Privacy Policy

Last Updated: December 28, 2025

1. Introduction

Sooch Capital ("Sooch Capital," "we," "our," or "us") respects your privacy and is committed to protecting the personal information of individuals who access or use our website, digital platforms, investor portals, and related services (collectively, the "Services").

This Privacy Policy explains how we collect, use, disclose, and safeguard information when you visit our website or engage with Sooch Capital in connection with real estate investments, capital raising activities, investor communications, and related business operations.

By accessing or using our Services, you acknowledge that you have read, understood, and agree to the practices described in this Privacy Policy.

2. Scope of This Privacy Policy

This Privacy Policy applies to:

  • Visitors to our website
  • Prospective investors
  • Accredited and non-accredited investors (where permitted by law)
  • Business partners and service providers
  • Individuals who communicate with us electronically or otherwise

This Privacy Policy does not apply to information collected offline or through third-party websites not controlled by Sooch Capital.

3. Information We Collect

3.1 Personal Information You Provide

We may collect personal information that you voluntarily provide, including but not limited to:

  • Full name
  • Email address
  • Phone number
  • Mailing address
  • Date of birth
  • Government-issued identification (as required for compliance)
  • Financial information (e.g., income ranges, net worth representations, investment history)
  • Accreditation status and supporting documentation
  • Any information submitted through forms, investor questionnaires, or communications

3.2 Automatically Collected Information

When you access our Services, we may automatically collect:

  • IP address
  • Browser type and version
  • Device identifiers
  • Operating system
  • Pages visited and time spent
  • Referring URLs
  • Cookies and similar tracking technologies

4. How We Use Your Information

We use collected information for legitimate business purposes, including to:

  • Evaluate investor eligibility and suitability
  • Comply with securities laws and regulatory requirements
  • Provide access to investor materials and portals
  • Communicate regarding offerings, updates, and disclosures
  • Conduct due diligence, KYC, and AML checks
  • Improve website functionality and user experience
  • Maintain internal records and audit trails
  • Protect against fraud, unauthorized access, and legal claims

5. Legal Bases for Processing (Where Applicable)

Where required by law, Sooch Capital processes personal information based on:

  • Your consent
  • Performance of a contract or pre-contractual obligations
  • Compliance with legal and regulatory obligations
  • Legitimate business interests that do not override individual rights

6. Disclosure of Information

We may share personal information with:

  • Legal, accounting, and compliance advisors
  • Third-party service providers (e.g., hosting, CRM, investor platforms)
  • Financial institutions and payment processors
  • Government or regulatory authorities when legally required
  • Successors in the event of a merger, acquisition, or asset sale

We do not sell personal information.

7. Cookies and Tracking Technologies

We may use cookies, web beacons, and similar technologies to:

  • Analyze traffic and usage patterns
  • Remember user preferences
  • Improve site functionality

You may disable cookies through your browser settings, though some features may not function properly.

8. Data Security

We implement reasonable administrative, technical, and physical safeguards designed to protect personal information. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.

9. Data Retention

We retain personal information for as long as necessary to:

  • Fulfill the purposes outlined in this Privacy Policy
  • Comply with legal, regulatory, and tax obligations
  • Resolve disputes and enforce agreements

10. Your Rights and Choices

Depending on your jurisdiction, you may have the right to:

  • Request access to your personal information
  • Request correction or deletion
  • Object to or restrict processing
  • Withdraw consent

Requests may be subject to legal limitations and verification requirements.

11. New York Residents

If Sooch Capital is incorporated or operates in New York State, we comply with applicable New York privacy and data security laws, including reasonable safeguards for private information under the SHIELD Act.

12. Children's Privacy

Our Services are not directed to individuals under the age of 18. We do not knowingly collect personal information from minors.

13. International Users

If you access our Services from outside the United States, you acknowledge that your information may be transferred to and processed in the United States, where data protection laws may differ.

14. Changes to This Privacy Policy

We reserve the right to modify this Privacy Policy at any time. Updates will be posted with a revised "Last Updated" date. Continued use of the Services constitutes acceptance of the updated policy.

15. Contact Information

For questions or requests related to this Privacy Policy, please contact:

Sooch Capital

Email: privacy@soochcapital.com

New York, NY, United States