Effective February 21, 2022
Information RAD Collects About You
Personal Information You Provide
We use the term “Personal Information” to mean any information that could be used to identify you, including, but not limited to, your name, postal address, email address, birth date, social security number, financial information, mobile or land-line telephone number, or any combination of information that could be used to identify you.
What Personal Information we collect from you depends on what how you interact with the Site:
Site Visitors. We have structured our Site so that, as a casual site visitor, you may visit our Site and review selected information about us without registering. However, if you wish to become an Investor, then we require you to provide certain additional Personal Information.
We may require each Investor to provide information designed to verify his or her identity. This information may include (i) information from a successfully completed electronic check transaction, (ii) a credit report, or (iii) other similar information designed to authenticate and confirm your identity or to otherwise comply with applicable law.
We also require each Investor to provide certain financial information. For example, we require that each Investor also provide Internal Revenue Service Form W-9 data, which includes your Social Security Number (or Taxpayer Identification Number, where applicable). We also require that Investors provide us with certain account and other payment information, such as information needed to make payments via ACH, wire, or electronic checks. Our registration process for Investors provides additional details on the types of payment information needed.
Even if you do not register for an account on the Site, we may collect certain information automatically. For example, we may automatically receive and record in our system the following information:
- your internet protocol (IP) address and location;
- referrer URL;
- the type and version of your web browser;
- device identifiers including mobile advertising identifiers; and
- your operating system.
We also record page views and other general statistical and tracking information. We use this data to help us administer and operate our Site, to better understand how our users access and interact with the Site, and for security and monitoring purposes.
We may send email messages that use a “click-through URL” linked to content on our Site. When you click one of these URLs, you pass through our web server before arriving at the destination web page. We track this click-through data to help determine interest in particular topics and measure the effectiveness of our customer communications. If you prefer not to be tracked, simply do not click text or graphic links in the email.
How We Use Your Personal Information
We use your Personal Information for the following business purposes:
- to process transactions that you have authorized us to make;
- to facilitate your activities with respect to our Site;
- to contact you regarding administrative issues, such as questions about your specific request, or otherwise respond to your comments or requests;
- to verify and authenticate your identity, to help us ensure that the individuals who use the Site and Services are who they claim to be;
- to prevent, detect, mitigate, and investigate fraud, security breaches, and potentially prohibited or illegal activities, including, for example, activities prohibited by the Anti-Money Laundering Act;
- to help us operate our Site;
- to deliver notices regarding your account;
- to comply with IRS requirements and for tax reporting purposes;
- to provide you with information, such as notices of investment opportunities via our Site or updates concerning investments that you have participated in;
- to send you information we believe is relevant to you, such as news, bulletins, marketing materials, or other information;
- to conduct user surveys and questionnaires; and
- to comply with applicable law.
How We Share Personal Data
Service Providers. To assist us in running our business and to perform certain services and functions, we may share your Personal Information with third-party providers of hosting, payment processing, transfer agent, email communication and customer support services, analytics, marketing, and advertising service providers (including DealMaker, Google, Facebook, Instagram, InfusionSoft, OfferBoard among others), which companies provide integrated services to us as part of our product.
For Legal Reasons. We may share your Personal Information to the extent we reasonably believe we are required to do so by law or to comply with legal or regulatory requirements, or to protect against fraud, illegal activity, or to otherwise protect RAD against liability.
In Connection with a Corporate Transaction. In the event of a transaction or proposed transaction involving the transfer of substantially all of the assets of RAD or one or more of its businesses to another entity, whether an affiliate or a third party, or in connection with a bankruptcy, we may share your Personal Information in the diligence process or to otherwise facilitate the transaction, and with individuals assisting in the transaction or in connection with a bankruptcy. Your Personal Information may also be one of the transferred assets as part of the transaction or bankruptcy.
For Safety & Security. We may reveal your Personal Information to third parties, including law enforcement agencies, in order to protect the safety and security of our users or of any third party.
Cookies, Pixel Tags, and Similar Technologies
A cookie is a small amount of data, often including a unique identifier, which is sent to your browser from a website and stored on your computer’s hard drive.
We use both “session” cookies and “persistent” cookies, as follows:
Session cookies: We use session cookies to improve navigation on our Site and to collect aggregate statistical information. A session cookie expires when you close your browser. Because these cookies are strictly necessary to use the Site, you cannot refuse them.
“Persistent” cookies: Persistent cookies are bits of information that are placed on the hard drive of your computer and can remain for extended periods of time. Persistent cookies also enable us to provide enhanced, more personal features (such as showing or hiding notifications), and track and target the interests of our users to enhance the experience on our Site. The types of persistent cookies used on the Site are described in more detail below. You may set your browser so that it does not accept cookies, and you may also use the direct opt-out tools provided by the parties described below. If you do not enable or if you disable cookies, however, you may not be able to access certain personalized features of our Services.
