Privacy Policy

1. Introduction

Sightline Capital LLC ("Company," "we," "us," or "our") is committed to protecting the privacy and security of your personal information. This Privacy Policy describes how we collect, use, disclose, and safeguard information when you access the Sightline Portal (the "Portal").

By using the Portal, you consent to the data practices described in this policy. If you do not agree with the terms of this Privacy Policy, please do not access the Portal.

2. Information We Collect

2.1 Personal Information

We collect personal information that you provide directly, including:

• Email address (used for authentication and communications)
• Name and contact information (provided during account setup)
• Investment account details and transaction history
• Tax identification information as required by law

2.2 Automatically Collected Information

When you access the Portal, we automatically collect:

• Device information (browser type, operating system)
• IP address and approximate geographic location
• Access timestamps and session duration
• Pages viewed and features accessed

3. How We Use Your Information

We use the collected information for:

• Authenticating your identity and managing Portal access
• Providing personalized investment information and portfolio data
• Processing and tracking distributions and transactions
• Communicating important account updates and regulatory notices
• Maintaining security and detecting fraudulent activity
• Complying with legal and regulatory requirements
• Improving Portal functionality and user experience

4. Information Sharing and Disclosure

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

• Service Providers: Third-party vendors who assist in Portal operations (hosting, email delivery) under strict confidentiality agreements
• Legal Compliance: When required by law, court order, or regulatory authority
• Business Transfers: In connection with a merger, acquisition, or sale of assets
• Protection of Rights: To protect the rights, property, or safety of the Company, investors, or others

5. Data Security

We implement industry-standard security measures to protect your information:

• TLS 1.3 encryption for all data in transit
• AES-256 encryption for data at rest
• Passwordless authentication via secure one-time codes
• Session management with automatic expiration
• Regular security assessments and monitoring
• Access controls limiting employee access to personal data

While we strive to protect your personal information, no method of transmission over the Internet or electronic storage is 100% secure. We cannot guarantee absolute security.

6. Data Retention

We retain personal information for as long as necessary to provide services and comply with legal obligations:

• Account information: Duration of investor relationship plus 7 years
• Transaction records: 7 years for regulatory compliance
• Access logs and audit trails: 7 years
• Authentication records: 90 days after session expiration

7. Your Rights

Subject to applicable law, you have the right to:

• Access the personal information we hold about you
• Request correction of inaccurate information
• Request deletion of your information (subject to retention requirements)
• Object to processing of your information
• Request data portability where technically feasible
• Withdraw consent for optional data processing

To exercise these rights, please contact us using the information below.

8. Cookies and Tracking

The Portal uses essential cookies required for authentication and security. We do not use third-party advertising or analytics cookies. Essential cookies include:

• Session authentication tokens
• Security and fraud prevention identifiers
• User preference settings

9. Children's Privacy

The Portal is not intended for individuals under 18 years of age. We do not knowingly collect personal information from minors. If we learn that we have collected information from a person under 18, we will delete that information promptly.

10. Changes to This Policy

We may update this Privacy Policy periodically to reflect changes in our practices or legal requirements. We will notify you of material changes by posting the updated policy on the Portal and updating the "Last Updated" date. Your continued use of the Portal after such changes constitutes acceptance of the updated policy.

11. Contact Us

If you have questions about this Privacy Policy or our data practices, please contact: