1. Introduction

Crown Point Equities LLC ("Crown Point," "we," "us," or "our") respects your privacy and is committed to protecting your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard information when you visit our website or engage with our investment services.

This policy applies to all users of our website and prospective investors. By accessing our website or providing us with personal information, you consent to the practices described in this Privacy Policy.

Effective Date: December 3, 2025

2. Information We Collect

We collect several types of information from and about users of our website and investment services:

Personal Information You Provide Directly

• Contact Information: Name, email address, phone number, mailing address

• Investor Qualification Information: Financial information necessary to verify accredited investor status including income, net worth, professional certifications (Series 7, 65, 82 licenses), employment information

• Investment Preferences: Property preferences, investment goals, timeline, risk tolerance

• Identity Verification: Government-issued identification, Social Security number (for tax reporting and anti-money laundering compliance), date of birth

• Banking Information: Bank account details, wire transfer information (for investment transactions)

• Professional Information: Company name, job title, business address

Information Collected Automatically

• Device Information: IP address, browser type, operating system, device identifiers

• Usage Data: Pages viewed, time spent on pages, links clicked, referring website

• Location Data: General geographic location based on IP address

• Cookies and Tracking Technologies: We use cookies, web beacons, and similar technologies to enhance user experience and analyze website traffic

Information from Third Parties

• Background Checks: For compliance purposes, we may obtain information from credit bureaus, public records, and watchlist databases

• Verification Services: Third-party services that verify accredited investor status

• Professional References: Information from financial advisors, attorneys, or other professionals you authorize us to contact

3. How We Use Your Information

We use the information we collect for the following purposes:

Investment Services

• Process and evaluate investment inquiries

• Verify accredited investor status as required by SEC regulations

• Prepare and execute subscription agreements

• Process investment transactions and distributions

• Provide investor communications and reporting

• Maintain investor records and documentation

Legal and Regulatory Compliance

• Comply with securities laws and regulations

• Conduct Know Your Customer (KYC) verification

• Perform anti-money laundering (AML) screening

• File required tax forms (IRS Form 1099, K-1 statements)

• Respond to legal requests and prevent fraud

Business Operations

• Respond to your inquiries and provide customer support

• Send investment opportunities, market updates, and newsletters

• Improve our website, services, and user experience

• Analyze website traffic and user behavior

• Protect against security threats and unauthorized access

4. How We Share Your Information

We may share your information with third parties in the following circumstances:

Service Providers

• Fund Administrators: Third-party administrators who manage fund accounting, investor reporting, and distributions

• Legal and Tax Professionals: Attorneys, accountants, and tax advisors who provide services to the fund

• Verification Services: Companies that verify accredited investor status and perform background checks

• Technology Providers: Website hosting, email services, CRM platforms, data analytics

• Financial Institutions: Banks and custodians that process investment transactions

Business Partners

• Co-Investment Partners: When you invest in properties with joint venture partners, your information may be shared with those partners

• Real Estate Professionals: Brokers, property managers, and development partners involved in specific projects

Legal Requirements

• Comply with subpoenas, court orders, or legal processes

• Respond to government or regulatory inquiries

• Enforce our Terms and Conditions or other agreements

• Protect the rights, property, or safety of Crown Point Equities, our investors, or others

• Detect, prevent, or address fraud, security, or technical issues

Business Transfers

If Crown Point Equities is involved in a merger, acquisition, asset sale, or bankruptcy, your information may be transferred as part of that transaction. We will notify you of any such change in ownership or control of your personal information.

With Your Consent

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

5. California Privacy Rights (CCPA)

If you are a California resident, you have specific rights regarding your personal information under the California Consumer Privacy Act (CCPA):

Right to Know

• The categories and specific pieces of personal information we have collected about you

• The categories of sources from which we collected your information

• The business or commercial purpose for collecting your information

• The categories of third parties with whom we share your information

Right to Delete

You have the right to request deletion of personal information we have collected from you, subject to certain exceptions (e.g., information required for legal compliance, completing transactions, or security purposes).

Right to Opt-Out of Sale

Crown Point Equities does not sell personal information as defined by the CCPA. We do not and will not sell your personal information to third parties for monetary consideration.

Right to Non-Discrimination

You have the right to exercise your CCPA rights without receiving discriminatory treatment. However, we may charge different prices or provide different service levels if the difference is reasonably related to the value provided by your data.

How to Exercise Your Rights

To exercise your CCPA rights, please contact us at:

• Email: [privacy@crownpointequities.com]

• Phone: [Your Phone Number]

• Mail: Crown Point Equities LLC, San Diego, California

We will verify your identity before processing your request. You may designate an authorized agent to make requests on your behalf, provided you give the agent written permission and verify your identity with us.

Response Timeline

We will respond to verifiable consumer requests within 45 days of receipt. If we require more time (up to 90 days total), we will inform you of the reason and extension period in writing.

6. Data Security

We implement reasonable administrative, technical, and physical security measures to protect your personal information from unauthorized access, disclosure, alteration, and destruction. These measures include:

• Encryption of sensitive data in transit and at rest

• Secure socket layer (SSL) technology for data transmission

• Access controls and authentication requirements

• Regular security assessments and updates

• Employee training on data security and privacy

• Secure storage of physical documents containing personal information

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.

7. Data Retention

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

Investor Information: For current and former investors, we retain information for at least seven years following the termination of your investment, as required by securities regulations and tax laws.

Prospective Investor Information: We retain information from prospective investors who do not complete an investment for up to three years, after which it is deleted unless you request continued communication.

Website Usage Data: We retain website analytics data for up to two years.

8. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to enhance your experience on our website. Cookies are small data files stored on your device that help us recognize you and remember your preferences.

Types of Cookies We Use

• Essential Cookies: Required for website functionality and security

• Analytics Cookies: Help us understand how visitors use our website

• Preference Cookies: Remember your settings and preferences

• Marketing Cookies: Track website visits to deliver relevant content

Managing Cookies

Most web browsers allow you to control cookies through their settings. You can set your browser to refuse cookies or alert you when cookies are being sent. Note that disabling cookies may limit your ability to use certain features of our website.

9. Third-Party Links

Our website may contain links to third-party websites, such as property listing services, market research platforms, or financial news sites. We are not responsible for the privacy practices or content of these external sites. We encourage you to review the privacy policies of any third-party sites you visit.

10. Children's Privacy

Our website and services are not directed to individuals under the age of 18. We do not knowingly collect personal information from children. If we become aware that we have collected information from a child under 18, we will take steps to delete that information promptly.

11. International Data Transfers

Crown Point Equities is based in California, United States. If you access our website or services from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States, where data protection laws may differ from those in your jurisdiction.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will post the updated policy on our website with a new "Effective Date."

Material changes that significantly affect your privacy rights will be communicated through prominent notice on our website or via email to active investors. Your continued use of our website or services after any changes indicates your acceptance of the updated Privacy Policy.

13. Do Not Track Signals

Some web browsers include a "Do Not Track" (DNT) feature that signals websites you visit that you do not want your online activity tracked. Our website does not currently respond to DNT signals or similar mechanisms.

14. Contact Information

If you have questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us:

Crown Point Equities LLC
Privacy Officer
San Diego, California
Email: [privacy@crownpointequities.com]
Phone: [Your Phone Number]

For California residents exercising CCPA rights, please clearly state "CCPA Request" in your communication.

15. Consent

By using our website or providing us with personal information, you consent to the collection, use, and sharing of your information as described in this Privacy Policy. If you do not agree with this policy, please do not access our website or provide us with any personal information.