Legal

Privacy Policy

Effective Date: May 28, 2026Golden Capital LLCGDPR + CCPA/CPRA

Golden Capital LLC is committed to protecting your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use the Golden Circle Capital platform.

1. Introduction

Golden Capital LLC ("Company," "we," "us," or "our") operates the Golden Circle Capital platform at goldencirclecapital.com (the "Service"). This Privacy Policy describes how we collect, use, process, and disclose information about you when you use our Service. By using the Service, you consent to the data practices described in this Policy.

This Policy applies to all users of the Service, regardless of location. Where applicable, it incorporates requirements of the EU General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA), and other applicable privacy laws.

2. Data Controller

For the purposes of applicable data protection law, the data controller responsible for your personal information is:

Golden Capital LLC

1621 Central Ave, Cheyenne, WY 82001, United States

Email: info@goldencirclecapital.com

Website: goldencirclecapital.com

3. Information We Collect

3.1 Information You Provide Directly

CategoryDetails
Account InformationFull name, email address, phone number, password (hashed)
Registration RequestName, email, phone number, optional message submitted in the waitlist form
Profile InformationAny additional profile information you choose to provide
Payment InformationPayment method details processed by Stripe or NowPayments (we do not store full card numbers)
Investment RequestsType of investment, amounts, plan preferences, and notes submitted through the dashboard
Support RequestsMessages, inquiries, and business evaluation requests submitted to the team
Referral InformationYour referral code usage and referral activity within the platform

3.2 Information Collected Automatically

CategoryDetails
Log DataIP address, browser type, operating system, pages visited, time and date of access, referring URLs
Device InformationDevice type, unique device identifiers, mobile network information
Usage DataFeatures used, dashboard interactions, clicks, session duration
Cookies & TrackingSession cookies, preference cookies, analytics identifiers (see Cookie Policy)

3.3 Information from Third Parties

We may receive information about you from third-party service providers including payment processors (Stripe, NowPayments), authentication services (Supabase), and analytics providers. We handle such information in accordance with this Privacy Policy.

4. How We Use Your Information

We use the information we collect for the following purposes:

CategoryDetails
Service ProvisionTo create and manage your account, process subscription payments, and provide access to the platform features
Investment FacilitationTo process investment requests, connect you with Fund Operators, and maintain your investment dashboard
CommunicationsTo send you service-related emails, subscription confirmations, notifications, and administrative messages
SecurityTo verify identity, prevent fraud, detect and respond to security incidents, and enforce our Terms of Service
Legal ComplianceTo comply with applicable laws, regulations, legal processes, and governmental requests
Service ImprovementTo analyze usage patterns, troubleshoot issues, and improve platform functionality
Referral TrackingTo track referral activity and calculate commissions for affiliate programs
MarketingTo send promotional communications where you have given consent (you may opt out at any time)

Legal bases for processing (where GDPR applies): contract performance, legitimate interests, legal obligation, and consent where explicitly obtained.

5. Sharing of Information

We do not sell, trade, or rent your personal information to third parties. We may share your information in the following circumstances:

5.1 Service Providers

We share information with third-party vendors who assist us in operating the Service, including: Supabase (database and authentication), Stripe (payment processing), NowPayments (cryptocurrency payments), Vercel (hosting and deployment), and email service providers. These providers are contractually bound to process data only on our instructions.

5.2 Fund Operators

If you submit an investment request and it is approved, we will share your relevant personal information (name, contact details, investment details) with the relevant Fund Operator solely to facilitate the investment relationship. This sharing is subject to confidentiality obligations.

5.3 Legal Requirements

We may disclose your information if required to do so by law, regulation, court order, governmental authority, or when we believe disclosure is necessary to protect our rights, your safety, or the safety of others.

5.4 Business Transfers

In the event of a merger, acquisition, or sale of all or a portion of our assets, your information may be transferred as part of that transaction. We will provide notice before your information becomes subject to a different privacy policy.

5.5 Consent

We may share your information with third parties when you have given us explicit consent to do so.

6. Data Retention

We retain your personal information for as long as necessary to provide the Service and fulfill the purposes outlined in this Policy, unless a longer retention period is required or permitted by law.

CategoryDetails
Account DataRetained for the duration of your account plus 3 years after closure
Transaction & Payment RecordsRetained for 7 years for tax and accounting purposes
Investment Request DataRetained for 7 years following the last transaction
Support CommunicationsRetained for 3 years from the date of last communication
Log and Analytics DataRetained for 13 months from collection, then aggregated or deleted
Marketing Consent RecordsRetained until you withdraw consent plus 3 years

When your personal data is no longer needed, we will securely delete or anonymize it in accordance with our data retention procedures.

