LAST UPDATED DECEMBER 27, 2018
WE RESPECT YOUR PRIVACY
- (i) We don’t ask you for personal or financial information unless we need it.
- (ii) We don’t share your personal information with anyone except to comply with the law, develop our products, or protect our rights.
- (iii) We aim to make it as simple as possible for you to control what’s visible to the public, seen by search engines, kept private, and permanently deleted.
- (iv) We will send you emails relating to specific transactions but will keep these emails to a minimum.
- (v) We will maintain appropriate security standards and procedures to protect your information.
- (vi) We will respect the trust you place in us and the confidential nature of the information you provide through your financial relationship with us.
WHAT INFORMATION WE COLLECT
When you interact with us through the Site or Services, we may collect and process Personal Information and other information from you, as further described below:
Personal Information That You Provide Through the Site. We collect Personal Information from you when you voluntarily provide such information. This Personal Information is required to transact business, to communicate with you, verify your identity and fulfill legal and regulatory requirements. The types of Personal Information we collect and share depends on the product or service you have with us. This information may be collected when you:
- (i) register for access to the Services (for example, contact information such as your name, email address, phone number, mailing address);
- (ii) complete certain forms on the Site;
- (iii) upload or submit any material through the Site;
- (iv) request any information or contact us with inquiries; or
- (v) wish to use certain Services (for example financial information such as bank account numbers, your Date of Birth and the last 4 digits of your social security number).
Non-Identifying Information. As is the case with most websites, when you visit the Site or interact with Akras Capital, LLC through the Site or Services (and whether or not you register for access to the Services), we receive, automatically track and store certain non-identifying information about you, including but not limited to:
- (i) browser type;
- (ii) IP address;
- (iii) language preference;
- (iv) cookies; domain servers;
- (v) URL traffic to, through and from the Site;
- (vi) types of computers and operating systems accessing the Site;
- (vii) statistical information about behavior of visitors/users to the Site; and
- (viii) any other web site usage information that we may collect when you visit the Site.
This information, which may be collected passively using various technologies or through other means, cannot be used to specifically identify you. Akras Capital, LLC may store such information itself or such information may be included in databases owned and maintained by Akras Capital, LLC affiliates, agents or service providers. The Site may use such information and pool it with other information for administrative purposes, to assess the usage, value and performance of our products and services, to improve your experience with the Services and to track, for example, how our Users use and interact with the Services.
Also, in an ongoing effort to better understand and serve the users of the Site and Services, Akras Capital, LLC often conducts research on its customer demographics, interests and behavior based on the Personal Information and other information provided to Akras Capital, LLC by Issuers and Users. Akras Capital, LLC may also disclose aggregated user statistics in order to describe our Services to current and prospective business partners and to other third parties for other lawful purposes.
Most web browsers automatically accept cookies but, if you prefer, you can change your browser to prevent this or to notify you each time a cookie is sent. You can also learn more about cookies by visiting www.allaboutcookies.org which includes additional useful information on cookies and how to block cookies using different browsers. By blocking or deleting cookies used on our Site or Services, please note that you may not be able to take full advantage of our Services. Therefore, we recommend that you leave cookies turned on because they allow you to take advantage of some of the Site’s features.
USE OF YOUR PERSONAL INFORMATION
- (i) identify you when you sign-in to your account;
- (ii) enable us to provide you with the Services;
- (iii) send you information we think you may find useful or which you have requested from us;
- (iv) present projects or opportunities to you when you use the Services which we believe will be of interest based on your geographic location and previous use of the Services;
- (v) notify an Issuer of your interest in the event you indicate an interest in making an investment with the Issuer through the Services;
- (vi) administer your account with us;
- (vii) enable us to contact you regarding any question you make through the Services;
- (viii) analyze the use of the Services and the people visiting to improve our content and Services;
- (ix) use for other purposes that we may disclose to you when we request your information.
Also, if you provide Personal Information in order to obtain access to the Services, we will use your Personal Information to provide you with access to such services and to monitor your use of such services. We also may obtain information about you from third party sources to verify your identity so we can properly process your requests and prevent fraud.
Regarding email contact with and from Akras Capital, LLC, please keep in mind the following: (i) we will send you email relating to your personal transactions but will keep these emails to a minimum; (ii) you will receive certain email notifications (forwarded messages, etc.) for which you may opt-out; (iii) we may send you service-related announcements on rare occasions when it is necessary or proper to do so; (iv) if you email us directly, we may email you back and keep records of all correspondence; and (iv) we may send you emails from time to time letting you know about special promotions, featured investments and other Akras Capital, LLC news. It is your responsibility to ensure that you maintain a current email address with Akras Capital, LLC, and notify us if there are any changes.
THIRD PARTY SERVICES
Akras Capital, LLC limits the sharing of your Personal Information and strives to keep your Personal Information private and confidential. We do not sell, license, lease or otherwise disclose your personal information to any unaffiliated third party for any reason, except as follows:
- (i) We may disclose your Personal Information when such disclosure is required or appropriate pursuant to laws, court orders or securities regulations, including responding to court orders and subpoenas, cooperating with government agencies, other regulatory bodies and law enforcement officials, performing background checks, resolving disputes or performing risk-management functions.
- (ii) We may share your Personal Information with companies that provide services to us, including outside contractors or agents who help us manage our information activities, but they may only use your personal information to provide us with a specific service and not for any other purpose.
