Privacy Policy

1. Scope and Eligibility

This Privacy Policy is intended for users located in the United States. We do not market to or knowingly collect personal information from individuals outside the United States. We do not knowingly collect personal information from children under 16. If we learn we have collected personal information from a child under 16, we will delete it.

2. Information We Collect

(a) Information You Provide. We collect information you submit to us, including through forms, email, chat or voice widgets (including our Elevista Connect product), phone calls, or subscription documents. This may include:

• name, email address, phone number, mailing address;
• accredited investor status, financial information, and verification documents required under Rule 506(c);
• inquiry content, messages, and chat or voice transcripts;
• credentials and account information for any investor portal;
• any other information you choose to provide.

(b) Information Collected Automatically. When you use the Site, we and our service providers may automatically collect:

• device and browser information (IP address, browser type, operating system, device identifiers);
• usage information (pages visited, time spent, referring URL, clickstream data);
• cookies, pixels, web beacons, and similar technologies (described in Section 6).

(c) Information from Third Parties. We may receive information from accreditation verification providers, identity verification providers, financial institutions, your representatives, and publicly available sources, in each case in connection with evaluating your eligibility for or administering your investment.

(d) Chat and Voice Widgets. Our chat and voice widgets, including Elevista Connect, may collect, process, and store the content of your interactions. Voice interactions may be recorded and processed by automated AI systems. At the point of interaction, we disclose that you are interacting with an AI agent and, where applicable, that the interaction is being recorded. Where additional notice or consent is required by applicable law, we provide it at the point of interaction.

3. How We Use Information

We use personal information to:

• respond to inquiries and communicate with you;
• evaluate your eligibility as an accredited investor and administer subscription processes;
• operate, administer, and report on your investment in any Affiliate Fund;
• send marketing communications by email, where you have provided permission, in compliance with the CAN-SPAM Act;
• if and when we use SMS or text marketing in the future, in compliance with the Telephone Consumer Protection Act (TCPA), including obtaining required consent;
• improve and secure the Site, our products, and our services;
• comply with legal, regulatory, tax, and audit obligations; and
• detect, prevent, and respond to fraud, security incidents, and unlawful activity.

4. How We Share Information

We do not sell personal information. We share personal information only as follows:

• Service providers that help us operate the Site and our business, including Airtable (CRM and database), Resend (transactional and marketing email), Google Analytics 4 (analytics), our hosting provider, accreditation verification providers, identity verification providers, document and data-room providers, our future investor portal vendor, professional advisors (legal, tax, audit), and similar vendors;
• Affiliate Funds and their administrators to administer your investment;
• Advertising and analytics partners if and when we activate cross-site advertising tools (such as the Meta Pixel). See Section 6;
• Legal and regulatory recipients, including in response to subpoenas, court orders, regulatory inquiries, or to protect our rights, property, or safety, or those of others; and
• In connection with a corporate transaction, such as a merger, financing, reorganization, or sale of assets.

We require service providers to use personal information only for the services they provide to us and to maintain reasonable security measures.

5. Data Sharing for Cross-Context Behavioral Advertising

We do not currently use cross-site advertising tools that “sell” or “share” personal information for cross-context behavioral advertising as those terms are defined under California law. In the future, we may activate the Meta Pixel and similar advertising and retargeting tools. When and if we do, we will update this Policy and provide opt-out mechanisms as required by applicable law. We honor browser-based opt-out signals, including the Global Privacy Control (GPC), as a request to opt out of any sharing for cross-context behavioral advertising.

6. Cookies, Pixels, and Similar Technologies

We and our service providers use cookies, pixels, web beacons, local storage, and similar technologies to operate the Site, remember preferences, measure performance, and analyze usage. We currently use Google Analytics 4 for analytics. We may add additional analytics, advertising, or session-replay tools in the future, including the Meta Pixel.

We use Cookiebot to manage cookie consent and preferences on the Site. Through the Cookiebot consent banner, you can accept, reject, or customize the categories of cookies and similar technologies used on the Site. You may change your preferences at any time by accessing the Cookiebot preferences link on the Site. You can also control cookies through your browser settings, including refusing new cookies, deleting existing cookies, or being notified when cookies are set. If you disable cookies, parts of the Site may not function properly. You can opt out of Google Analytics by installing the Google Analytics Opt-out Browser Add-on. Where applicable, we honor the Global Privacy Control (GPC).

