Privacy Policy
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
| Category | Details |
|---|---|
| Account Information | Full name, email address, phone number, password (hashed) |
| Registration Request | Name, email, phone number, optional message submitted in the waitlist form |
| Profile Information | Any additional profile information you choose to provide |
| Payment Information | Payment method details processed by Stripe or NowPayments (we do not store full card numbers) |
| Investment Requests | Type of investment, amounts, plan preferences, and notes submitted through the dashboard |
| Support Requests | Messages, inquiries, and business evaluation requests submitted to the team |
| Referral Information | Your referral code usage and referral activity within the platform |
3.2 Information Collected Automatically
| Category | Details |
|---|---|
| Log Data | IP address, browser type, operating system, pages visited, time and date of access, referring URLs |
| Device Information | Device type, unique device identifiers, mobile network information |
| Usage Data | Features used, dashboard interactions, clicks, session duration |
| Cookies & Tracking | Session 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:
| Category | Details |
|---|---|
| Service Provision | To create and manage your account, process subscription payments, and provide access to the platform features |
| Investment Facilitation | To process investment requests, connect you with Fund Operators, and maintain your investment dashboard |
| Communications | To send you service-related emails, subscription confirmations, notifications, and administrative messages |
| Security | To verify identity, prevent fraud, detect and respond to security incidents, and enforce our Terms of Service |
| Legal Compliance | To comply with applicable laws, regulations, legal processes, and governmental requests |
| Service Improvement | To analyze usage patterns, troubleshoot issues, and improve platform functionality |
| Referral Tracking | To track referral activity and calculate commissions for affiliate programs |
| Marketing | To 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.
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.
| Category | Details |
|---|---|
| Account Data | Retained for the duration of your account plus 3 years after closure |
| Transaction & Payment Records | Retained for 7 years for tax and accounting purposes |
| Investment Request Data | Retained for 7 years following the last transaction |
| Support Communications | Retained for 3 years from the date of last communication |
| Log and Analytics Data | Retained for 13 months from collection, then aggregated or deleted |
| Marketing Consent Records | Retained 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:
| Category | Details |
|---|---|
| Right of Access | Request a copy of the personal data we hold about you |
| Right to Rectification | Request correction of inaccurate or incomplete personal data |
| Right to Erasure | Request deletion of your personal data, subject to legal retention requirements |
| Right to Restriction | Request restriction of processing in certain circumstances |
| Right to Portability | Receive your data in a structured, machine-readable format |
| Right to Object | Object to processing based on legitimate interests or for direct marketing |
| Right to Withdraw Consent | Withdraw consent at any time where processing is based on consent |
| Right to Non-Discrimination | Not 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.
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:
| Category | Details |
|---|---|
| Supabase | Database, authentication, storage — supabase.com/privacy |
| Stripe | Payment processing — stripe.com/privacy |
| NowPayments | Cryptocurrency payments — nowpayments.io/privacy-policy |
| Vercel | Hosting 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.