PRIVACY POLICY

WE RESPECT YOUR PRIVACY

At RealtyBits we take your privacy seriously and do our best to protect it. We are required by law to ask for certain information in order to perform our services for you, but we are committed to protecting your personal and financial information. Below are basic privacy principles or privacy policy "bill of rights" that we adhere to. This Bill of Rights includes the following list of policies:

  1. We don't ask you for personal or financial information unless we need it.
  2. We don't share your personal information with anyone except to comply with the law, develop our products, or protect our rights.
  3. We aim to make it as simple as possible for you to control what's visible to the public, seen by search engines, kept private, and permanently deleted.
  4. We will send you emails relating to specific transactions but will keep these emails to a minimum.
  5. We will maintain appropriate security standards and procedures to protect your information.
  6. We will respect the trust you place in us and the confidential nature of the information you provide through your financial relationship with us.

OUR POLICY

Welcome to the web site www.RealtyBits.com (the “Site”) owned and operated by RealtyBits, Inc. (hereinafter, “RealtyBits”, “we”, “us”, and/or “our”). This Privacy Policy has been created to provide information about our company and its financial matchmaking services (the “Services”) to all visitors of the Site and the users of the Services provided thereon, including, but not limited to, investment managers offering an investment (the “Issuer”) and investors using the site to invest (in each case, a “User”, and collectively, “Users”). This Privacy Policy sets forth RealtyBits’ policy with respect to information, including personally identifiable information (“Personal Information”), and other information that is collected from Users.

By using the Site and/or Services, you accept the practices and terms set forth in our Privacy Policy as it may be updated from time to time in RealtyBits’ sole and absolute discretion.

WHAT INFORMATION WE COLLECT

When you interact with us through the Site or Services, we may collect and process Personal Information and other information from you, as further described below:

Personal Information That You Provide Through the Site. We collect Personal Information from you when you voluntarily provide such information. This Personal Information is required to transact business, to communicate with you, verify your identity and fulfill legal and regulatory requirements. The types of Personal Information we collect and share depends on the product or service you have with us. This information may be collected when you:

  1. register for access to the Services (for example, contact information such as your name, email address, phone number, mailing address);
  2. complete certain forms on the Site;
  3. upload or submit any material through the Site;
  4. request any information or contact us with inquiries; or
  5. wish to use certain Services (for example financial information such as bank account numbers, your Date of Birth and the last 4 digits of your social security number).

By voluntarily providing us with Personal Information, you are giving RealtyBits permission to use and store it consistent with this Privacy Policy. We may also obtain your personal information from your transactions with us or other Users through the Services, or from third parties such as credit reporting agencies. If we combine or associate information from other sources with personal information that you provide directly to us through or in connection with the Services, we will treat the combined information as Personal Information in accordance with this Privacy Policy.

Non-Identifying Information. As is the case with most websites, when you visit the Site or interact with RealtyBits through the Site or Services (and whether or not you register for access to the Services), we receive, automatically track and store certain non-identifying information about you, including but not limited to:

  1. browser type;
  2. IP address;
  3. language preference;
  4. cookies; domain servers;
  5. URL traffic to, through and from the Site;
  6. types of computers and operating systems accessing the Site;
  7. statistical information about behavior of visitors/users to the Site; and
  8. any other web site usage information that we may collect when you visit the Site.

This information, which may be collected passively using various technologies or through other means, cannot be used to specifically identify you. RealtyBits may store such information itself or such information may be included in databases owned and maintained by RealtyBits affiliates, agents or service providers. The Site may use such information and pool it with other information for administrative purposes, to assess the usage, value and performance of our products and services, to improve your experience with the Services and to track, for example, how our Users use and interact with the Services.

Also, in an ongoing effort to better understand and serve the users of the Site and Services, RealtyBits often conducts research on its customer demographics, interests and behavior based on the Personal Information and other information provided to RealtyBits by Issuers and Users. RealtyBits may also disclose aggregated user statistics in order to describe our Services to current and prospective business partners and to other third parties for other lawful purposes.

