PRIVACY POLICY

General

This Privacy Policy sets out how Drawbridge Realty Management, LLC and our subsidiaries and affiliates ("Drawbridge," "we," or “our”) use and protect Personal Information that we may collect about you when you visit our website www.drawbridgerealty.com (the “Website”), correspond with us, or when you interact with our Services. We use your Personal Information to provide our real estate investment and related commercial services (the "Services"). This Privacy Policy applies to our Services that process Personal Information.

What We Mean By Personal Information

For purposes of this Privacy Policy, "Personal Information" means any information from or about a person or household that either identifies a person directly or that makes a person identifiable when it is combined with other information from or about that person from any source.

Notice of Information Collected About You

Categories of Information We Collect

We may collect the following categories of Personal Information, including via your submissions to us through our Website:

(A) Identifiers such as your name, address, and email address, financial account information, or Social Security Number;
(B) Internet or other electronic network activity information, including, but not limited to, information regarding your interaction with our Website;
(C) Professional or employment-related information; and
(D) Any other information that you voluntarily choose to submit.

Categories of Sources From Which We Collect Personal Information

We collect Personal Information from the following categories of sources:

  • Information you voluntarily provide, including from subscription agreements, investor questionnaires, forms, and contracts;
  • Information automatically collected via cookies, web logs, web beacons, and other analytic tools; and
  • Information obtained from our commercial partners, including from our service providers that provide recruiting, employment, and other professional services.

Why We Collect Your Information:

We collect your Personal Information for the following purposes:

  • To respond to, process, and communicate with you about your requests, inquiries, and comments;
  • To manage, monitor and improve the essential functioning and performance of the Website;
  • To protect against, identify and prevent fraud and other unlawful activity, claims and other liabilities;
  • To provide our Services that you request; and
  • To comply with applicable legal requirements, industry standards, and our own policies.

Security

We take reasonable measures to protect your Personal Information, including maintaining physical, electronic and procedural safeguards. Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. If you have concerns about the security of your information with Drawbridge, please contact us at (877) 923-2234 or via email, at Info@drawbridgerealty.com.

California Privacy Rights

Subject to the limitations set forth in Cal. Civ. Code § 1798.100 et seq., if you are a California resident you may have the right:

  • to request disclosure of the categories and specific pieces of information collected about you;
  • to request the disclosure of the business purpose for collecting or selling Personal Information, the categories of third parties with whom it is shared, and the categories of sources from which Personal Information is collected;
  • to request the deletion of your Personal Information Personal Information, subject to the limitations set forth in California Civil Code Section 1798.105(d); and
  • not to be discriminated against for exercising the rights guaranteed by California Civil Code Section 1798.100 et seq.

Requests to Know

You have the right to request that we disclose:

  • The categories of Personal Information we collect;
  • The categories of Personal Information we have sold or disclosed for a business purpose;
  • The categories of sources from which we collect your Personal Information;
  • Our business or commercial purpose for selling or collecting your information;
  • The categories of Personal Information sold or shared about you, as well as the categories of third parties to whom the Personal Information was sold, by category of Personal Information for each party to whom information was sold; and
  • The specific pieces of Personal Information collected about you.

Delivery may take place electronically or by mail. We are not required to provide Personal Information to you more than twice in a 12-month period.

Requests to Delete

You have the right to request that we delete any Personal Information we have collected about you. Upon receiving a verified request to delete your Personal Information, we will do so unless otherwise authorized by law.

Verifiable Requests

We will acknowledge the receipt of requests to know or requests to delete your information free of charge, within 10 business days. In order to protect your privacy and the security of your information, we may verify your request by asking you to provide additional information for us to match against our records. We will respond to your request within 45 calendar days of receipt, after we have successfully verified your identity.

Requests for the disclosure or deletion of your Personal Information can be submitted via telephone, at (877) 923-2234 or via email, at Info@drawbridgerealty.com.

Sale of Information

We do not sell your Personal Information.

The Right to Non-Discrimination

You have a right not to receive discriminatory treatment for the exercise of your California privacy rights.

