13 years of age. We do not knowingly collect information from children under 13.
International Data Transfers
While we do not actively target EEA residents, any data we receive is processed in the United States. By using our Website, you consent to the transfer of your information to the United States and acknowledge that this jurisdiction may not provide the same level of data protection as your home country.
Changes to This Privacy Policy
We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the new Privacy Policy on this page and updating the “Last Updated” date.
Contact Us
If you have questions about this Privacy Policy, please contact us at:
Email: privacy@stapleton.com Address: Phone: 650-584-9365
Governing Law
This Privacy Policy is governed by and construed in accordance with the laws of [Insert Jurisdiction]. Any disputes relating to this Privacy Policy shall be subject to the exclusive jurisdiction of the courts of The United States of America.