Privacy Policy | Command Stone

Command Stone Private Partners Inc. ("Company," "we," "us," or "our") operates commandstone.com and Stonebook. This Privacy Policy describes how we collect, use, and share information when you use the Site.

Command Stone Private Partners Inc., a corporation ("Command Stone", "we", "us", or "our"), respects the privacy of the firms and individuals who use our platform. This Privacy Policy explains what information we collect through commandstone.com and the portfolio reporting software offered through it, how that information is used and safeguarded, and the choices available to you. Because our clients are investment advisory firms and family offices, this Policy distinguishes throughout between information about our clients and information those clients furnish to us about their own underlying customers.

1. Company Information

Company: Command Stone Private Partners Inc.
Address: 12 Farnsworth St, Boston, MA 02210
Phone: (888) 903-2690
Email: support@commandstone.com
Website: commandstone.com

2. Information We Collect

Information you provide directly

Contact and identity details such as name, firm name, business title, business email address, mailing address, and telephone number.
Account credentials and authentication data, including multi-factor authentication settings.
Billing and subscription details. Payment card data is processed by our payment processor and is not stored on our systems.
Mobile telephone number and marketing preferences, where you choose to provide them.

Information furnished by custodians and clients

Position, transaction, and balance data delivered on a read-only basis by custodians you designate.
Valuations, ownership tags, and entity structures that you or your representatives enter for privately held assets.
Account titling and household groupings used to organize reporting.

Information collected automatically

Log and device data such as IP address, browser type, operating system, pages viewed, and timestamps.
Cookies and similar technologies used to keep you signed in, remember preferences, and measure aggregate site usage.

We do not collect information from any source in order to sell it, and we do not purchase personal information from data brokers.

3. How We Use Information

We use the information described above to:

Provide, operate, reconcile, and support the reporting platform.
Authenticate users, administer subscriptions, and process payments.
Generate the reports, exposure views, and audit records that you request.
Respond to inquiries and provide technical and account support.
Maintain the security and integrity of the platform, including fraud prevention and access logging.
Send administrative notices and, where you have opted in, promotional communications.
Comply with legal, regulatory, tax, and recordkeeping obligations.

We do not use data furnished by custodians or clients to make investment recommendations, and we do not trade on, aggregate for resale, or otherwise commercially exploit that data.

4. Information Sharing and Disclosure

We do not sell your personal information. We disclose information only in the limited circumstances described below:

Service providers who perform functions on our behalf, such as cloud hosting, market data supply, payment processing, and customer support tooling, each bound by contractual confidentiality and permitted to use the information only to provide services to us.
Custodians and other data sources you designate, solely to establish and maintain the read-only connections you have authorized.
Professional advisers, including auditors and legal counsel, where reasonably necessary.
Governmental authorities or other parties where required by law, subpoena, court order, or other legal process, or where necessary to protect our rights, safety, or property.
A successor entity in connection with a merger, acquisition, financing, or sale of assets, subject to the commitments in this Policy.

With respect to mobile telephone numbers and SMS consent, the following applies without exception:

No mobile information will be shared with third parties or affiliates for marketing or promotional purposes. All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

5. SMS Program and Your Choices

Where you have opted in, Command Stone may send recurring promotional text messages. Message frequency varies, and message and data rates may apply. You may reply STOP at any time to end messages, or reply HELP for assistance. You may also contact us at (888) 903-2690 or support@commandstone.com. Carriers are not liable for delayed or undelivered messages. Supported carriers include: AT&T, T-Mobile, Metro PCS, Verizon Wireless, US Cellular, Google Voice, Cellular One, Cellcom, Cellular South, Interop, and Clearsky.

Consent to receive text messages is never a condition of purchasing or using the Services, and withdrawing consent will not affect your access to the platform.

6. Data Security

We maintain administrative, technical, and physical safeguards designed to protect information against unauthorized access, alteration, disclosure, and destruction. These include encryption of data in transit and at rest, role-based access controls, multi-factor authentication, network segmentation, logging of access to client data, and periodic review of our security posture. Because the platform holds read-only data and cannot move funds or place trades, a compromise of the platform does not expose client assets to transfer.

No method of transmission or storage is completely secure, and we cannot guarantee absolute security. You are responsible for safeguarding your own credentials and for promptly reporting any suspected unauthorized access.

7. Data Retention

We retain information for as long as your subscription remains active and thereafter for the period necessary to satisfy legal, regulatory, audit, and legitimate business requirements. Because advisory firms are subject to their own recordkeeping obligations, historical reporting data is retained in a manner that allows a firm to produce records for examination. Upon written request following termination, we will return or delete client data in accordance with the terms of the applicable subscription agreement and any legal obligation to retain it.

8. Your Rights and Choices

Depending on your jurisdiction, you may have the right to request access to the personal information we hold about you, to request correction or deletion of that information, to object to or restrict certain processing, to request a portable copy, and to withdraw consent where processing is based on consent. Residents of certain states, including California, may also have the right not to be discriminated against for exercising these rights.

To exercise any of these rights, contact us at support@commandstone.com or (888) 903-2690. We will respond within the period required by applicable law and may need to verify your identity before acting on a request. Where you are an underlying customer of one of our client firms, please direct your request to that firm, which controls the data in question; we will assist that firm in responding.

9. Cookies and Tracking

We use strictly necessary cookies to operate the platform and maintain authenticated sessions, together with limited analytics cookies to understand aggregate usage. You may configure your browser to refuse cookies, though disabling strictly necessary cookies will prevent you from signing in. We do not serve third-party advertising on the platform and do not participate in cross-context behavioral advertising.

10. Children's Privacy

The Services are intended solely for business use by professional firms and are not directed to children. We do not knowingly collect personal information from anyone under the age of eighteen. If we learn that we have collected such information, we will delete it promptly.

11. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or in applicable law. The current version will always be posted on this page, and material changes will be communicated to subscribing firms through the platform or by email.

12. Contact Us

Questions, requests, or complaints regarding this Privacy Policy may be directed to:

Company: Command Stone Private Partners Inc.
Address: 12 Farnsworth St, Boston, MA 02210
Phone: (888) 903-2690
Email: support@commandstone.com