- “Affiliate” means an entity that controls, is controlled by, or is under common control with the Company, whether the control results from equity ownership, contract, overlapping management, or otherwise.
- “Content” refers to all text, images, photographs, graphics, logos, illustrations, descriptions, data, tools, features, pages, and other materials provided on the Site, as well as the selection, assembly, arrangement, “look and feel,” and design of our Site.
- “Services” the Content, products, or services offered on or through the Site.
- “Site” refers to, together and collectively, the domains and subdomains of our website at retokens.com.
- “Token” means a token that is a digital representation of indirect ownership in real estate.
- “User” means anyone who accesses and/or uses any of our Site or Services.
- “We,” “us,” and “our” refer to the Company and its Affiliates.
Changes to this Policy
PERSONAL INFORMATION WE COLLECT
To help us to provide Services, we collect personal information about you through several means.
How We Collect Personal Information
Direct Means. We collect personal information from you directly by asking you for it when you open an account or in other instances when you contact us or access or use any of our Site or Services. In fact, various laws require that we collect some of the kinds of personal information we ask for, such as anti-fraud / anti-money laundering laws and “Know Your Customer” obligations. In addition to personal information that we are required to obtain from you by law, we may ask you for other personal information that you can choose, at your option, provide or withhold, and any such information provided will be subject to this policy.
Automatic or Passive Means. Whenever you visit, use, access, or interact with any of our Site or Services, we use “cookies” and tracking technologies (further explained below) to collect data about you and your activities on our Site or use of our Services automatically or passively. These cookies help us better understand how our users navigate through our Site, learn what content is being viewed, and administer and improve our Site. Cookies are small text files that web servers place on an internet user’s computer or mobile device that are designed to store basic information and to recognize your browser or mobile device.
Third-Party Sources. We may obtain information about you from various third parties, including: (1) service providers we engage to conduct certain functions on our behalf, such as to verify the identities of the Users of our Services or Site; (2) analytics providers, who we use to assist us better understand who is using our Site and Services; and (3) advertising, social media and market research providers and partners whom we engage or with whom we partner for advertising, social media or market research services, as well as for referral purposes.
Types of Information We Collect
The type of personal information we collect from and about you online will depend on how you interact with us. The personal information we collect from or about you may include, but may not be limited to, the following:
- Your name, residential and business address, email address, citizenship, telephone number, Social Security Number, date of birth, your employment status and employer.
- Copies of your correspondence via email, phone, or social media, if you contact us.
- Information needed to grant us access to your accounts on third-party websites or applications (“Third-Party Site”). The personal information collected from the Third-Party Site may be used to register your User account and to provide some of our services.
- Your username and password.
- Information that is about you individually but that does not identify you, such as your investment history and experience, investment portfolio, and your educational or professional history.
Personal Financial Information
When you subscribe to make an investment in one of the offerings available on the Site, you will again be asked for personal information. To help facilitate the subscription process, you will also be required to provide personal financial information, including, but not limited to:
If you choose to invest through our Site, we may collect information including, but not limited to:
- Financial information, including your social security number, income, and net worth.
- Information to confirm your place of residence.
- Information about your bank accounts or other sources of payment.
- Your blockchain wallet address, wallet type, Token reference information, and date/time stamps.
- Information to confirm your relationship with other parties associated with the Site or our Services.
- Your investment experience, objectives, and preference, as well as information to establish whether or not you are an “accredited investor.”
- Access credentials you establish to receive our Services or access our Site.
- Information about your relationship to or ownership in any entity that uses our Services.
- Your preferences for receiving, and how you engage with, our marketing communications.
We collect data from activity that is publicly visible and/or accessible on blockchains. This may include blockchain addresses and information regarding purchases, sales, or transfers of Tokens, which may then be associated with other information you have provided to us. Your transactions through the Services will be recorded on the blockchain and associated with your wallet ID. Any information that you attach to a blockchain operation may be viewed by the public, meaning that others will have access to this content, and it may be viewed, collected, and used by others. Further, due to the nature of blockchain technology, information that is recorded on the blockchain cannot practically be corrected or revised.