7. Data Security

We implement appropriate technical and organizational measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include:

  • Encryption of data in transit using TLS/HTTPS
  • Encryption of sensitive data at rest within our database
  • Password hashing using industry-standard algorithms
  • Row-level security policies restricting data access by user
  • Regular security reviews and access controls
  • Two-factor authentication options for administrator accounts

However, no method of transmission over the Internet or electronic storage is 100% secure. While we strive to protect your personal information, we cannot guarantee its absolute security. If you believe your information has been compromised, please contact us immediately at info@goldencirclecapital.com.

8. Your Rights

Depending on your location, you may have the following rights with respect to your personal information:

CategoryDetails
Right of AccessRequest a copy of the personal data we hold about you
Right to RectificationRequest correction of inaccurate or incomplete personal data
Right to ErasureRequest deletion of your personal data, subject to legal retention requirements
Right to RestrictionRequest restriction of processing in certain circumstances
Right to PortabilityReceive your data in a structured, machine-readable format
Right to ObjectObject to processing based on legitimate interests or for direct marketing
Right to Withdraw ConsentWithdraw consent at any time where processing is based on consent
Right to Non-DiscriminationNot be discriminated against for exercising your privacy rights

To exercise any of these rights, please submit a request to info@goldencirclecapital.com. We will respond within thirty (30) days. We may need to verify your identity before processing your request.

9. California Privacy Rights (CCPA/CPRA)

If you are a California resident, you have specific rights under the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA):

9.1 Right to Know

You have the right to request that we disclose: the categories and specific pieces of personal information we collected about you; the categories of sources from which we collected personal information; the business or commercial purpose for collecting personal information; and the categories of third parties with whom we share personal information.

9.2 Right to Delete

You have the right to request deletion of your personal information, subject to certain exceptions including information necessary to complete transactions, detect security incidents, comply with legal obligations, or enable solely internal uses aligned with your expectations.

9.3 Right to Correct

You have the right to request correction of inaccurate personal information we maintain about you.

9.4 Right to Opt-Out of Sale or Sharing

We do not sell personal information as defined under CCPA/CPRA. We do not share personal information for cross-context behavioral advertising.

9.5 Right to Limit Use of Sensitive Personal Information

We do not use sensitive personal information beyond what is necessary to provide our services.

9.6 How to Submit a CCPA Request

To exercise your California privacy rights, please email info@goldencirclecapital.com with the subject line "California Privacy Rights Request." We will not discriminate against you for exercising your rights.

10. International Data Transfers

Golden Capital LLC is based in Wyoming, USA. If you are accessing the Service from outside the United States, your information will be transferred to, stored, and processed in the United States. By using the Service, you consent to this transfer.

For users in the European Economic Area (EEA), United Kingdom, or Switzerland, we rely on the following legal mechanisms for international data transfers: Standard Contractual Clauses (SCCs) approved by the European Commission, or other appropriate safeguards as required by applicable law.

We take appropriate measures to ensure that your personal data remains protected wherever it is transferred, in accordance with this Privacy Policy and applicable law.

11. Children's Privacy (COPPA)

The Service is not directed to children under the age of 13. We do not knowingly collect personal information from children under 13 in violation of the Children's Online Privacy Protection Act (COPPA). If you are under 13, please do not use the Service or provide any personal information.

If we learn that we have collected personal information from a child under 13 without parental consent, we will take steps to delete that information as quickly as possible. If you believe we might have information from or about a child under 13, please contact us at info@goldencirclecapital.com.

12. Cookies

We use cookies and similar tracking technologies to operate and improve the Service. Please refer to our Cookie Policy for detailed information about the cookies we use, their purposes, and how to manage your preferences.

Essential cookies required for the Service to function cannot be disabled. You may control non-essential cookies through your browser settings or our cookie preference center.

13. Third-Party Services

The Service integrates with third-party services that have their own privacy policies. We are not responsible for the privacy practices of these third parties. We encourage you to review their policies:

CategoryDetails
SupabaseDatabase, authentication, storage — supabase.com/privacy
StripePayment processing — stripe.com/privacy
NowPaymentsCryptocurrency payments — nowpayments.io/privacy-policy
VercelHosting and deployment — vercel.com/legal/privacy-policy

14. Changes to This Policy

We may update this Privacy Policy from time to time. When we make changes, we will update the "Effective Date" at the top of this page. For material changes, we will provide notice via email or through a prominent notice on the Platform at least thirty (30) days before the changes take effect. Your continued use of the Service after the effective date constitutes acceptance of the updated Policy.

15. Contact & Requests

For any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact our privacy team at:

Golden Capital LLC — Privacy Team

1621 Central Ave, Cheyenne, WY 82001, United States

Email: info@goldencirclecapital.com

Subject line: "Privacy Request"

We will respond to all privacy requests within thirty (30) days. For requests requiring identity verification, we may ask for additional information to confirm your identity before processing.