Privacy Policy
DiNapoli Capital Partners
Effective Date: May 28, 2026
Introduction
DiNapoli Capital Partners ("Company," "we," "us," or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website and interact with us.
Please read this Privacy Policy carefully. If you do not agree with our policies and practices, please do not use our website.
1. Information We Collect
We may collect information about you in a variety of ways. The information we may collect on the website includes:
Personal Information You Provide:
Name
Email address
Phone number
Company name and title
Address
Any other information you voluntarily provide through contact forms or inquiries
Information Collected Automatically:
IP address
Browser type and version
Operating system
Pages visited and time spent on site
Referral source
Device information
2. How We Use Your Information
We use the information we collect to:
Respond to your inquiries and requests
Send communications regarding business opportunities and investment information
Improve our website and user experience
Comply with legal obligations
Prevent fraud and maintain security
Analyze website traffic and usage patterns
Legal Basis for Processing (GDPR)
For users in the European Union, we process personal information based on the following legal grounds:
Consent: When you voluntarily provide information through contact forms or inquiries
Legitimate Interest: To improve our services, prevent fraud, and conduct business operations
Contract: To fulfill obligations related to investment opportunities or business relationships
Legal Obligation: When required by applicable law
3. Disclosure of Your Information
We do not sell, trade, or rent your personal information to third parties. However, we may share information with:
Service providers who assist us in operating our website and conducting our business (subject to confidentiality agreements)
Legal authorities when required by law
Professional advisors (attorneys, accountants, consultants)
4. Data Security
We implement appropriate technical and organizational measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. However, no method of transmission over the internet or electronic storage is completely secure. While we strive to use commercially acceptable means to protect your information, we cannot guarantee absolute security.
5. Cookies and Tracking Technologies
Our website uses cookies and similar tracking technologies to enhance your experience. Cookies are small files stored on your device that help us:
Remember your preferences
Understand how you use our site
Improve site functionality
Analyze traffic patterns
You can control cookie settings through your browser. Please note that disabling cookies may affect site functionality.
6. Third-Party Links
Our website may contain links to third-party websites. We are not responsible for the privacy practices of these external sites. We encourage you to review their privacy policies before providing any information.
7. Data Retention
We retain your personal information for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable law. When information is no longer needed, we will securely delete or anonymize it.
8. Your Rights
Depending on your location, you may have certain rights regarding your personal information, including:
GDPR Rights (European Users)
If you are located in the European Union, you have the following rights:
Right of Access: Request a copy of the personal data we hold about you
Right to Rectification: Request correction of inaccurate or incomplete data
Right to Erasure ("Right to be Forgotten"): Request deletion of your personal data, subject to legal exceptions
Right to Restrict Processing: Request that we limit how we use your data
Right to Data Portability: Receive your data in a structured, commonly used, machine-readable format
Right to Object: Object to processing of your data for certain purposes
Right to Lodge a Complaint: File a complaint with your local data protection authority
California Consumer Rights (CCPA)
If you are a California resident, you have the following rights:
Right to Know: Request what personal information we collect, use, share, and sell
Right to Delete: Request deletion of personal information we have collected from you (subject to certain exceptions)
Right to Opt-Out: Direct us not to sell or share your personal information
Right to Non-Discrimination: We will not discriminate against you for exercising your CCPA rights
Right to Correct: Request correction of inaccurate personal information
How to Exercise Your Rights
To exercise any of these rights, please contact us using the information in Section 10 below. We will respond to your request within 30 days (or as required by applicable law). You may also designate an authorized agent to submit requests on your behalf.
Please note that we may need to verify your identity before fulfilling your request.
9. CCPA Data Categories
For California residents, the following are the categories of personal information we collect and the purposes for which we use them:
Category
Examples
Purpose
Identifiers
Name, email, phone, address
Business communications, inquiries
Commercial Information
Transaction history, investment details
Business operations
Internet Activity
IP address, browsing history, cookies
Website analytics, security
Geolocation Data
Inferred location from IP
Service improvement
Inferences
Preferences, investment interests
Targeted communications
CCPA Note: We do not currently "sell" personal information as defined under the CCPA. If this changes, we will provide notice and allow you to opt-out.
10. International Data Transfers (GDPR)
If you are located in the European Union, please be aware that your personal information may be transferred to, stored in, and processed in the United States. The United States may not have the same level of data protection as the EU. By providing your information, you consent to such transfer. We will implement appropriate safeguards, such as Standard Contractual Clauses, to protect your data during international transfers.
11. Data Processing Agreement
For business partners and investors subject to GDPR, we can provide a Data Processing Agreement (DPA) upon request. Please contact us for more information.
12. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. We will notify you of any significant changes by posting the updated policy on our website with an updated effective date. Your continued use of the website constitutes your acceptance of the updated Privacy Policy.
13. Contact Us
If you have questions about this Privacy Policy, or if you wish to exercise your data rights, please contact us at:
DiNapoli Capital Partners
information@dinapolicapital.com
(408) 971-1680
3021 Citrus Circle, Suite 130, Walnut Creek, CA 94598