1. INFORMATION WE COLLECT

We collect the following categories of information:

1.1 Information You Provide Directly:

• Name, email address, phone number, company name, and title
• Business metrics (e.g., revenue, EBITDA, ownership structure)
• Investment preferences or mandate criteria (for capital providers)
• Any messages, inquiries, or communications submitted via the Platform

1.2 Automatically Collected Data:

• IP address, browser type, operating system
• Usage data and clickstream behavior
• Device identifiers and location (general, not GPS-level)

We do not collect sensitive personal information such as Social Security numbers, biometric data, or consumer payment details.

2. HOW WE USE YOUR INFORMATION

CapitalSphere uses your information to:

• Assess eligibility for membership
• Facilitate introductions between compatible members
• Provide communications relevant to our services
• Improve the functionality and security of our Platform
• Comply with legal and regulatory obligations

We do not sell your personal information to third parties.

3. INFORMATION SHARING & DISCLOSURE

We may share your information with:

• Affiliated entities within the Bainbridge platform
• Approved CapitalSphere members (e.g., investors introduced to business owners)
• Service providers performing functions on our behalf (e.g., IT, analytics, vetting)
• Regulatory bodies or law enforcement, if required by law or to protect our rights

All third-party service providers are bound by confidentiality agreements and are not permitted to use your data for unrelated purposes.

4. DATA SECURITY

We implement reasonable administrative, technical, and physical safeguards to protect your information. However, no method of transmission over the internet is 100% secure. You use the Services at your own risk.

5. DATA RETENTION

We retain your information as long as necessary to:

• Fulfill the purposes outlined in this policy
• Comply with legal, tax, or regulatory obligations
• Enforce our agreements

When no longer required, data is securely deleted or anonymized.

6. YOUR CHOICES

You may:

• Request access to or correction of your data
• Ask us to delete your information (subject to retention exceptions)
• Opt out of non-essential communications

To exercise any of these rights, contact us at info@capitalsphere.com.

7. COOKIES & TRACKING

We use minimal cookies solely for:

• Session management
• Security enhancement
• Non-identifiable analytics (e.g., aggregate page views)

We do not use third-party advertising trackers or behavioral profiling.

8. CALIFORNIA PRIVACY RIGHTS (CCPA)

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

• Know what categories of data we collect and why
• Request deletion of your personal information
• Not be discriminated against for exercising privacy rights

We do not “sell” personal information as defined under CCPA.

9. CHILDREN’S PRIVACY

Our Services are not intended for individuals under 18. We do not knowingly collect data from children. If we become aware that a minor has submitted personal data, we will promptly delete it.

10. CHANGES TO THIS POLICY

We may update this Privacy Policy periodically. We will notify users of material changes via email or platform notice. Continued use after such updates constitutes acceptance.

11. CONTACT US

If you have any questions, concerns, or requests regarding this policy, please contact:

CapitalSphere, LLC
A Bainbridge Company
Email: info@capitalsphere.com
Phone: 858-638-1800