TECHNOLOGY (COOKIES)

Cookies are small pieces of information which are issued to your computer when you visit a website and which store and sometimes track information about your use of the Services. RealtyBits uses cookies to help recognize you as a repeat visitor, to improve the quality of our Services, and to try and make your browsing experience meaningful. When you enter our Site, our web server sends a cookie to your computer which allows us to recognize your computer but not specifically who is using it. By associating the identification numbers in the cookies with other customer information when, for example, you log-in to the Site or Services, then we know that the cookie information relates to you. Some of the cookies used by our Services are served by us, and some are served by third parties who are delivering services on our behalf. The use of cookies by any third parties, including our affiliates or service providers, is not covered by this Privacy Policy. We do not have access or control over these cookies.

Most web browsers automatically accept cookies but, if you prefer, you can change your browser to prevent this or to notify you each time a cookie is sent. You can also learn more about cookies by visiting www.allaboutcookies.org which includes additional useful information on cookies and how to block cookies using different browsers. By blocking or deleting cookies used on our Site or Services, please note that you may not be able to take full advantage of our Services. Therefore, we recommend that you leave cookies turned on because they allow you to take advantage of some of the Site's features.

USE OF YOUR PERSONAL INFORMATION

RealtyBits considers the protection of sensitive information to be an important goal. Accordingly, RealtyBits uses the Personal Information you provide in a manner that is consistent with this Privacy Policy. If you provide Personal Information for a certain reason, we may use the Personal Information in connection with the reason for which it was provided. For example, we will use the Personal Information you provide or that we obtain from third parties to:

  1. identify you when you sign-in to your account;
  2. enable us to provide you with the Services;
  3. send you information we think you may find useful or which you have requested from us;
  4. present projects or opportunities to you when you use the Services which we believe will be of interest based on your geographic location and previous use of the Services;
  5. notify an Issuer of your interest in the event you indicate an interest in making an investment with the Issuer through the Services;
  6. administer your account with us;
  7. enable us to contact you regarding any question you make through the Services;
  8. analyze the use of the Services and the people visiting to improve our content and Services;
  9. use for other purposes that we may disclose to you when we request your information.

Also, if you provide Personal Information in order to obtain access to the Services, we will use your Personal Information to provide you with access to such services and to monitor your use of such services. We also may obtain information about you from third party sources to verify your identity so we can properly process your requests and prevent fraud.

In addition, RealtyBits and its subsidiaries and affiliates may also use your Personal Information and other non-identifiable information collected through the Site (collectively, "User Information") to, among other things, improve user experience, customize content for our users in order to make the Site simpler to use, and to help us identify any other issues with respect to the Services or a User’s use of the Site or Services. RealtyBits and its subsidiaries and affiliates may also use this information to communicate with you regarding the Services. If you object to our collection or storage of any User Information mentioned above (and any additional information we may choose to gather) you should not use the Site. Additionally, if you decide you no longer want RealtyBits to store and utilize your information consistent with this Privacy Policy, you may opt out of this Privacy Policy by the directions in the Right To Opt-out section at the bottom of this Privacy Policy.

EMAIL

Regarding email contact with and from RealtyBits, please keep in mind the following: (i) we will send you email relating to your personal transactions but will keep these emails to a minimum; (ii) you will receive certain email notifications (forwarded messages, etc.) for which you may opt-out; (iii) we may send you service-related announcements on rare occasions when it is necessary or proper to do so; (iv) if you email us directly, we may email you back and keep records of all correspondence; and (iv) we may send you emails from time to time letting you know about special promotions, featured investments and other RealtyBits news. It is your responsibility to ensure that you maintain a current email address with RealtyBits, and notify us if there are any changes.