7. Email Marketing

We send marketing emails only to recipients who have provided permission to receive them, consistent with the CAN-SPAM Act. Every marketing email includes an unsubscribe link. You may opt out of marketing emails at any time by clicking the unsubscribe link or by contacting us at hello@clarkst.com. Opting out of marketing does not stop transactional or relationship communications, such as investor reporting, K-1 delivery, or responses to your inquiries.

8. SMS and Text Communications

We do not currently send SMS or text marketing communications. If we begin doing so in the future, we will obtain prior express consent as required by the Telephone Consumer Protection Act (TCPA) and applicable rules, and we will provide opt-out instructions in each message.

9. Data Retention

We retain personal information for as long as necessary to fulfill the purposes described in this Policy. Our default retention practices are:

• Investor and subscription records: for the duration of your investment relationship with Clark St Capital and any Affiliate Fund, plus seven (7) years thereafter, to satisfy tax, audit, securities, and regulatory recordkeeping requirements;
• Prospect and inquiry data: until you opt out, plus two (2) years thereafter for relationship and pipeline purposes, unless a longer period is required by law;
• Marketing email data: until you unsubscribe, plus a reasonable period thereafter to honor your opt-out and prevent re-solicitation;
• Website analytics and log data: for the retention period of the applicable analytics tool (Google Analytics 4 default retention applies unless we configure otherwise);
• Chat and voice transcripts: for up to two (2) years from the interaction, unless retained longer for legal, security, or service-improvement purposes.

We may retain information longer where required by law, regulation, or legitimate business purposes (such as defending legal claims).

10. Data Security

We maintain reasonable administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, use, disclosure, alteration, and destruction. No method of transmission over the internet or method of electronic storage is 100% secure, and we cannot guarantee absolute security. You are responsible for safeguarding any credentials issued to you and for the security of devices you use to access the Site.

11. Your Privacy Rights

(a) All U.S. Users. Regardless of your state, you may:

• request access to or a copy of personal information we hold about you;
• request correction of inaccurate personal information;
• request deletion of personal information, subject to legal and regulatory recordkeeping requirements;
• opt out of marketing emails at any time;
• contact us with privacy questions or complaints.

(b) State-Specific Rights. Depending on your state of residence, you may have additional rights under state privacy laws, including the right to:

• know what categories of personal information we collect, use, and share;
• opt out of the “sale” or “sharing” of personal information (we do not sell, and we do not currently share for cross-context behavioral advertising. See Sections 4 and 5);
• limit the use of sensitive personal information (we do not use sensitive personal information for purposes that require an opt-out under California law);
• portability of your personal information;
• non-discrimination for exercising these rights;
• appeal a denial of your privacy request.

States currently providing comprehensive privacy rights to residents include California, Colorado, Connecticut, Virginia, Utah, Texas, Oregon, Montana, Delaware, New Hampshire, New Jersey, Iowa, Tennessee, Indiana, Kentucky, Maryland, Minnesota, and Rhode Island, among others. The specific scope of your rights depends on the law of your state of residence.

(c) How to Exercise Your Rights. Submit requests to hello@clarkst.com with the subject line “Privacy Request.” We will verify your identity before processing your request and respond within the time required by applicable law (generally 45 days, with one extension permitted where allowed). You may designate an authorized agent to make a request on your behalf, subject to verification.

(d) Global Privacy Control. We honor browser-based opt-out signals, including the Global Privacy Control (GPC), as a request to opt out of any sale or sharing of personal information for cross-context behavioral advertising.

12. Third-Party Sites and Services

The Site may link to or integrate with third-party websites, tools, or services. Those third parties operate independently of Clark St Capital, and we are not responsible for their privacy practices. Review the privacy policies of any third-party services you use.

13. Changes to This Policy

We may update this Policy from time to time. The “Effective Date” at the top of this Policy reflects the most recent update. Material changes will be communicated through the Site or, for credentialed users, through the investor portal or via the contact information you have provided. Your continued use of the Site after the effective date of any update constitutes acceptance of the updated Policy.

14. Contact Us

For questions, requests, or complaints about this Privacy Policy or our privacy practices, contact: