Privacy Policy

1. Who We Are

Cardinal Mark Investments LLC ("Cardinal Mark," "we," "us," or "our") is a California limited liability company engaged in real estate investment advisory services. This Privacy Policy describes how we collect, use, disclose, and safeguard personal information obtained through our website at cardinalmarkinvestments.com (the "Site") and through direct communications with prospective and current investors and partners.

This Site is directed to sophisticated investors and real estate professionals. If you require this Policy in Japanese, please contact us and we will make reasonable efforts to provide a translated summary upon request.

2. Information We Collect

We may collect the following categories of personal information:

• Contact and Identity Information: Name, email address, telephone number, company name, title, and country of residence, when provided through our contact form or direct communications.
• Investor Inquiry Data: Investment interests, target returns, capital availability, and other information voluntarily disclosed in connection with an investment inquiry.
• Usage Data: IP address, browser type, device type, pages visited, time spent, and referring URLs, collected automatically via our hosting infrastructure.
• Communications: Records of email, phone, and written correspondence with us.

We do not collect payment card data, Social Security numbers, passport numbers, or other government-issued identification through this Site.

3. How We Use Your Information

• To respond to investor inquiries and evaluate potential investment relationships;
• To communicate information about current and future investment opportunities, subject to applicable securities laws and your status as an accredited investor or qualified purchaser, where applicable;
• To operate, maintain, and improve the Site;
• To comply with applicable legal and regulatory obligations;
• To detect, prevent, and address fraud and security issues;
• For internal analytics and business development.

We do not sell your personal information to third parties.

4. How We Share Your Information

• Joint Venture Partners: Cardinal Mark Investments is a joint venture between VMG Properties LLC and Capital Brain Co., Ltd. (株式会社キャピタル・ブレイン). Information relating to investment inquiries may be shared between joint venture partners for purposes of evaluating and fulfilling investor relationships, subject to applicable confidentiality obligations.
• Service Providers: Third-party vendors who support our operations, including Vercel, Inc. (website hosting). These parties are contractually restricted from using your information for independent purposes.
• Legal and Regulatory Requirements: When required by law, court order, regulatory authority, or government agency in the United States or Japan, or as necessary to protect our legal rights.
• With Your Consent: For any other purpose with your explicit prior consent.

5. International Data Transfers

Cardinal Mark Investments operates in the United States and maintains a strategic partnership with Capital Brain Co., Ltd., headquartered in Tokyo, Japan. If you provide personal information from Japan or another country, your data may be transferred to, stored, and processed in the United States, where privacy laws may differ from those of your jurisdiction. By engaging with this Site or contacting us via email or other means, you expressly acknowledge and consent to this international transfer for the purposes described in this Policy.

We are aware of Japan's Act on the Protection of Personal Information (APPI), as amended. To the extent our activities bring us within scope of APPI, we will handle personal information of Japanese nationals with the care and protections consistent with APPI requirements, including limiting use to disclosed purposes, implementing security measures, and honoring requests for disclosure, correction, and deletion.

6. California Privacy Rights (CCPA / CPRA)

While Cardinal Mark Investments may not meet the statutory thresholds for mandatory CCPA/CPRA compliance, we voluntarily extend the following rights to California residents as a matter of best practice: (i) the right to know what personal information we have collected and how it is used and shared; (ii) the right to request deletion of their personal information, subject to legal exceptions; (iii) the right to request correction of inaccurate personal information; (iv) the right to opt out of the sale or sharing of personal information (we do not sell personal information); and (v) the right to non-discrimination for exercising these rights.

To exercise any of these rights, contact us at investor@vmgproperties.com. We will verify your identity and respond within 45 days as required by law.

7. Data Security and Retention

We implement reasonable administrative, technical, and physical safeguards to protect your personal information against unauthorized access, disclosure, alteration, and destruction. No electronic transmission or storage is completely secure; we cannot guarantee absolute security. We retain personal information for as long as necessary to fulfill the purposes described herein, comply with legal obligations, and support potential investor relationships.

8. Children's Privacy

This Site is not directed to individuals under the age of 18. We do not knowingly collect personal information from minors. Contact us immediately if you believe a minor has provided personal information to us.

9. Changes to This Policy

We reserve the right to update this Privacy Policy at any time. Material changes will be reflected in the "Last Updated" date above. Your continued use of the Site following any update constitutes acceptance of the revised Policy.

10. Contact