Non-Identifiable Information and Aggregated Personal Information
We or our Integrated Service Providers may automatically collect certain information when you access or interact with our Site or Services, including, but limited to: (1) Your IP address or other unique identifier from the computer, mobile device, tablet, or other device you use to access any of our Site or Services; (2) the computer or other device type you use to access or use our Site or Services, the type of browser on the device, the browser’s settings, and the device’s operating system, software, and hardware; (3) your mobile device’s unique mobile platform advertising identifier, if you access any of our Site or Services from a mobile device; and (4) information about your interaction with our Site or Services, such as: the date and time of your visit to the Site; the number of times you visit our Site; the areas, pages, and features of or on our Site you visit or use; the amount of time you spend viewing or using the Site or particular areas of them; emails that you open, forward or click-through to our Site; and other website you may visit from our Site.
We or our Integrated Service Providers collect this information through the use of “cookies” and other technologies to better understand how our users navigate through our Site, learn what content is being viewed, and administer and improve our Site. We may use Google Analytics cookies for data analytics purposes. You can find more information on how Google uses data from these cookies at www.google.com/policies/privacy/partners/.
You may stop or restrict the placement of our cookies, Google’s cookies and third-party cookies on your computer, device or mobile phone by adjusting your web browser preferences or a “Do Not Track” setting in your web browser or by activating the appropriate setting on your mobile phone. You can also restrict marketing cookies by rejecting cookies on the website. If you do so, you may still use our Site, but this may interfere with some of its functionality.
You may also clear cookies from your computer or device via your web browser settings. You may also wish to use a Google Analytics opt-out web browser add-on. Information on this option is available at: http://support.google.com/analytics/bin/answer.py?hl=en&answer=2700409.
We may also collect personal information associated with feedback and correspondence from or with you, such as information you provide when you request information from us or otherwise correspond with us, including our Site or via social networking sites or services.
We may take personal information we collect from or about you directly and combine that with other information, including personal information we obtain about from third-party sources or that we automatically collect about you through our Site or Services.
HOW WE USE PERSONAL INFORMATION WE COLLECT
We use personal information that we collect from or about you to:
- Deliver our Services to you.
- Meet and enforce legal requirements, including ones pertaining to the determination of your eligibility to invest and identity verification, and “Know Your Customer” protocols.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
- Protect against, investigate, and deter fraudulent, unauthorized, and illegal activity.
- Personalize your experience on our Site or when engaging with us.
- Provide advertising, including targeted advertising, in order to promote our Services.
- Perform analytics about your access and use of our Site or Services and advertisements.
- On a de-identified, aggregated basis, analyze how you use the Services to help us understand traffic patterns and know if there are problems with the Services or areas in which we can improve.
- Communicate with you, such as through email or text messages, in order to provide you with information and updates about us and our Services, and to respond to your comments and questions.
WITH WHOM WE SHARE PERSONAL INFORMATION WE COLLECT
Third Parties with Whom We Share Personal Information
- The companies you invest in.
- Government agencies, as required by laws and regulations.
- Public blockchains. As described above, your transactions through the Services will be recorded on public blockchains and associated with your wallet ID. Any information associated with a blockchain transaction may be viewed by the public, meaning that others may view, collect, and use this information.
- Our service providers. We work with various third-party service providers, including database administrators, cloud computing services, advertising services, data analysts, identity verification services, accountants, auditors, payment processors, and escrow partners. We may provide your personal information to them to the extent required by law, required or needed to fulfill our obligations to you, or required or needed by such service providers to perform their service.
Other Instances in Which We Share Information with Third Parties
In addition to the third parties described above, we may transfer personal information we collect from or about you to a third party:
- To meet legal obligations or for protection. We may also transfer your personal information to a third party when required by law or to respond to legal process or as necessary to protect our customers, lives, the security of our Services, or our rights or property.
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The manner of operation of our partners, service providers, and other third parties with whom we share or disclose your information is governed by the policies of those third parties, and we shall have no liability or responsibility for their privacy practices or other actions. Generally, you can easily recognize when one of our partners is associated with a service. However, certain parties may provide services anonymously, and, in that case, we will only share information that is directly related to the applicable service(s).
Aggregated / De-Identified Information
Collected personal information may be aggregated and/or de-identified (in which any details that identify you personally have been removed). We may share this aggregated and/or de-identified information with third-party providers to help deliver products, services and content that are better tailored to the Users of our Site or Services and for our own business purposes where permissible under applicable law.
HOW WE SAFEGUARD PERSONAL INFORMATION WE COLLECT
Your account with us is protected by a password for your privacy and security. You must prevent unauthorized access to your account and personal information by selecting and protecting your password and/or other sign-on mechanism appropriately and limiting access to your computer or device and browser, including by signing off after you have finished accessing your account.
