Privacy policy

 


1. Introduction

This Privacy Policy describes the types of information that Inception REIT, Inc. (the "Company", “I-REIT”, “our”, "we" or “us”) may collect from you or that you may provide when you visit the Website http://inceptionreit.com (the "Website") and our practices for collecting, using, maintaining, protecting, and disclosing that information.  This Privacy Policy is a part of and subject to our Terms and Conditions. 

This Privacy Policy applies to information we collect:

·                  On this Website.

·                  In email, text, and other electronic messages between you and us through this Website.

·                  When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this Privacy Policy.

This Privacy Policy does not apply to information collected by:

·                  I-REIT, offline or through any other means, including on any other website operated by us or any third party (including our affiliates and subsidiaries);

·                  Information made available in a credit report we may obtain about you; or

·                  Any third party, including through any application or content that may link to or be accessible from or on the Website

Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to access or use our Website. By accessing or using this Website, you agree to this Privacy Policy.

This Privacy Policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this Website after we make changes is deemed to be your acceptance of those changes, so please check this Privacy Policy for updates.


2. Information We Collect About You and How We Collect It

We collect several types of information from and about users of our Website, including information:

·                  By which you may be personally identified, such as name, postal address, e-mail address, telephone number, social security number, financial information related to your status as an accredited investor as described in the Memorandum, information about your business or project, or any other information you provide or the Website collects that may be “personal” or “personally identifiable information” under applicable law ("personal information");

·                  That is about you but individually does not identify you; and/or

·                  About your internet connection, the equipment you use to access our Website, and usage details.

We collect this information:

·                  Directly from you when you provide it to us.

·                  From a third party service provider or professional who delivers information to us on your behalf pursuant to procedures described in the Memorandum (see “Investor Verification Process”).

·                  Automatically as you navigate through the Website.  Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.

·                  From third parties including, for example, entities with which we have a business or commercial relationship.

Information You Provide to Us

The information we collect on or through our Website may include:

·                  Information that you provide by filling in forms on our Website, including information you upload to our Website and information you provide at the time you register to use our Website, subscribe to our services, post material, or request further services. 

·                  Information you provide when you have questions about or report a problem with our Website.

·                  Your responses to information requests or surveys we may ask you to complete.

·                  Information provided by a third party on your behalf (including, for example, financial information related to your status as an “accredited investor” or other information about you, your business or your project).

·                  Records and copies of your correspondence (including email addresses), if you contact us.

·                  Communications and details of transactions you carry out through our Website.

·                  Your search queries on the Website.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

·                  Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.

·                  Information about your computer and internet connection, including your IP address, operating system, and browser type.

We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). Please read below for information on how you can opt out of behavioral tracking on this website and how we respond to web browser signals and other mechanisms that enable consumers to exercise choice about behavioral tracking.

The information we collect automatically is statistical data and may include personal information, and we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

·                  Estimate our audience size and usage patterns.

·                  Store information about your preferences, allowing us to customize our Website according to your individual interests.

·                  Speed up your searches.

·                  Recognize you when you return to our Website.

The technologies we use for this automatic data collection may include:

·                  Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.

 

·                  Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information.

 

·                  Web Beacons. Pages of our the Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related Website statistics (for example, verifying system and server integrity).

We do not collect personal information automatically, but we may tie this information to personal information about you that we collect from other sources or you provide to us.

Third Party Use of Cookies and Other Tracking Technologies

Some content or applications, including advertisements, on the Website are served by third-parties, including content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.

 

3. Third Party Use of Cookies and Other Tracking Technologies

Some content or applications, including advertisements, on the Website are served by third-parties, including content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.

 

4. How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

·                  To present our Website and its contents to you.

·                  To provide you with information, services or investment products that you request from us.

·                  To confirm your status as an accredited investor.

·                  To provide you with notices about your account.

·                  To allow you to participate in interactive features on our Website.

·                  To fulfill any other purpose for which you provide it.

·                  To carry out our obligations and enforce our rights arising from any contracts entered into between you and us.

·                  To notify you about changes to our Website or any investment products or services we offer or provide though it.

·                  In any other way we may describe when you provide the information.

·                  For any other purpose with your consent.

We may also use your information to contact you about our services or investment products that may be of interest to you. If you do not want us to use your information in this way, please check the relevant box located on the form on which we collect your data or contact us to be removed from our database (or unsubscribe). For more information, see Choices About How We Use and Disclose Your Information.  We may use the information we have collected from you to enable us to display information or promotional material to our business partners’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with such a promotional feature, the sponsor of that material may assume that you meet its target criteria.


5. Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this Privacy Policy:

·                  To our subsidiaries and affiliates.

