Last Updated and Effective: May 2025
This Privacy Policy & California Privacy Notice (“Privacy Policy”) sets forth the privacy practices of Square Nine Capital LLC (“Square Nine,” “we,” “our,” or “us”) regarding the collection, use, sharing, and disclosure of personal information, including but not limited to information that may be collected through this website (the “Site”). This Privacy Policy explains how we use personal data and under what circumstances we may share it. Your access and use of the Site constitutes your agreement to this Privacy Policy, as permitted by applicable law.
1. Personal Information We Collect
When you interact with our Site or engage with Square Nine during the normal course of business, we may collect nonpublic personal information (“Personal Information”) that allows us to manage relationships and fulfill our business and regulatory obligations.
This information may include identifiers such as your name, address, phone number, email, date of birth, nationality, signature, tax ID, passport number, financial account details, investment activity, and related personal and financial data.
We may also collect background or due diligence information—including credit, legal, or regulatory history—as required by applicable laws including anti-money laundering and financial compliance.
2. Sources of Personal Information
We may collect Personal Information from:
- Direct communications and interactions with you
- Your transactions with Square Nine
- Authorized third-party service providers
- Our affiliates
- Government entities and regulators
- Public records, databases, and social media
3. How We Use Personal Information
We use Personal Information for purposes including:
- Providing investment products and services
- Administering client or investor relationships
- Processing inquiries, transactions, and onboarding
- Performing operational functions and account maintenance
- Verifying identity and conducting compliance checks
- Communicating with clients, partners, and prospects
- Maintaining and improving the Site’s security and usability
- Meeting regulatory, legal, and audit obligations
4. How We Share Personal Information
Square Nine does not sell Personal Information. We may share Personal Information only with non-affiliated third parties necessary to service an account, as required by law, or to support business functions such as fund administration, legal counsel, or auditing.
5. How We Protect Personal Information
We implement commercially reasonable safeguards to protect Personal Information from unauthorized access, use, or disclosure. Access is limited to employees or service providers who require the information for legitimate business purposes.
6. Notice for Residents of the European Economic Area and United Kingdom
Residents of the EEA and UK have rights under GDPR, including:
- Accessing and rectifying your data
- Requesting deletion (“right to be forgotten”)
- Objecting to or restricting processing
- Data portability where applicable
- Withdrawing consent
- Filing complaints with the appropriate data protection authority
Due to the global nature of our business, your data may be transferred internationally. We take steps to ensure appropriate safeguards are in place, such as through Standard Contractual Clauses or equivalent mechanisms.
7. Contact Us
For questions about this Privacy Policy, email us at: [email protected]
Privacy Notice for California Consumers
Last Updated: May 2025
This section applies only to California residents under the California Consumer Privacy Act (as amended by the CPRA). It outlines Square Nine’s practices regarding the collection, use, and disclosure of Personal Information over the past 12 months.
Categories of Personal Information We Collect:
- Identifiers (name, alias, address, SSN, passport, etc.)
- Customer Records (employment history, financial details, etc.)
- Protected Class Information (age, citizenship, etc.)
Sources:
- Communications with you
- Observed website activity
- Service providers
- Affiliates
- Government/public data sources
We do not knowingly sell or share Personal Information of individuals under 18 years of age.
Purposes for Collection and Use Include:
- Providing information, updates, and services
- Managing transactions, accounts, and inquiries
- Regulatory and compliance requirements
- Employment-related purposes (applicants, employees, contractors)
- Detecting and preventing fraud or security incidents
Disclosure of Personal Information:
We may disclose information to:
- Service providers and vendors
- Affiliates and business partners
- Legal or regulatory bodies
- In the event of a business transfer
- As authorized by you
We do not sell or share personal information for cross-context behavioral advertising.
Data Retention:
We retain Personal Information only as long as necessary to fulfill legal and business purposes.
Your Rights Under the CPRA
You may have the following rights, subject to verification and applicable exceptions:
- Request access to specific personal data we hold about you
- Request deletion of your Personal Information
- Request correction of inaccurate data
- Opt out of data sale or sharing (if ever applicable)
- Limit use of sensitive personal information
- Protection against discrimination for exercising your privacy rights
To make a verifiable request or to exercise your rights, contact us at: [email protected]. We may require identification verification and reserve the right to deny requests we cannot verify.