Effective November 1, 2021

Secure Living, LLC (“Secure Living”) provides an online marketplace that connects real estate sponsors (i.e. real estate investors, businesses, and developers) to non-accredited investors seeking to gain access to an asset class that often requires a lot of capital. We will operate as an intermediary technology platform under Title III of the JOBS Act, connecting issuers and investors through Regulation Crowdfunding. This privacy policy (our “Privacy Policy”) describes our data practices regarding Personal Information (defined below). This Privacy Policy applies to Personal Information collected through our website, located at www.securelivingrei.com (the “Site”). This Privacy Policy does not apply to any Personal Information collected by third-party websites or apps not operated by Secure Living.

By accessing the Site and/or using our Services, you are consenting to our use of your Personal Information under this Privacy Policy. Further, your access to and use of the Services is subject to the Secure Living Terms of Service located at www.securelivingrei.com.

Information Secure Living 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.

Investors. If you choose to access our Services as an Investor, we require that you complete a registration form. An Investor is an individual who is over the age of 18 and has completed the registration process on the Site. Our registration forms will specify the information which you must provide to enjoy the particular features to which you wish to subscribe, which may include such items as (i) name; (ii) email address; (iii) phone number(s); (iv) mailing address; (v) social security number (for IRS tax reporting purposes); (vi) birth date.

We also require that Investors provide us with certain accounts 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.

Electronic Signature.

I agree that any time I click or have clicked on an “I Agree”, “I Consent” or other similarly worded button or entry field with my mouse, keystroke, or other devices, my agreement or consent is legally binding and enforceable against me and is the legal equivalent of my handwritten signature on an agreement that is printed on paper. I agree to be bound by any affirmation, assent, or agreement that I transmit, or have transmitted, to or through this website (the “Platform”) by computer or other electronic devices, including internet, telephonic and wireless devices, including but not limited to any consent I give or have given to receive communications from securelivingrei.com solely through electronic transmission.

Automatically Collected Information

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 certain 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 concerning 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, etc.;
• 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 enforce this Privacy Policy and our Terms of Service;
• to conduct user surveys and questionnaires; and
• to comply with applicable law.

 

We use the aggregated information to analyze the effectiveness of our Site, to improve our Services, and for other similar purposes. Also, from time to time, we may undertake or commission statistical and other summary analyses of the general behavior and characteristics of users participating in our Services and the characteristics of visitors at our Site. We may collect aggregated information through features of the software that support our Services, through cookies, and other means described in this Privacy Policy.

To enable us to better understand the characteristics of our Investors and/or to provide services tailored to your needs, we may combine the Personal Information an Investor provides with certain automatically-collected information that would not otherwise be personally identifiable. If we combine or link any automatically collected, non-individually identifiable information with your Personal Information, the resulting combination will be treated as Personal Information under this Privacy Policy.

How We Share Personal Data

We do not disclose your Personal Information to unaffiliated third parties except as provided in this Privacy Policy, as follows:

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 in 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 Secure Living 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 Secure Living 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 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, to protect the safety and security of our users or 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. 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. If you do not enable or if you disable cookies, however, you may not be able to access certain personalized features of our Services.

We may also use so-called “pixel tags” – small graphic images (also known as “web beacons” or “single-pixel images”) – to tell us what parts of our website have been visited or to measure the effectiveness of marketing campaigns on our Site. In contrast to cookies, which are stored on a user’s computer hard drive, pixel tags are embedded invisibly on our Site. Pixel tags inform us whether emails have been opened, to help ensure that our messages are of interest to our users. We may tie the information gathered by pixel tags to our users’ Personal Information, in which case it will be subject to the terms of this Privacy Policy.

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. 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 Secure Living. Secure Living 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 website that collects Personal Information.

Data Security

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. 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.

Data Retention

We keep all records including your Personal Information in accordance with Regulation Crowdfunding (“Reg CF”) Rule 404(a).

Your Choices

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 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, investments on the platform and the rights thereof, and 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 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 protected].

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 [email protected]. 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.

Children’s Privacy

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. The 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 [email protected].

Changes to This Privacy Policy

We reserve the right to alter, modify, update, add to, subtract from, or otherwise change this Privacy Policy at any time, which will become effective as of posting on the Site. We encourage you to periodically review this Privacy Policy to stay informed about how we collect, use, and share Personal Information.

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, Secure Living does not share your Personal Information with third parties for their direct marketing purposes.

How We Respond to “Do Not Track” Signals

Our Site currently does not respond to “Do Not Track” (DNT) signals and operates as described in this Privacy Policy whether or not a DNT signal is received. If we do so in the future, we will describe how we do so in this Privacy Policy.

Contact Us

If you have any questions about this Privacy Policy, the practices of our Site or Services, or your dealings with our Site or Services, please contact us at: [email protected].