Privacy Policy

EB5 Circle is an education and project-discovery website about the U.S. EB-5 immigrant investor program. This policy explains what personal information the website collects, why, how it is stored and shared, and the choices available to you. In this policy, "we", "us" and "our" mean EB5 Circle, and "you" means a visitor to the website.

This policy applies to the website only. If you are connected with an immigration attorney, securities professional or other service provider, that person or firm handles your information under their own privacy terms, which you should review with them directly.

The website has two forms that collect personal information: the consultation request form on the contact page, and the project inquiry form on individual project pages. Both are optional. You can read the entire website without submitting anything.

Like any website, ours receives some technical information when your browser connects to it. We keep this to the minimum needed to operate and protect the site.

IP address

When you submit a form, our server uses your IP address briefly to limit repeated submissions and prevent spam. This check happens in the server's memory. Your IP address, and any hashed (scrambled) version of it, is not stored with your inquiry.

Server logs

Our hosting infrastructure may record standard request data, such as the time of a request, the page requested, the browser type and the IP address, for security and troubleshooting.

Cookies

The only cookie the website uses is a strictly necessary session cookie for the administrator area, which is used by authorised staff to sign in. It is not set for public visitors.

Analytics and advertising

We do not use analytics tools, advertising cookies or tracking pixels, and we do not build advertising profiles of visitors.

We use the information you submit for the purposes you would expect from an inquiry form, and for no others:

• To read and respond to your consultation request or project inquiry, using your preferred contact method.
• To follow up on your inquiry, for example to schedule a call in the time window you indicated.
• To pass your inquiry to the sponsor-supplied contact for a project, or to a qualified professional, only where you have asked to be connected (see the next section).
• To keep the website secure and to prevent spam, abuse and repeated automated submissions.
• To meet any legal obligations that apply to us.

We do not sell your personal information, and we do not use it for third-party advertising. Where the law requires a legal basis for processing, we generally rely on your consent (which you give when submitting a form), on steps taken at your request before any engagement, and on our legitimate interest in operating a secure website.

• Storage. Inquiries are stored on the website's server.
• Internal access. Inquiries are viewed only by authorised EB5 Circle staff who need them to respond to you.
• Service providers. An inquiry may be forwarded to a customer relationship management (CRM) or workflow automation service operated on EB5 Circle's behalf, so that we can track and respond to it. These providers process information on our instructions.
• Qualified professionals, at your request. If you ask to be connected, we may share your inquiry with a qualified professional, such as a U.S. immigration attorney or a licensed securities professional, so they can arrange a consultation with you. We do this only if you asked to be connected.
• Legal reasons. We may disclose information where required by law, or where reasonably necessary to protect the rights, safety or security of our visitors, staff or website.

We do not share your information with anyone else without your permission.

We keep inquiries only for as long as needed to respond to you and follow up. Authorised administrators can delete inquiry records at any time. We aim to review and delete inquiries that have not progressed within 24 months of the last contact. We may keep information for longer only where the law requires it.

Information held by a professional you were connected with is governed by that professional's own retention practices.

Depending on where you live, you may have some or all of the following rights over your personal information:

• Access: ask what information we hold about you and receive a copy.
• Correction: ask us to correct information that is inaccurate or incomplete.
• Deletion: ask us to delete your information.
• Objection: object to, or ask us to restrict, how we use your information.
• Withdrawal of consent: withdraw the consent you gave when submitting a form. Withdrawal does not affect anything we did before you withdrew.

Privacy rights vary by jurisdiction. For example, residents of the European Union and the United Kingdom have rights under the General Data Protection Regulation (GDPR) and its UK equivalent, individuals in India have rights under the Digital Personal Data Protection Act, 2023, and residents of some U.S. states have rights under state privacy laws. We will respond to requests in line with the law that applies to you. You may also have the right to complain to a data protection authority in your country.

To make a request, please contact us through the contact page and say that your message concerns privacy. We may need to confirm your identity before acting on a request.

Our visitors live in many countries. Information you submit may be processed and stored in the United States, and by service providers in other countries, where data protection laws may differ from those where you live. By submitting a form, you understand that your information may be transferred in this way. We take reasonable steps to protect it wherever it is processed.

We use reasonable technical and organisational measures to protect the information you submit, including restricting access to authorised staff. No website or method of transmission is completely secure, however, and we cannot guarantee absolute security. This is one reason we ask you not to send sensitive documents through the forms.

The website's forms are not directed at children under 16, and we do not knowingly collect personal information from them. EB-5 planning often involves a whole family, so a parent or guardian is welcome to submit an inquiry on behalf of the family, including information about children's general circumstances where relevant. If you believe a child under 16 has submitted information to us, please contact us and we will delete it.

We may update this policy from time to time, for example if the website's forms or service providers change. The "last updated" date at the top of this page shows when it was last revised. Significant changes will be reflected on this page before they take effect.

Questions about this policy can be sent through the contact page. For related information, see our Terms of Use and Disclosures.