Effective date: October 1, 2026. Version 2.0.
This notice explains what personal information Laguna Point collects, why we collect it, who we share it with, how long we keep it, and what rights and choices you have. It covers our website and the information we handle about our investors, their representatives and others who deal with us. Investor meetings, webinars and recordings are covered by our Investor Event Terms, Confidentiality, and Privacy Notice.
Who we are
In this notice, “Laguna Point,” “we,” “us,” and “our” mean Laguna Point Management, LLC and Stone Coast Management, LLC, the investment entities they manage, and their affiliates, operating under the trade name “Laguna Point Properties.” We are a private real estate investment manager. Our investors are existing members of the private LLCs we manage, not the general public, so most of the information we hold comes out of that relationship.
What this notice covers and which document controls
This notice applies to personal information we collect online and offline: on our website, through our investor document sites and investor portal, by email, mail and phone, and in signed documents. It does not describe the practices of other companies that our website links to, which have their own notices.
Three documents can apply to you, and they work together:
- Your subscription agreement, operating agreement and other investor agreements control investor matters, including the confidentiality of investor information, to the extent they address the same subject as this notice.
- The Investor Event Terms, Confidentiality, and Privacy Notice controls investor events and their recordings.
- This notice covers everything else, and describes how we handle personal information where those documents say nothing on the point.
If two of these documents conflict, the one higher on the list controls for that subject.
Information we collect
Categories of information
Depending on how you deal with us, we collect these categories of personal information:
- Identifiers, such as your name, the name of any entity you invest through, and documents or details we ask for to confirm who you are.
- Contact information, such as postal and email addresses and phone numbers, for you and for any representative or adviser you ask us to deal with.
- Financial and tax information, such as your Social Security number or taxpayer identification number, your tax status and tax forms, and the bank and wire details we use to send and receive funds.
- Investment and ownership records, such as the entities you invest through, ownership percentages, investment amounts and elections, contributions, distributions and transfers.
- Signatures, both handwritten and electronic, and records of when and how documents were signed.
- Account and sign-in data, such as the email address we use to invite you to our investor document sites, one-time sign-in codes, and records of sign-in activity.
- Communications, such as emails and messages between you and us, including your questions and our replies.
- Device and technical data, such as IP address, browser type and the pages requested from our website.
Where it comes from
We collect personal information from these sources:
- You, through forms, signed documents, emails, calls and our websites.
- Your representatives and advisers, such as an attorney, accountant or financial advisor who acts for you.
- Custodians and IRA administrators, when you invest through a retirement account.
- Our service providers, such as our investor portal provider and the banks that confirm a wire arrived.
- Public records, such as business-entity filings and court records.
Sensitive personal information
Some of what we hold is sensitive, including Social Security and taxpayer identification numbers and financial account and wire details. We use sensitive personal information only to administer your investment, report taxes, verify identity, prevent fraud and meet our legal and compliance obligations. We do not use it to infer characteristics about you, and we do not use it for marketing or profiling.
Investor document sites and sign-in
We share investor documents on secure sites in our Microsoft 365 environment. To give you access, we invite you as a guest using your email address. Microsoft processes that email address and your sign-in activity, and it may send you a one-time sign-in code. Microsoft’s own privacy statement describes how it handles that information, including any cookies it sets to keep you signed in.
Communications
Emails to and from investors@laguna-point.com are logged to your record in our investor portal, so our team can see the full history of your correspondence with us.
Electronic signatures
When you sign a document through DocuSign, we receive your signature and the signed document, and DocuSign records details about the signing, such as when it happened. DocuSign handles that information under its own terms as well.
How we use information
We use personal information to:
- administer your investment, including capital calls, distributions and investor reports;
- prepare and deliver tax forms such as Schedule K-1 and meet our other tax reporting obligations;
- verify identity and meet anti-money-laundering, sanctions and other know-your-customer requirements;
- keep the records the law requires us to keep;
- communicate with you, answer your questions and send you information about your investment;
- run, secure and maintain our websites, investor sites and systems, and detect and prevent fraud, unauthorized access and other misuse;
- protect our rights, property and safety, and those of our investors and others, including establishing, exercising or defending legal claims; and
- send our newsletter, if you subscribe to it.
We do not use your personal information for a purpose that is unrelated to these without telling you first and, where the law requires it, getting your consent.
How we share information
We share personal information only in the ways described here.
Service providers
These companies process information for us under confidentiality obligations, and may use it only to provide their services to us:
- Microsoft, for Microsoft 365, SharePoint, Teams and its sign-in service;
- RealPage IMS, our investor portal provider;
- DocuSign, for electronic signatures;
- banks and payment processors, for moving money; and
- our website host and email provider.
Professional advisers
We share information with our accountants, tax preparers, fund administrators and legal advisors, who are bound by professional or contractual duties of confidentiality, when they need it to advise us or to do work for us.
Financings, sales and audits
A lender, buyer, auditor or similar party may need information about the entities and owners involved in a financing, refinancing, sale or audit. We share it with them under confidentiality, and only what the transaction calls for.
Government and courts
We disclose information to tax authorities, regulators, courts and law enforcement when the law or legal process requires it, and when we believe disclosure is needed to protect our rights or the safety of others.
Business transfers
If we are involved in a merger, acquisition, reorganization or sale of assets, personal information may be transferred as part of that transaction. We will tell you if the new owner’s handling of your information would differ materially from this notice.
With your consent
We share information with anyone else when you ask us to or agree to it, for example with a representative you name.
No sale, no advertising
We do not sell personal information. We do not share it for cross-context behavioral advertising, and we do not use it for third-party advertising.