We are committed to safeguarding the confidentiality of your information but cannot guarantee the security of your information. We provide physical, electronic, and procedural safeguards to protect information we process and maintain. For example, we (1) encrypt any information we store, (2) transmit information via https and (3) limit access to this information to (a) authorized employees and contractors who need to know that information in order to operate, develop, and/or improve our Site or Services and (b) third parties that must receive that information in order to facilitate provision of our Services.
Please be aware that, although we endeavor to provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches. Unauthorized entry or use, hardware or software failure, or other factors may compromise the security of User information at any time. If you believe your information may not be secure for any reason, please contact us immediately at firstname.lastname@example.org.
You are solely responsible for keeping your third-party wallet and its private keys secure and you should never share your wallet credentials with anyone. If you discover an issue related to your wallet, please contact your wallet provider. The private keys necessary to decrypt a third-party wallet are held solely by you, and not by the Company. The Company has no ability to help you access or recover your private keys for your wallet.
In addition, when you use our Site or Services you might be required or permitted to visit other websites. We take no responsibility for the security of such websites and/or systems.
YOUR CHOICES REGARDING PERSONAL INFORMATION
You have several choices regarding the use of personal information we collect about or from you.
Changing or Deleting Your Personal Data
A User of our Site or Services may review, update, correct or delete personal information furnished by the User by contacting us at email@example.com or, in certain cases, by accessing their User account. For your protection, we may only share and update the personal information associated with the specific email address that you use to send us your request, and we may need to verify your identity before doing so. We will try to comply with such requests in a reasonably timely manner. If you completely and permanently delete all of your personal information, then your User account will be deactivated. If you wish to cancel your account, you may do so by emailing us at firstname.lastname@example.org , and any personal information associated with your account will be deleted as soon as is reasonably practical or as required by applicable law, subject to our data retention policy.
We retain personal information we receive for as long as you use any of our Site or Services, or as necessary to fulfill the purposes for which it was collected, provide our Services, resolve disputes, establish legal defenses, enforce our agreements, and comply with applicable laws. We may retain information that is otherwise deleted in anonymized and aggregated form, in archived or backup copies as required pursuant to records retention obligations, or otherwise as required by law. We may retain an archived copy of your records as required by law or for legitimate business purposes.
Download or Access Personal Information
You can ask us for a copy of your personal information, including a copy in machine readable form, by emailing us at email@example.com.
Opting Out of Email Communications
Opting Out of Sharing Information with Affiliated and Non-Affiliated Third Parties for Marketing Purposes
If you would like to opt out of sharing any of your information with Affiliates and non-Affiliate third parties for marketing or solicitation purposes, please contact us at firstname.lastname@example.org.
OUR USE OF TRACKING TECHNOLOGIES
We may also use so-called “pixel tags”– small graphic images– to tell us what parts of our Site have been visited or to measure the effectiveness of searches customers perform on our Site. Pixel tags are sometimes referred to as “web beacons.” Pixel tags also enable us to send email messages in a format customers can read, and they inform us whether emails have been opened, to help ensure that our messages are of interest to our Users.
ADDITIONAL PRIVACY-RELATED INFORMATION
Links to Third-Party Websites
We may provide links to third-party websites on our Site or in our communications or other materials exchanged with you. We have no control over those websites, and they may be subject to their own terms of service and privacy policies. As such, we do not endorse and are not responsible for the availability of, or for any content, advertising, products, or other materials on or available from, those third-party websites. By using any of our Site or Services, you agree that we will not be liable for any damage or loss caused by your use of or reliance on any content, advertising, products, or other materials on or available from these third-party websites.
How We Respond to Do Not Track Signals
Your browser settings may allow you to automatically transmit a “Do Not Track” signal to website and other online services you visit. To find out more about Do Not Track, please visit http://www.allaboutdnt.com.
Users Outside the United States
The Company is based in the United States. Our Site and Services are controlled and operated by the Company from the United States and are not intended to subject us to the laws or jurisdiction of any state, country, or territory other than that of the United States. Your personal information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Site or Services, you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your personal information.
Our Site and Services are not intended for children under the age of 18. We do not use our Site or Services to knowingly solicit data from, or market to, children under the age of 18. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us at email@example.com. We will take steps to delete such information from our files within a reasonable time.