Data Policy

1. Scope

This policy covers corporate websites operated by Sim Capital, inbound business communications, and operational systems used to run the holding company. It does not replace product privacy notices for UpperDeck, Property Desk, or other portfolio products.

2. Categories of data

Depending on how you interact with us, we may process:

• Identity and contact data
• Business inquiry and partnership correspondence
• Technical and usage logs from our websites
• Vendor and contractor business information
• Publicly available professional information when evaluating partnerships

3. Lawful bases and purposes

Where applicable law requires a lawful basis, we process data to respond to requests, operate our business, pursue legitimate interests such as security and product improvement, comply with legal obligations, and enter into or perform contracts.

4. Processors and subprocessors

We use trusted service providers for hosting, analytics, communications, and security. Providers are expected to process data only on our instructions and with appropriate safeguards. A current list of major providers can be requested by emailing us.

5. Retention and deletion

We retain data for as long as reasonably necessary for business, legal, and security purposes. When data is no longer needed, we delete or de-identify it according to our operational practices, subject to backup and legal hold requirements.

6. Security controls

We apply access controls, encryption in transit where appropriate, monitoring, and least-privilege practices. Portfolio products may implement additional controls based on their risk profile and customer requirements.

7. Cross-border transfers

Data may be stored or processed in the United States and other jurisdictions. Where required, we use appropriate transfer mechanisms and contractual protections.

8. Requests

To request access, correction, or deletion of personal data we hold about you, contact hello@simcapital.com. We will respond in accordance with applicable law.