·                  To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.

·                  To a buyer or other successor of our business resulting from sale of assets or stock, merger, reorganization, or dissolution, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by I-REIT about our Website users is among the assets transferred.

·                  To third parties to promote their products or services to you if you have not opted out of these disclosures.

·                  To fulfill the purpose for which you provide it.

·                  For any other purpose disclosed by us when you provide the information.

·                  With your consent.

We may also disclose your personal information:

·                  To comply with any court order, law, or legal requirement, including to respond to any government, court or regulatory request.

·                  To enforce or apply our Terms and Conditions and other agreements, including for billing and collection purposes.

·                  If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of I-REIT, our customers, or others. This may include exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.


6. Choices About How We Use and Disclose Your Information

We have created mechanisms to provide you with the following control over your information:

·                  Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe's website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.

·                  Disclosure of Your Information for Third-Party Advertising. If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt out by logging into the Website and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes, or by sending us an email stating your request to info@inceptionreit.com.

·                  Promotional Offers from I-REIT. If you do not wish to have your contact information used by I-REIT to promote our own or third parties' products or services, you can opt out by logging into the Website and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes, or by sending us an email stating your request to info@inceptionreit.com. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. This opt out does not apply to information provided to I-REIT as a result of a product purchase, warranty registration, product service experience, or other transactions.

·                  Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver promotional material according to our advertisers' target-audience preferences, you can opt out by logging into the Website and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes or by sending us an email stating your request to info@inceptionreit.com.

We do not control third parties' collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way.  Third party ad networks may be members of either the Network Advertising Initiative (“NAI”) or About Ads-Digital Advertising Alliance (“DAI”). If they are members and you do not want to receive targeted advertisements from these third-party ad networks, you may opt out. Information as to member companies, the practices of such third-party ad networks and your choices regarding having information used by these companies, including how to opt out, can be found at either: http://www.networkadvertising.org/optout_nonppii.asp for NAI members or http://www.aboutads.info/choices/ for DAI members. Information on how to opt out of the use of your information by DoubleClick is available at http://www.google.com/policies/technologies/ads/ and information on how to opt out of Google Analytics is available at https://tools.google.com/dlpage/gaoptout.

Opting out of one or more NAI or DAI members means that only those particular members will no longer deliver targeted content or ads to you. It does not mean you will no longer receive any targeted content or ads on our websites or other non-United websites. If your browser is configured to reject cookies when you visit one of the above referenced opt-out pages and then you erase your cookies, use a different computer or change web browsers, your NAI or DAI opt-out may no longer be active.


7. Accessing and Correcting Your Information

You can review and change your personal information by logging into the Website and visiting your account profile page.

You may also send us an email at info@inceptionreit.com to request access to, correct or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.


8. Your California Privacy Rights

California Civil Code Section § 1798.83 permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to info@inceptionreit.com or write us at: 345 N Maple Dr., Ste 298, Beverly Hills, CA 90210.


9.    Data Security

I-REIT maintains physical, electronic and procedural safeguards designed to protect your information. Although we take reasonable steps to safeguard and to prevent unauthorized access to your personal information, we cannot be responsible for the acts of those who gain unauthorized access to it.  I-REIT makes no warranty, express, implied, or otherwise, that we will prevent unauthorized access to your personal information. 

The safety and security of your information also depends on you.  Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. You should not share your password with anyone. You should also, among other prudent steps, keep your computer equipment and virus protection software updated, use only secure websites, and be alert to phishing scams and other nefarious online activities.

In addition, the transmission of information via the internet is not completely secure. We cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.


10.  Permitted Users of the Website

Our Website is not intended for persons under 18 years of age. No one under age 18 is permitted to use this Website and no such person may provide any information to the Website.

Our Website is also intended for use only by residents of the United States.  If you are a non-U.S. person or a resident of a jurisdiction other than the United States, please contact us directly by calling or writing to us at the address below.


11.   Changes to Our Privacy Policy

It is our policy to post any changes we make to our Privacy Policy on this page.  We may also, but are not required to, post a notice that the Privacy Policy has been updated on the Website home page. If we make material changes to how we treat our users' personal information, we will notify you by email to the primary email address specified in your account and/or through a notice on the Website home page. The date the Privacy Policy was “last revised” is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for visiting our Website and reviewing this Privacy Policy to check for any changes.


12.   Contact Information

To ask questions or comment about this Privacy Policy and our privacy practices, contact us at:

Inception REIT, INC 345 N Maple Ave Ste 298, Beverly Hills, CA 90210

info@inceptionreit.com  

or via our phone number: 213-910-4142

Please reference this Privacy Policy in those communications.