THIRD PARTY SERVICES

RealtyBits limits the sharing of your Personal Information and strives to keep your Personal Information private and confidential. We do not sell, license, lease or otherwise disclose your personal information to any unaffiliated third party for any reason, except as follows:

  1. We may disclose your Personal Information when such disclosure is required or appropriate pursuant to laws, court orders or securities regulations, including responding to court orders and subpoenas, cooperating with government agencies, other regulatory bodies and law enforcement officials, performing background checks, resolving disputes or performing risk-management functions.
  2. We may share your Personal Information with companies that provide services to us, including outside contractors or agents who help us manage our information activities, but they may only use your personal information to provide us with a specific service and not for any other purpose.
  3. To help us improve our services to you, we may engage third parties to help us carry out certain internal functions such as account processing, client services or other data collection relevant to our business. Use of any Personal Information shared in connection therewith is strictly limited to the performance of the task we request and for no other purpose.
  4. In the event you indicate an interest in making an investment through our Site, we will notify the Issuer of your interest and will provide your Personal Information to the Issuer.
  5. We may make certain automatically collected information about your interactions and activities on the Services, such as the business or investment areas of interest to you or you have invested in, and your past activities, projects or proposals, publicly available on or through the Services. Any such publicly available information will be accessible by other Users.
  6. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Information may be part of the transferred assets and you will be notified via email and/or a prominent notice on our Site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your Personal Information.

In addition to the above, we may need to share your information in continuance of the transaction for which you have voluntarily utilized our services. The ways in which we share that information immediately follows.

Potential Disclosure of Subscriber Information to Related Transaction Parties; Ongoing Compliance with Governmental Requirements. The real estate company(ies) sponsoring an investment project (collectively, the “Sponsor”), lenders relating to the investment project, or other parties involved with the investment and related transactions (collectively, “Related Transaction Parties”) may require that RealtyBits, the Manager, or any of their respective affiliates provide such Related Transaction Parties with the names, investment amounts, and other information regarding the various investors in a financing offering, notwithstanding the usual privacy policies of RealtyBits or any of its affiliates. You hereby expressly consent and agree that any of RealtyBits, the Manager or any of their respective affiliates may provide such information (which may include, without limitation, Social Security numbers or similar identifying information, evidence of your qualification as an “accredited investor,” or other information related to your involvement with an investment project) to any such Related Transaction Parties requiring such information as part of the consummation of, or continued participation in, the investment project or the related transactions contemplated hereunder, as RealtyBits or any of its affiliates may deem appropriate in its or their sole and absolute discretion.

The Department of the Treasury, the Internal Revenue Service, and other governmental authorities may from time to time impose certain compliance or reporting requirements that may require RealtyBits or any of its affiliates to request from you additional financial or personal information. These regulations, including (without limitation), the PATRIOT Act and the Foreign Account Tax Compliance Act, may require increased due diligence, compliance activity, or reporting on the part of RealtyBits or any of its affiliates. You hereby warrants that you will, upon request, supply to RealtyBits or any of its affiliates all information reasonably necessary or advisable to carry out such functions or requirements.

SAFEGUARDING USER INFORMATION

The Security of your User Information is important to us, and we take commercially reasonable steps to safeguard such information. These steps and procedural safeguards are in line with industry standards and practices and include:

  1. Encryption and authentication tools to maintain the confidentiality of User Information including Transport Layer Security technology (TLS) encryption certificates provided by Let’s Encrypt CA (SHA-256 With RSA Encryption);
  2. Limits on, to the greatest extent possible, who or what can access your User Information, including utilization of a “lease-privilege principle” such that employees have access only to the information and systems needed to perform their functions and only for the duration of such need;
  3. Redundant systems to monitor the entire RealtyBits’ server infrastructure in real-time with web-based and server applications reporting and instant notification to the appropriate staff for any remediation; and
  4. The use of cookies to help (anonymously) recognize you as a repeat visitor and to track Site traffic patterns.

However, despite these efforts, please note that RealtyBits cannot ensure or guarantee the security of your User Information nor do we make any representation or warranty regarding the security of your account. If we learn of a security systems breach, then we may attempt to notify you electronically so that you can take appropriate protective steps. We may also post a notice on or through the Site and the Services in the event of a security breach. Depending on where you live, you may have a legal right to receive notice of a security breach in writing.

ACCURATE INFORMATION

You are solely responsible for helping us to maintain the accuracy and completeness of your personal and other information. We urge you to review your information regularly to ensure that it is correct and complete. If you believe that any of your information is incorrect, please contact us at contact@realtybits.com.

