PRIVACY POLICY

LAST UPDATED JULY 8, 2019

WE RESPECT YOUR PRIVACY

We take your privacy seriously and do our best to protect your personal information. Below is an overview of some core components of our data handling practices. Please be sure to review the full Privacy Policy below.

• We don't ask you for personal information unless we need it.
• We don't share your personal information with anyone except as described in this Privacy Policy.
• 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.
• We will send you emails relating to specific transactions but will keep these emails to a minimum.
• We will maintain appropriate security standards and procedures to protect your information.
• 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

IIRR Management Services, LLC, (hereinafter, “IIRR”, “we”, “us”, and/or “our”) has created this Privacy Policy to explain how we collect, store, use and protect your personal information when you use access www.realtyshares.com for which IIRR provides management services, or use its financial matchmaking services (collectively “Services”) including, but not limited to, investment managers offering an investment (the “Issuer (s)” or “Manager (s)”) and investors using the site to invest (in each case, a “User”, and collectively, “Users”).

This Privacy Policy is incorporated into, and considered a part of, the Terms of Service. Please carefully review this Privacy Policy and our Terms of Service as they govern the collection of information and use of the Services we offer. By using the Services, you are giving us permission to use and store such information consistent with this Privacy Policy and the Terms of Service.

By accessing or using our Services, you signify acceptance to the terms of this Privacy Policy and consent to the collection, use, and disclosure of your personal information as described below. If you do not agree with or you are not comfortable with any aspect of this Privacy Policy or our Terms of Service, you should immediately discontinue access or use of our Services.

CHANGES TO THIS PRIVACY POLICY

We reserve the right to modify this Privacy Policy at any time, and when required by law, we will notify you of changes to this Privacy Policy. If we make any materials changes we will notify you by email or by means of a notice on our Service prior to the change becoming effective.

We may provide additional “just-in-time” disclosures or additional information about data collection, use and sharing practices specific Services. These notices may supplement or clarify our privacy practices or may provide you with additional choices about how we process your personal information.

We encourage you to review this Privacy Policy periodically. If you have any questions you can contact us at support@iirrms.com.

PERSONAL INFORMATION WE COLLECT

Personal information is data that can be used to identify you directly or indirectly, or to contact you (“Personal Information”). This Privacy Policy does not apply to anonymized or aggregated data as it cannot be used to identify you.

We collect Personal Information to provide you with our Services. When we require certain Personal Information from Users it is because we are required by applicable law to collect this information or it is relevant for specified purposes. You are free to choose whether to provide us with the types of Personal Information requested, but we may not be able to serve you as effectively or offer you all our Services when you do choose not to share certain information with us.

When you access or use our Services, we may collect and process the following types of information:

1. Information You Provide to Us. We collect Personal Information that you voluntarily provide to us. 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. For example, this information may be collected when you:
   
   • register for access to the Services (for example, contact information such as your name, email address, phone number, mailing address);
   • complete certain forms;
   • upload or submit any material;
   • request any information or contact us with inquiries; or
   • 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).
2. Information from Third Party Sources. From time to time, we may obtain information about you from third party sources as required or permitted by applicable law, such as public databases, credit bureaus, ID verification partners, resellers and channel partners, joint marketing partners, and social media platforms. We may also obtain your Personal Information from your transactions with us or other Users through the Services. 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.

HOW YOUR PERSONAL INFORMATION IS USED

We will not use your Personal Information for purposes other than those purposes described in this Privacy Policy without your permission. Examples of how we will use your Personal Information include:

• To identify you when you sign-in to your account;
• To enable us to provide you with the Services;
• To send you information we think you may find useful or which you have requested from us;
• To 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;
• To notify an Issuer of your interest in the event you indicate an interest in making an investment with the Issuer through the Services;
• To administer your account with us;
• To enable us to contact you regarding any question you make through the Services;
• To analyze the use of the Services and the people visiting to improve our content and Services;
• To use for other purposes that we may disclose to you when we request your information.

In addition, IIRR 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. IIRR and its subsidiaries and affiliates may also use this information to communicate with you regarding the Services and/or other services such parties may offer.

