Effective November 1, 2021
Information DiversyFund 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 your name, address, email address, birth date, financial information, cell or land-line phone number, or any combination of information that could be used to identify you.
What Personal Information we collect from you depends on what Services you choose to use and how you interact with the Site:
Site Visitors. We have structured our Site so that, as a casual site visitor, you may come to our Site and review selected information about our Services 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.
We also may require each Investor to provide certain “know your customer” information for regulatory compliance purposes such as investment objectives, financial goals, income and net worth information and investment experience.
Users also may choose to upload media files such as videos, photos, text, and other content to the Site to share with DiversyFund and other users. When you upload this content, we may also collect metadata associated with these media files including date, time, location and device information. DiversyFund’s use of such content will be governed by our user-generated terms and conditions which are provided at the time of collection of such content.
Location Data. We may collect your location information through our mobile applications by capturing the location (e.g. latitude/longitude) of your mobile device. If you have given the app permission to access your location, we may collect your device’s location even if you are not using the Service and store your location history. If you want to opt-out of the collection of your location data, please adjust your settings in your mobile device to restrict the app’s access to your location data. Geolocation data may be used to enhance the Services, for example to offer additional functionality and information regarding your location in connection with the location of DiversyFund properties.
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:
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:
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, compliance and audit services, email communication and customer support services, analytics, marketing, and advertising service providers (including Google, Facebook, Instagram and Zendesk among others), which companies provide integrated services to us as part of our product.
IRA. We team up with third-party custodians to allow you to invest your IRA funds in diversified alternatives such as commercial real estate investments. These parties are not affiliated with DiversyFund, but act as a directed custodian for IRAs and other custodial accounts. If you elect to initiate the opening of a self-directed IRA account with DiversyFund, we streamline the enrollment process by sharing certain Personal Information with these custodians, including but not limited to your name, Social Security number, date of birth, and contact information. You are not required to invest your IRA funds as a condition of using the Services.
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 DiversyFund 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 DiversyFund 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:
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 DiversyFund. DiversyFund 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. 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:
Any deletion requests may be sent to hello@DiversyFund.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 hello@DiversyFund.com. Please understand that you will not be allowed to opt-out of transactional notices or other legal and related notices concerning your relationship to the Site or your account.
Our Site is not directed to children under the age of 18. 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 email us at hello@DiversyFund.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, DiversyFund 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:
You may contact us by mail as follows:
750 B Street, Suite 1930
San Diego, CA 92101
GLBA Privacy Notice
November 1, 2021
|FACTS||WHAT DOES DIVERSYFUND, INC. AND DIVERSY ADVISORY SERVICES, LLC (COLLECTIVELY, “DIVERSYFUND”) DO WITH YOUR PERSONAL INFORMATION?|
|Why?||Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.|
|What?||The types of personal information we collect and share depend on the product or service you have with us. This information can include:
• Social Security number and income
• Investment experience and assets
• Account transactions and checking account information
When you are no longer our customer, we continue to share your information as described in this notice.
|How?||All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons DiversyFund chooses to share; and whether you can limit this sharing.|
|Reasons we can share your personal information||Does DiversyFund share?||Can you limit this sharing?|
|For our everyday business purposes —
such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus
|For our marketing purposes —
to offer our products and services to you
|For joint marketing with other ﬁnancial companies||No||We don’t share|
|For our affliates’ everyday business purposes — information about your transactions and experiences||Yes||No|
|For our affliates’ everyday business purposes — information about your creditworthiness||No||We don’t share|
|For our afﬁliates to market to you||No||We don’t share|
|For nonafﬁliates to market to you||No||We don’t share|
|Questions?||Email email@example.com or go to www.diversyfund.com|
|Who is providing this notice?||This notice is being provided on behalf of DiversyFund, Inc., Diversy Advisory Services, LLC and their affiliated companies. A list of DiversyFund affiliated companies is located at the end of this document.|
|How does DiversyFund
protect my personal information?
|To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured ﬁles and buildings.|
|How does DiversyFund
collect my personal information?
|We collect your personal information, for example, when you
We also collect your personal information from others, such as credit bureaus, affiliates, or other companies.
|Why can’t I limit all sharing?||Federal law gives you the right to limit only
State laws and individual companies may give you additional rights to limit sharing. See below for more on your rights under state law.
|Affiliates||Companies related by common ownership or control. They can be ﬁnancial and nonﬁnancial companies.
|Nonaffiliates||Companies not related by common ownership or control. They can be ﬁnancial and nonﬁnancial companies.
|Joint marketing||A formal agreement between nonafﬁliated ﬁnancial companies that together market ﬁnancial products or services to you.
|Other important information|
|California Residents Only: Under California law, we will not share information we collect about you with nonaffiliates unless the law allows. For example, we may share information with your consent, to service your accounts. We will limit sharing among our affiliates to the extent required by California law.|
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