Financial privacy
Information about your investment, including your identity, the amount you invested, and your financial and tax details, is nonpublic personal information, and we treat it that way. We do not share nonpublic personal information about current or former investors with nonaffiliated third parties except as the law permits. That means sharing to service your account (for example, with our administrators, portal provider and banks), sharing with your consent or at your direction, and sharing as required by law, such as with tax authorities and regulators or in response to legal process.
We share this information with our affiliates, meaning the investment entities we manage and companies under common control with us, as needed to administer your investment. Because we share information only in these ways, there is nothing for you to opt out of. If that ever changes, we will give you notice and any choice the law requires before we act.
Our website, cookies and tracking
Our website has a contact form and a newsletter sign-up. If you use the contact form, we receive your name, email address and the message you write. If you subscribe to the newsletter, we receive your email address and any other details you enter, and we use them to send the newsletter until you unsubscribe.
Our website uses only the cookies it needs to run, and our hosting provider keeps basic server logs, such as IP address, browser type and the pages requested, to keep the site working and secure. We do not use advertising cookies, ad pixels or third-party tracking tools, and we do not track you across other websites. That is why the site does not show a cookie banner. If we ever add tools that need your choice, we will add a banner and update this notice first.
We honor Global Privacy Control and Do Not Track signals that your browser sends, even though we do not track you in a way that depends on them. You can also block or delete cookies in your browser settings, though parts of the site may not work as well if you do.
Our website may link to other sites. Those sites have their own privacy practices, and we are not responsible for them.
Security
We limit access to personal information to the people who need it for their work. Investors reach documents through personal sign-in links, and sensitive files are set to view-only with downloading turned off. Please do not forward your link, since it is meant for you alone. Our providers encrypt information as part of their services.
No system is perfectly secure, so we cannot promise absolute security. If a security incident affects your personal information, we will notify you and any regulator as the law requires.
How long we keep information
We keep personal information for as long as we need it for the investment relationship, and after that for as long as tax, legal and record-keeping requirements call for. Tax filings, signed investment documents and records of money movements, for example, may have to be kept for years after an investment ends. When we no longer need information for these purposes, we delete it or remove the details that identify you.
Where information is stored
We operate in the United States, and the personal information we hold is stored primarily in the United States, including with our service providers. If you use our website or send us information from outside the United States, you understand that it will be handled in the United States, where privacy laws may differ from those where you live.
Your rights and choices
Your rights
Depending on where you live, you may have the right to:
- access the personal information we hold about you and receive a copy;
- ask us to correct information that is wrong or incomplete;
- ask us to delete your information;
- receive your information in a portable, commonly used format where that is feasible;
- ask us to limit how we use and disclose your sensitive personal information; and
- opt out of marketing.
We use sensitive personal information only for the purposes listed in this notice, so there is generally no further use to limit, but you are welcome to ask. We will not deny you service, charge you a different price or otherwise treat you differently because you used any of these rights.
How to make a request
Email investors@laguna-point.com, or write to us at Laguna Point Properties, Attn: Privacy, 12226 South 1000 East, Suite 4, Draper, Utah 84020. Tell us what you are asking for and the name and email address on your investor record.
Verifying your identity and using an agent
We will match your request against what we already hold and may ask for more, because we do not want to hand your tax number or account details to the wrong person. You may use an authorized agent to make a request. We may ask for your written permission and may confirm the request with you directly.
Our response and appeals
We respond within the time the law requires, generally 45 days, and we will tell you if we need more time. We may decline or limit a request where the law allows or requires it, for example when tax or other record-keeping rules require us to keep a record, or when the information is exempt. When we do, we explain why. If you disagree with our decision, write to us with the subject line “Privacy appeal,” and someone who was not involved in the first decision will review it and reply in writing.
State privacy rights
Residents of California and other states with privacy laws have rights under those laws, and we honor them for residents of those states in the ways described in this notice. Which rights apply depends on your state and on whether a given law covers us or the information involved. Many of these laws exempt certain financial and legal-compliance information. Nothing in this notice is an admission that any specific law applies to us or that we meet any specific threshold. We do not disclose personal information to third parties for their own direct marketing.
Communications preferences
To stop receiving the newsletter, use the unsubscribe link in any issue or email us. Messages about your investment, such as capital calls, tax documents and account notices, are not marketing, and we will keep sending them while you hold an investment.
Children
Our website and services are not directed to anyone under 18, and we do not knowingly collect personal information from children. If you believe a child has given us information, contact us and we will delete it.
Changes to this notice
We will post updates on this page with a new effective date and version number. We will note material changes at the top of the page, and where the law requires it, we will also tell you directly.
Dispute resolution
This notice, and any dispute arising out of or relating to it or to how we handle your personal information, are governed by the laws of the State of Delaware, without regard to conflict-of-laws principles. Any such dispute belongs exclusively in the state or federal courts located in Delaware, and you and we consent to the personal jurisdiction of those courts.
To the extent the law allows, you and we may bring claims only on an individual basis, and not as a plaintiff or class member in any class, collective or representative action. Nothing in this section limits any right you have under law that cannot be waived, including any right to bring a complaint to a government regulator. Where your investor agreements contain their own governing-law or dispute-resolution terms for investor matters, those terms control for those matters.
Contact
For privacy questions, requests and appeals, email investors@laguna-point.com or write to Laguna Point Properties, Attn: Privacy, 12226 South 1000 East, Suite 4, Draper, Utah 84020. For general questions that are not about privacy, email info@laguna-point.com.