SHARING YOUR INFORMATION & THIRD PARTY SERVICES

We limit the sharing of your Personal Information and strive to keep your Personal Information private and confidential. We may share or collect your Personal Information in collaboration with our third party service providers (“Partners”), including companies that assist with payment processing, business analytics, data processing, account management, and other services. We instruct these Partners to not use your Personal Information themselves or share it with another party not under a similar contract to provide service to us, and to only use your Personal Information for the specific services we have requested for us or on your behalf.

We do not sell, license, lease or otherwise disclose your Personal Information to any unaffiliated third party for any reason, except as follows:

• 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.
• 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 and must abide by this Privacy Policy. For example, we may provide your Personal Information to RealtyShares Inc. so they assist us in providing account management services to you.
• 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.
• In the event you indicate an interest in making an investment through our Services, we will notify the Issuer of your interest and will provide your Personal Information to the Issuer.
• 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.
• We may share your information with companies or other entities that we plan to merge with or be acquired by. Should such a combination occur, we will require that the new combined entity follow this Privacy Policy with respect to your Personal Information. You will receive prior notice of any change in applicable policies.
• We may share your information with companies or other entities that purchase our assets pursuant to a court-approved sale under U.S. Bankruptcy law.

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 we share that information includes:

1. Additional Accreditation Verification Measures. In addition to the information you provide to us, under certain circumstances, federal law may require us 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 we 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. We will pay the service provider's fees and costs for this service. We 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 us declining to accept your investment subscription.
2. Potential Disclosure of Your Information to Related Transaction Parties. As part of the consummation of, or continued participation in, the investment project or the related transactions contemplated hereunder, 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 us to share your information, including, without limitation, your name, investment amount, 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. We only share your information with Related Transaction Parties in accordance with this Privacy Policy.
3. Ongoing Compliance with Governmental Requirements. 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 us to obtain additional information from you. 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 our part.

You may opt out of having your Personal Information shared with third parties, or from allowing us to use your Personal Information for any purpose that is incompatible with the purposes for which we originally collected it or subsequently obtained your authorization. If you choose to so limit the use of your Personal Information, certain features or Services may not be available to you.

COOKIES & INFORMATION COLLECTED AUTOMATICALLY

As is the case with most websites, when you interact with our website or use our Services (and whether or not you register for access to the Services), we receive and store certain types of information automatically. This information includes, but it is not limited to:

• browser type;
• IP address;
• language preference;
• cookies; domain servers;
• URL traffic to, through and from the website;
• types of computers and operating systems accessing the website;
• statistical information about behavior of visitors/users to the website; and
• any other web site usage information that we may collect when you visit the website or use the Services.

We may store such information or such information may be included in databases owned and maintained by our affiliates, agents or service providers. We 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 Services, we often conduct research on our customer demographics, interests and behavior based on the Personal Information and other information provided to us by Issuers and Users.

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. We use 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 website, 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 Services, then we know that the cookie information relates to you.

Some of the cookies used by our Services are served by us (“first party cookies”), and some are served by third parties who are delivering services on our behalf (“third party cookies”). The parties that set third party cookies can recognize your computer both when it visits our website and when it visits certain other websites.

We treat information collected by cookies and other technologies as non-personal information. However, to the extent that IP addresses or similar identifiers are considered personal information by local law, we treat these identifiers as personal information.

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 have the right to decide whether to accept cookies. You can exercise your preferences in relation to cookies served on our Sites by taking the steps outlined below.

• Our Cookies (or, "First-Party Cookies"). You can use the browser with which you are viewing this website to enable, disable or delete cookies. To do this, follow the instructions provided by your browser (usually located within the "Help", "Tools" or "Edit" settings). Please note, if you set your browser to disable cookies, you may not be able to access secure areas of our website. Also, if you disable cookies other parts of the Services may not work properly.
• Third-Party Cookies. To opt-out of third-party advertising networks and similar entities that use targeting/advertising cookies, go to http://www.aboutads.info/choices. Once you click the link, you may choose to opt-out of such advertising from all participating advertising companies or only advertising provided by specific advertising entities. For Google Analytics, you may opt out by going to: https:// tools.google.com/dlpage/gaoptout.
• Do Not Track: Some Internet browsers - like Internet Explorer, Firefox, and Safari - include the ability to transmit "Do Not Track" or "DNT" signals. Since uniform standards for "DNT" signals have not been adopted, our website does not currently process or respond to "DNT" signals.

