PRIVACY POLICY
Privacy Policy
Effective Date: 2026-06-04
Last Updated: 2026-08-15
This Privacy Policy describes how DIG Strategic LLC ("DIG," "we," "us," or "our"), which operates GateCurate (a Davis Infinity Group LLC company), collects, uses, discloses, and protects your personal information when you visit gatecurate.com (the "Site"), subscribe to The Briefing newsletter, purchase a GateCurate subscription, or otherwise interact with our services (collectively, the "Services"). It also describes how we handle information collected through the Founding Architect cohort program, which closed on August 2, 2026 and does not reopen; those disclosures are marked historical below and are retained because we continue to hold information collected during that program.
By using the Services, you agree to the collection and use of information in accordance with this Policy. If you do not agree, please do not use the Services.
The Services are intended for businesses and users in the United States. We do not currently offer the Services to, or direct them at, individuals located in the European Economic Area, the United Kingdom, or Switzerland. The EU/UK/Swiss provisions in this Policy are included for completeness and apply only to the extent required by applicable law.
1. Who We Are
The data controller responsible for your personal information is:
DIG Strategic LLC (operator of GateCurate; a Davis Infinity Group LLC company)
1401 21st Street, #14403
Sacramento, CA 95811
United States
Email: legal@gatecurate.com
2. Information We Collect
2.1 Information You Provide Directly
- Newsletter signup: first name, last name, email address, company name (optional), role/title (optional), primary industry, ZIP code (optional).
- Founding Architect application (historical — program closed August 2, 2026): name, email address, business name (optional), business website (optional), operator type/vertical, descriptions of your current intake process, descriptions of friction you experience, your interest in the Founding Architect cohort, and referral source (optional). We no longer accept applications and no longer collect this category of information; we continue to hold records already collected, as described in Section 8.
- Subscription purchases: name, email address, billing address, and payment information. Payment card data is collected and stored by our payment processor, Stripe, Inc.; we do not store full payment card numbers on our systems.
- Customer support inquiries: any information you choose to provide when contacting us.
- Beta program participation (historical — program closed August 2, 2026): usage feedback, survey responses, scheduled-call notes, and any materials submitted during the Founding Architect Beta cohort. We no longer collect this category of information; we continue to hold records already collected, as described in Section 8.
2.2 Information Collected Automatically
- Technical data: IP address (anonymized for analytics purposes), browser type and version, device type, operating system, referring URL, and pages viewed.
- Usage data: pages visited, time spent on pages, clicks, scroll depth, and similar engagement metrics.
- Cookies and similar technologies: see Section 11 below.
2.3 Information from Third Parties
- Payment processor: Stripe provides us transaction confirmation data (last four digits of card, card brand, billing country, subscription status) but does not share full payment card details.
- Analytics providers: aggregated and anonymized usage data from Google Analytics 4.
- Publicly available sources (historical): during the Founding Architect application window, which closed August 2, 2026, we supplemented contact information applicants provided with publicly available business information (e.g., the applicant's firm website) to assess fit for the cohort. We no longer supplement records from public sources for this purpose.
3. How We Use Your Information
We use your information for the following purposes:
- Service delivery: to provide, maintain, and improve the Services, including account management, content delivery, and customer support.
- Communications: to send The Briefing newsletter, transactional emails (subscription confirmations, payment receipts, password resets, service updates), and respond to inquiries.
- Beta program administration (historical): during the Founding Architect program, which closed August 2, 2026, we used applicant and participant information to evaluate applications, manage cohort participation, and gather feedback for product development. We no longer process information for these purposes; records already collected are held only for the record-keeping purposes described in Section 8.
- Marketing (with consent): to send marketing communications you have opted into, and to tailor those communications to your industry/vertical.
- Analytics and improvement: to understand how visitors use the Site, identify performance issues, and improve content and user experience.
- Payment processing: to process subscription transactions and prevent fraud.
- Legal compliance: to comply with applicable laws, respond to legal process, enforce our Terms of Service, and protect our rights, property, and safety, and that of our users and others.
- Business operations: internal record-keeping, audit, and risk management.
4. Legal Bases for Processing (EU/UK Residents)
If you are located in the European Economic Area, United Kingdom, or Switzerland, we process your personal data on the following legal bases:
- Consent: for marketing emails, optional cookies, and other processing where you have explicitly opted in. You may withdraw consent at any time.
- Contract: to perform our subscription agreement with you, including payment processing and service delivery.
- Legitimate interests: for analytics, fraud prevention, and service improvement, where such interests are not overridden by your data-protection rights. This basis previously also covered direct outreach in connection with the Founding Architect cohort; that program closed August 2, 2026 and we no longer conduct such outreach.
- Legal obligation: to comply with applicable laws, tax obligations, and regulatory requirements.
5. How We Share Information
We do not sell your personal information. We share personal information only in the following circumstances:
5.1 With Service Providers
We share information with third-party vendors that perform services on our behalf, bound by written agreements requiring confidentiality and data protection consistent with this Policy. See Section 7 for our current service-provider list.