The Categories of Third Parties With Whom We Share Information

We only disclose personal information we receive from you (i) to third parties if it is necessary or appropriate for the effective management and administration of the investment funds in which you invest, (ii) to service providers (but only to the extent permitted by law), (iii) with your consent or as directed by you and (iv) as required by law. These disclosures include ones made to:

a. Financial service providers, such as broker-dealers, placement agents, custodians, banks and others used to facilitate transactions for our funds;
b. Other service providers, such as legal, accounting or tax preparation services;
c. Other partners of our funds in connection with closing documentation, financial statements and other reports or other partner communications; and
d. Transfer agents, portfolio companies, brokerage firms and the like, in connection with distributions to our partners.

Categories of Information We May Disclose For a Business Purpose:

We may disclose the following categories of Personal Information for business purposes, including to Service Providers:

(A) Identifiers such as your name, address, email address, financial account information, or Social Security Number;
(B) Internet or other electronic network activity information, including, but not limited to, information regarding your interaction with our Website;
(C) Professional or employment-related information; and
(D) Any other Personal Information that you voluntarily choose to submit.

Authorized Agents

You may designate an authorized agent to make requests on your behalf. You must provide an authorized agent written permission to submit a request on your behalf, and we may require that you verify your identity directly with us. Alternatively, an authorized agent that has been provided power of attorney pursuant to California Probate Code sections 4000-4465 may submit a request on your behalf.

Data Retention

We retain Personal Information about you only for as long as needed for the purposes for which it was collected.

Links to Other Websites

Our Website may contain links to other websites of interest. However, once you have used these links to leave our Website, we do not have any control over third party websites. We cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this Privacy Policy. You should exercise caution and review the privacy policy applicable to the website in question.

Children

The Website and the Services are not intended for children under the age of 16. Accordingly, we do not intend to collect, sell or process Personal Information from anyone we know to be under 16 years of age.

How We Use Cookies

Some of the features on the Website and the Services require the use of "cookies" – small text files that are stored on your computer's hard drive. We use cookies to measure which pages are being accessed, and which features are most frequently used. This enables us to continuously improve the Website to meet the needs of our visitors.

The following sets out how we may use different categories of cookies and your options for managing cookie settings:

Type of Cookies Description Managing Settings
Required Cookies Required cookies enable you to navigate the Website and use its features, such as accessing secure areas of the Website and using our services. If you have chosen to identify yourself to us, we use cookies containing encrypted information to allow us to uniquely identify you. These cookies allow us to uniquely identify you when you are logged into the Website and to process your online transactions and requests. Because required cookies are essential to operate the Website, there is no option to opt out of these cookies.
Performance Cookies These cookies collect information about how you use our Website, including which pages you go to most often and if they receive error messages from certain pages. These cookies do not collect information that individually identifies you. Information is only used to improve how the Website functions and performs. From time-to-time, we may engage third parties to track and analyze usage and volume statistical information relating to individuals who visit the Website. We may also utilize Flash cookies for these purposes. To learn how to opt out of performance cookies using your browser settings, click here.
To learn how to manage privacy and storage settings for Flash cookies, click here
Functionality cookies Functionality cookies allow our Website to remember information you have entered or choices you make (such as your username, language, or your region) and provide enhanced, more personal features. These cookies also enable you to optimize your use of the Website after logging in. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customize. We may use local shared objects, also known as Flash cookies, to store your preferences or display content based upon what you view on the Site to personalize your visit. To learn how to opt out of functionality cookies using your browser settings, click here.
To learn how to manage privacy and storage settings for Flash cookies, click here

How We Respond to Do Not Track Signals

California law requires us to let you know how we respond to web browser Do Not Track (DNT) signals. Because there currently is no industry or legal standard for recognizing or honoring DNT signals, we don’t respond to them at this time.

Changes to This Notice

This Privacy Policy may change from time to time. Please check the Website periodically to review such changes to the Privacy Policy.

Contact Us

If you have any questions or concerns about this Privacy Policy or about our privacy or data security practices, please contact us at Info@drawbridgerealty.com (877) 923-2234.

Last Updated on December 9, 2023