SAFEGUARDING USER INFORMATION

The security of your Personal 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:

• Encryption and authentication tools to maintain the confidentiality of User Information including Transport Layer Security technology (TLS) encryption certificates provided by Comodo CA Limited (SHA-256 With RSA Encryption);
• 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;
• Redundant systems to monitor our server infrastructure in real-time with web-based and server applications reporting and instant notification to the appropriate staff for any remediation; and
• The use of cookies to help recognize you as a repeat visitor and to track Site traffic patterns.

However, despite these efforts, we cannot guarantee that loss, misuse, unauthorized acquisition, or alteration of your information will not occur. Please recognize that you play a vital role in protecting your own Personal Information. When registering with our Services, it is important to choose a password of sufficient length and complexity, to not reveal this password to any third-parties, and to immediately notify us if you become aware of any unauthorized access to or use 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 the website 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.

We cannot ensure or warrant the security or confidentiality of information you transmit to us or receive from us by internet or wireless connection, including email, phone, or SMS, since we have no way of protecting that information once it leaves and until it reaches us. If you have reason to believe that your information is no longer secure, please contact us at the email address, mailing address or telephone number listed at the end of this Privacy Policy.

COMMUNICATIONS

Regarding email contact with and from us, 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 news. It is your responsibility to ensure that you maintain a current email address with us, and notify us if there are any changes.

HOW YOU CAN ACCESS, CHANGE, OR DELETE YOUR PERSONAL INFORMATION

You are solely responsible for helping us to maintain the accuracy and completeness of your Personal Information. We urge you to review your information regularly to ensure that it is correct and complete.

You are entitled to review, correct, or amend your Personal Information where it is inaccurate or delete your Personal Information. You may also 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. 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.

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. You can also request deletion or correction of your Personal Information by contacting us at support@iirrms.com. We will retain your Personal Information for as long as your account is active or as needed to provide you Services, and we may continue to retain such Personal Information beyond your active use of our platform.

PUBLIC INFORMATION

Please keep in mind that any information you post on portions of the 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 support@iirrms.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 Services nor the information or content contained therein (collectively “Third Party Sites”). Please remember that when you use a link to go from our Services 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 Services, is subject to that Third Party Site’s rules and policies. We encourage you to review the Third Party Site’s rules and policies before proceeding.

INTERNATIONAL USERS

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. By providing your Personal Information on or through the Services you recognize such transfer of your Personal Information to the United States is necessary for the performance of the Services, as outlined in the Terms of Service, and/or to comply with applicable laws, and you do not object to such transfer.

CHILDREN'S PERSONAL INFORMATION

We do not knowingly collect Personal Information from children under the age of 18 without the consent of their legal guardian. If you are under the age of 18, please do not submit any Personal Information through the Services. 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 our website without their permission. If you are a parent or guardian and discover that your child under the age of 18 has a registered account with the Services or that we have received any Personal Information of that child without your consent, please notify us, and we will endeavor to delete that information from our databases and to prevent access to our Services.

CALIFORNIA PRIVACY RIGHTS

If you are a California resident, you have the right to request information from us regarding the manner in which we share certain categories of your Personal Information with third parties for the third parties' direct marketing purposes. California law provides that you have the right to submit a request to us at our designated address and receive the following information: (a) the categories of information we disclosed to third parties for the third parties' direct marketing purposes during the preceding calendar year; and (b) the names and addresses of third parties that received such information, or if the nature of their business cannot be determined from the name, then examples of the products or services marketed. You are entitled to receive a copy of this information in a standardized format and the information will not be specific to you individually. You may make such a request by emailing support@iirrms.com.

HOW TO CONTACT US

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