5.2 For Legal Reasons
We may disclose information when we believe in good faith that disclosure is necessary to:
- Comply with applicable law, regulation, legal process, or government request;
- Enforce our Terms of Service or other agreements;
- Detect, prevent, or address fraud, security, or technical issues;
- Protect against harm to the rights, property, or safety of DIG, our users, or the public.
5.3 Business Transfers
If DIG is involved in a merger, acquisition, asset sale, financing, or similar transaction, your information may be transferred as part of that transaction. We will provide notice and applicable choices to affected users.
5.4 With Your Consent
We may share information for other purposes with your explicit consent.
6. Aggregated and De-identified Data
We may use and share aggregated or de-identified data (data that cannot reasonably be used to identify you) for any purpose, including publishing operator benchmarks, industry analysis, and case studies. When we publish such data, individual customers are never named or identified, and care is taken to ensure aggregate values cannot be reverse-engineered to identify any specific party.
6A. Publication of De-identified Qualification Reasons (Opt-In)
With your explicit opt-in permission, we may publish the plain-language reasons our product generates when qualifying the leads you bring into GateCurate, in our editorial and marketing (for example, The Briefing). This is opt-in, default-off, and not required to use the Services. Before publishing, we remove information that could reasonably be used — directly or indirectly, or in combination — to identify you or any third party (such as a lead), and we publish only content that cannot reasonably be linked to an identifiable person. How to opt out or withdraw: email legal@gatecurate.com with the subject line "Publication Opt-Out," or use the opt-out link in the related confirmation email. We honor opt-out requests within ten (10) business days; after withdrawal we will not draw from your account for future pieces, and we will remove any already-published item later found to identify an individual. Because these reasons derive from data about your leads, you are responsible for any lawful basis, notice, or permission required for us to use that data this way; we publish only de-identified content and do not name you or your customers.
7. Third-Party Service Providers
The Services rely on the following categories of third-party service providers. Each is bound by contractual data-protection terms with us and processes personal information only as needed to perform their function.
- Hosting and infrastructure: Cloudflare, Inc. (United States) — Site hosting, content delivery network, edge compute, DNS.
- Payment processing: Stripe, Inc. (United States) — subscription payments, card data tokenization, under a GateCurate-branded merchant account held by our parent, Davis Infinity Group LLC. Subject to Stripe's own privacy policy at stripe.com/privacy.
- Customer relationship management: Taskade Inc. — subscriber registry and operational data.
- Transactional email delivery: our email dispatcher routes through reputable third-party email service providers compliant with SPF, DKIM, and DMARC standards.
- Analytics and performance: Google Analytics 4 (Google LLC), with IP anonymization enabled, and Cloudflare, Inc. (cookieless web-analytics and performance measurement) — used to understand how the Site is used and performs.
- AI service providers: We use third-party AI / large-language-model providers as our service providers — both to assist in producing editorial content and, as part of the GateCurate product, to process intake and lead data and generate qualification output. These providers act only on our behalf, under contract, to provide their services to us, and are not permitted to use the data for their own purposes. We are finalizing data-protection terms (including limits on model training and data retention) with each such provider.
We may add, replace, or discontinue service providers from time to time. Material changes will be reflected in updates to this Policy.
8. Data Retention
We retain personal information for as long as needed to provide the Services and fulfill the purposes described in this Policy, unless a longer retention period is required or permitted by law. Specific retention practices:
- Newsletter subscribers: until you unsubscribe, plus a reasonable archival period (up to 18 months) for legal and operational records.
- Founding Architect applicants and Beta participants (program closed August 2, 2026): we continue to hold application records, and non-disclosure agreement records for Beta participants, for three (3) years following the close of the program — that is, until August 2, 2029 — for legal, audit, and record-keeping purposes, including the confidentiality obligations that survive the program under Section 12 of our Terms of Service. Because the program does not reopen, we no longer retain this information for eligibility tracking. You may request deletion of your application record at any time by emailing legal@gatecurate.com; see Section 10.
- Active subscribers: for the duration of your subscription plus seven (7) years following termination, to comply with tax, accounting, and audit requirements.
- Site analytics: aggregated analytics data retained for up to 26 months.
- Support communications: retained for up to three (3) years following the close of the inquiry.
9. International Data Transfers
DIG is based in the United States. By using the Services, you understand that your information may be transferred to, stored, and processed in the United States and other jurisdictions where our service providers operate, which may have data-protection laws different from those in your jurisdiction.
The Services are U.S.-focused, as noted above. To the extent we receive personal data from the European Economic Area, United Kingdom, or Switzerland, we will put appropriate transfer safeguards in place — such as the European Commission's Standard Contractual Clauses (SCCs) and any required supplementary measures — before relying on such transfers.