You may, of course, decline to share any or all of your Personal Information with us or ask us to delete your Personal Information from our systems at any time, in which case we may not be able to provide to you some of the features and functionality found on or through the Site and the Services (see below section regarding Right To Opt-out).

Additional Accreditation Verification Measures. In addition to the information you provide to us, under certain circumstances, federal law may require RealtyBits or any of its affiliates to take additional steps to verify that you are an “accredited investor.” If such circumstances apply to the offering of certain securities in which you would like to invest, you agree to utilize an independent third-party verification provider, which may be VerifyInvestor.com (“VI”) or such other service provider as RealtyBits may from time to time utilize for such purpose, to verify your status as an accredited investor. You understand that VI or such other provider may contact you directly in such instance, and you agree to promptly work with VI or such other provider to complete the verification process. RealtyBits or an affiliate will pay the service provider's fees and costs for this service. RealtyBits will not share with you the information received from VI or such other service provider regarding you or your status as an accredited investor unless such information is the basis for RealtyBits or an affiliate declining to accept your investment subscription.

We will retain your User Information for as long as your account is active or as needed to provide you services, and we may continue to retain such User Information beyond your active use of the RealtyBits platform. You may modify or delete the Personal Information you have provided to us by logging in and updating your account. We may, however, retain certain information as required by law or for necessary business purposes.

PUBLIC INFORMATION

Please keep in mind that any information you post on portions of the Site or Services that are open to the public, including but not limited to our blog, will be public information available to anyone. Information that you provide in these areas may be read, collected and used by others who access them. Accordingly, you should exercise caution when deciding to disclose your personal information in these areas. To request removal of your personal information from these publicly accessible areas, contact us at contact@realtybits.com. In some cases, we may not be able to remove your personal information and we will let you know if this is the case and why.

LINKS TO OTHER WEBSITES

We are not responsible for the practices employed by websites linked to or from our Site or Services nor the information or content contained therein (collectively “Third Party Sites”). Please remember that when you use a link to go from our Site to a Third Party Site, our Privacy Policy is no longer in effect. Your browsing and interaction on any Third Party Site, including those that have a link on our Site, is subject to that Third Party Site’s rules and policies. Please read over those rules and policies before proceeding.

INTERNATIONAL USERS

The Services may be accessed and/or used by Users located outside the United States. If you choose to use the Services from the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your personal information outside of those regions to the United States and by providing your personal information on or through the Services you consent to that transfer.

UPDATES AND CHANGES TO PRIVACY POLICY

We reserve the right at any time to add to, change, update, or modify this Privacy Policy, simply by posting such change, update, or modification on the Site and without any other notice to you. Any such change, update or modification will be effective immediately upon posting on the Site. We encourage you to periodically review this page for the latest information on our privacy practices.

CHILDREN'S PRIVACY

RealtyBits does not knowingly collect Personal Information from children under the age of 13 without the consent of their legal guardian. If you are under the age of 13, please do not submit any Personal Information through the Site. We encourage parents and legal guardians to monitor their children's Internet usage and to help enforce our Privacy Policy by instructing their children never to provide Personal Information on this Site without their permission. If you are a parent or guardian and discover that your child under the age of 13 has a registered account with the Services or RealtyBits has received any Personal Information of that child without your consent, you may contact us, and we will endeavor to delete that information from our databases.

OTHER TERMS AND CONDITIONS

Your access to and use of this Site is subject to the Terms of Service.

CONTACT REALTYBITS

If you have questions or comments about this Privacy Policy, your choices with regards to our collection and use of your User Information or any other aspect of the Site or Services, please feel free to contact us by email at contact@realtybits.com.

Right To Opt-out. If at any time you wish to opt-out of the above Privacy Policy, you may do so at any time by contacting us by email at contact@realtybits.com. If at any time you so decide to opt-out by contacting us at the above email, RealtyBits will cease the sharing or use of your information after a reasonable amount of time to process such a request. However, please be advised that certain of our Services, including but not limited to our investment platform, require the sharing of your information in order to service your activity on our site. In such a case, it may be necessary for us to terminate your use of such services. We will not charge you a fee for withdrawal of your consent.