In particular, the Site uses:
about your use of the Site will be transmitted to, and stored by, Google. Google will use this information for the purpose of evaluating your use of the Site, compiling reports on Site activity for Site operators and providing other services relating to Site activity and internet usage, including tracking which pages of our Site you visit so we can optimize your experience with our Site. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. We have implemented the IP anonymization feature in Google Analytics which anonymizes your IP address to protect individual privacy. You can opt-out from the collection of this information by Google by downloading and installing a browser plug-in at https://tools.google.com/dlpage/gaoptout. For more information on Google Analytics privacy practices, read here and, for information on Google Analytics cookies expiration, read here.
● Third party advertising cookies and pixels, in connection with our marketing programs, including Google, Facebook, Twitter, among others. We do not use such tools for marketing or re-targeting purposes in relation to users located outside the U.S. You may find more information on what cookies and similar technologies have been set and how to manage and delete them at http://preferences- mgr.truste.com in the United States, or at the European Digital Advertising Alliance’s site http://www.youronlinechoices.eu/ in Europe. For more information on advertising cookies, please also consult the Network Advertising Initiative’s online resources at http://www.networkadvertising.org. If you do not want Twitter specifically to show you interest- based advertising on and off Twitter, you can visit your Twitter settings under Personalization and data, or visit the Digital Advertising Alliance’s consumer choice tool at optout.aboutads.info. If you do not want Facebook to show you interest-based advertising, you can visit Facebook settings under Your Ad Preferences on Facebook.
Feedback, Questionnaires and Surveys.
Our Site allows site visitors and Investors to participate in surveys and questionnaires, which from time to time we may post on the Site. We also encourage our users to provide feedback to us about our Site and our Services. You are free to choose whether you participate in these activities. We may ask that, in addition to providing your responses, you also provide us with your contact information. In these instances, we use any Personal Information you choose to provide to us in connection with these activities for the purposes for which you submit the information.
We aggregate information derived from survey and questionnaire information – with your Personal Information removed – for monitoring or improving the use and appeal of this Site (with no other obligation to you and, specifically, with no obligation to compensate you for these uses). You are not obligated to participate in any of these activities.
Links to Other Sites
This privacy statement applies only to Personal Information collected by our Site. Our Site contains links to other sites that are not owned or controlled by RAD. RAD is not responsible for the privacy practices of such other sites, and we encourage you to be aware when you leave our Site and to read the privacy statements of each and every web site that collects Personal Information.
We have put in place commercially-reasonable security systems intended to prevent unauthorized access to or disclosure of Personal Information, and we take reasonable steps to secure and safeguard this Personal Information against loss, theft, and unauthorized use, disclosure, or modification. With that said, there is no such thing as 100% security of the networks, servers, and databases we operate or that are operated on our behalf. For example, email sent to or from the Site may not be secure. Before submitting any Personal Information via the Site, please be aware of these inherent risks and understand that you do so at your own risk.
In general, you may browse the Site without providing Personal Information. However, if you choose not to provide certain Personal Information through our Site, we may not be able to provide certain services or process certain of your requests, and you will not be able to become an Investor or use all of the features and products that we offer through this Site.
Depending on the functionality associated with the Site feature you are using, you may be able to update or delete certain of your Personal Information on the Site. Accordingly, at your request, we will take reasonable steps to remove your Personal Information from our databases. However, please note that:
- we may not be permitted to delete your Personal Information completely, due to IRS and regulatory reporting requirements relating to investments on the platform and the rights and obligations pertaining thereto, and relating to data backups and records of deletions;
- if you request deletion of your Personal Information, you may be unable to use certain features of the Site and any associated services;
- certain of your Personal Information may remain in our databases following the deletion of your account; and
- we may not be able to remove de-identified, anonymous, or aggregate data from our databases. Any deletion requests may be sent to email@example.com].
If you no longer wish to receive marketing emails from us, you can opt out of these communications by clicking on the “unsubscribe” link included in those emails, or by contacting us at firstname.lastname@example.org. Please understand that you will not be allowed to opt-out of transactional notices or other legal and related notices concerning your investor or business relationship with RAD, your account with us, or interaction with this Site.
Our Site is not directed to children under the age of 13. We do not knowingly seek to collect or maintain Personal Information or other information from children under the age of 18. We will use commercially reasonable efforts to delete any Personal Information or other information later determined to be provided by a child under the age of 18. Use of the Site by children under the age of 18 is not permitted. If you become aware that a minor has provided Personal Information through our Site, please contact us immediately by email at email@example.com.
Your California Privacy Rights
“Shine the Light” Law
California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their Personal Information (if any) for such third parties’ direct marketing purposes in the prior calendar year, as well as the type of Personal Information disclosed to those parties. However, RAD does not share your Personal Information with third parties for their direct marketing purposes.
How We Respond to “Do Not Track” Signals
You may contact us, for any reason, by email as follows: firstname.lastname@example.org
You may contact us by mail as follows:
RAD Diversified REIT, Inc.
211 N. Lois Ave.,
Tampa, FL 33609