10. Your Rights and Choices
10.1 General Rights
Subject to applicable law, you have the right to:
- Access the personal information we hold about you;
- Request correction of inaccurate or incomplete information;
- Request deletion of your personal information;
- Object to or restrict certain processing;
- Request portability of your personal information in a structured, commonly used, machine-readable format;
- Withdraw consent at any time for processing based on consent.
10.2 California Residents (CCPA / CPRA)
If you are a California resident, the California Consumer Privacy Act ("CCPA"), as amended by the California Privacy Rights Act ("CPRA"), provides additional rights:
- Right to know: the categories and specific pieces of personal information we collect, the categories of sources, the business purpose for collection, and the categories of third parties with whom we share information.
- Right to delete: request deletion of personal information we collected from you, subject to certain exceptions.
- Right to correct: request correction of inaccurate personal information.
- Right to limit: limit the use and disclosure of sensitive personal information (note: we do not currently collect sensitive personal information as defined under the CPRA).
- Right to opt out of sale or sharing: we do not sell personal information or share it for cross-context behavioral advertising.
- Right to non-discrimination: you will not be denied service, charged a different price, or provided a lower level of service for exercising any of these rights.
To exercise these rights, email legal@gatecurate.com. We may require verification of your identity before fulfilling your request.
10.3 EU, UK, and Swiss Residents (GDPR / UK GDPR)
If you are located in the European Economic Area, United Kingdom, or Switzerland, you also have the right to lodge a complaint with your local data protection authority if you believe our processing of your personal information violates applicable law.
10.4 How to Exercise Your Rights
To exercise any of the rights described above, email legal@gatecurate.com with the subject line "Privacy Request." We will respond within the timeframe required by applicable law (typically 30 days under GDPR, 45 days under CCPA/CPRA). We may need to verify your identity before fulfilling certain requests.
11. Cookies and Similar Technologies
We use cookies and similar tracking technologies to:
- Maintain essential Site functionality (strictly necessary cookies);
- Remember your preferences and improve user experience;
- Measure how the Site is used and performs (cookie-based analytics, such as Google Analytics, and cookieless analytics beacons, such as Cloudflare's).
We do not use cookies for advertising or cross-site behavioral tracking. Our cookie-based analytics are configured to anonymize your IP address, and our performance analytics are cookieless.
You can control cookies through your browser settings; blocking some cookies may impact certain features of the Site. Because the Services are U.S.-focused and we do not sell or share personal information, we do not currently display a cookie-consent banner. If we expand to jurisdictions that require prior consent for non-essential cookies, we will present that choice before setting them.
12. Data Security
We implement reasonable administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, alteration, disclosure, or destruction. These include:
- Encryption of data in transit (TLS 1.2+);
- Encrypted storage at rest for sensitive data and credentials;
- Role-based access controls for internal systems;
- Regular review of service-provider security practices;
- Incident response procedures for suspected breaches.
No method of transmission or storage is 100% secure. While we strive to protect your information, we cannot guarantee absolute security. You are responsible for keeping your account credentials confidential.
13. Children's Privacy
The Services are not directed to individuals under sixteen (16) years of age, and we do not knowingly collect personal information from children. If we become aware that we have collected personal information from a child without verifiable parental consent, we will take steps to delete that information promptly. If you believe we have collected information from a child, please contact legal@gatecurate.com.
14. Marketing Communications
If you subscribe to The Briefing newsletter or otherwise consent to marketing communications, you may opt out at any time by:
- Clicking the "unsubscribe" link in any marketing email;
- Emailing legal@gatecurate.com with the subject line "Unsubscribe."
Opting out of marketing communications does not affect transactional communications related to your account or subscription (e.g., payment receipts, service updates, security notices).
15. Do Not Track and Global Privacy Control
Some browsers transmit "Do Not Track" signals. Because no consistent industry standard exists for responding to such signals, the Services do not currently respond to Do Not Track signals. Because we do not sell or share personal information, there is no sale or sharing for you to opt out of — including via Global Privacy Control (GPC); should our practices ever change, we will treat GPC as a valid opt-out signal. We respect the cookie and consent choices you make directly with us as described in this Policy.
16. Third-Party Links
The Site may contain links to third-party websites, products, or services. We are not responsible for the privacy practices of those third parties. We encourage you to review the privacy policies of any third-party sites you visit.
17. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make changes, we will update the "Last Updated" date at the top of this Policy. For material changes, we will provide additional notice through the Site, by email to active subscribers, or by other means as required by applicable law.
Your continued use of the Services after the effective date of any update constitutes acceptance of the updated Policy.
18. Contact Us
If you have questions, concerns, or complaints about this Policy or our privacy practices, please contact us:
DIG Strategic LLC (operator of GateCurate; a Davis Infinity Group LLC company)
Attn: Privacy
1401 21st Street, #14403
Sacramento, CA 95811
United States
Email: legal@gatecurate.com
This Privacy Policy is provided for informational purposes and does not constitute legal advice. For specific legal questions regarding your use of the Services, please consult qualified counsel.