- (iii) To help us improve our services to you, we may engage third parties to help us carry out certain internal functions such as account processing, client services or other data collection relevant to our business. Use of any Personal Information shared in connection therewith is strictly limited to the performance of the task we request and for no other purpose.
- (iv) In the event you indicate an interest in making an investment through our Site, we will notify the Issuer of your interest and will provide your Personal Information to the Issuer.
- (v) We may make certain automatically collected information about your interactions and activities on the Services, such as the business or investment areas of interest to you or you have invested in, and your past activities, projects or proposals, publicly available on or through the Services. Any such publicly available information will be accessible by other Users.
- (vi) In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Information may be part of the transferred assets and you will be notified via email and/or a prominent notice on our Site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your Personal Information.
In addition to the above, we may need to share your information in continuance of the transaction for which you have voluntarily utilized our services. The ways in which we share that information immediately follows.
Potential Disclosure of Subscriber Information to Related Transaction Parties; Ongoing Compliance with Governmental Requirements. The real estate company(ies) sponsoring an investment project (collectively, the “Sponsor”), lenders relating to the investment project, or other parties involved with the investment and related transactions (collectively, “Related Transaction Parties”) may require that Akras Capital, LLC, the Manager, or any of their respective affiliates provide such Related Transaction Parties with the names, investment amounts, and other information regarding the various investors in a financing offering, notwithstanding the usual privacy policies of Akras Capital, LLC or any of its affiliates. You hereby expressly consent and agree that any of Akras Capital, LLC, the Manager or any of their respective affiliates may provide such information (which may include, without limitation, Social Security numbers or similar identifying information, evidence of your qualification as an “accredited investor,” or other information related to your involvement with an investment project) to any such Related Transaction Parties requiring such information as part of the consummation of, or continued participation in, the investment project or the related transactions contemplated hereunder, as Akras Capital, LLC or any of its affiliates may deem appropriate in its or their sole and absolute discretion.
The Department of the Treasury, the Internal Revenue Service, and other governmental authorities may from time to time impose certain compliance or reporting requirements that may require Akras Capital, LLC or any of its affiliates to request from you additional financial or personal information. These regulations, including (without limitation), the PATRIOT Act and the Foreign Account Tax Compliance Act, may require increased due diligence, compliance activity, or reporting on the part of Akras Capital, LLC or any of its affiliates. You hereby warrants that you will, upon request, supply to Akras Capital, LLC or any of its affiliates all information reasonably necessary or advisable to carry out such functions or requirements.
SAFEGUARDING USER INFORMATION
The Security of your User Information is important to us, and we take commercially reasonable steps to safeguard such information. These steps and procedural safeguards are in line with industry standards and practices and include:
- (i) Encryption and authentication tools to maintain the confidentiality of User Information including Transport Layer Security technology (TLS) encryption certificates provided by Comodo CA Limited (SHA-256 With RSA Encryption);
- (ii) Limits on, to the greatest extent possible, who or what can access your User Information, including utilization of a “lease-privilege principle” such that employees have access only to the information and systems needed to perform their functions and only for the duration of such need;
- (iii) Redundant systems to monitor the entire Akras Capital, LLC’ server infrastructure in real-time with web-based and server applications reporting and instant notification to the appropriate staff for any remediation; and
However, despite these efforts, please note that Akras Capital, LLC cannot ensure or guarantee the security of your User Information nor do we make any representation or warranty regarding the security of your account. If we learn of a security systems breach, then we may attempt to notify you electronically so that you can take appropriate protective steps. We may also post a notice on or through the Site and the Services in the event of a security breach. Depending on where you live, you may have a legal right to receive notice of a security breach in writing.
You are solely responsible for helping us to maintain the accuracy and completeness of your personal and other information. We urge you to review your information regularly to ensure that it is correct and complete. If you believe that any of your information is incorrect, please contact us at firstname.lastname@example.org.
You may, of course, decline to share any or all of your Personal Information with us or ask us to delete your Personal Information from our systems at any time, in which case we may not be able to provide to you some of the features and functionality found on or through the Site and the Services (see below section regarding Right To Opt-out).
Additional Accreditation Verification Measures. In addition to the information you provide to us, under certain circumstances, federal law may require Akras Capital, LLC or any of its affiliates to take additional steps to verify that you are an “accredited investor.” If such circumstances apply to the offering of certain securities in which you would like to invest, you agree to utilize an independent third-party verification provider, which may be VerifyInvestor.com (“VI”) or such other service provider as Akras Capital, LLC may from time to time utilize for such purpose, to verify your status as an accredited investor. You understand that VI or such other provider may contact you directly in such instance, and you agree to promptly work with VI or such other provider to complete the verification process. Akras Capital, LLC or an affiliate will pay the service provider’s fees and costs for this service. Akras Capital, LLC will not share with you the information received from VI or such other service provider regarding you or your status as an accredited investor unless such information is the basis for Akras Capital, LLC or an affiliate declining to accept your investment subscription.
We will retain your User Information for as long as your account is active or as needed to provide you services, and we may continue to retain such User Information beyond your active use of the Akras Capital, LLC platform. You may modify or delete the Personal Information you have provided to us by logging in and updating your account. We may, however, retain certain information as required by law or for necessary business purposes.
Please keep in mind that any information you post on portions of the Site or Services that are open to the public, including but not limited to our blog, will be public information available to anyone. Information that you provide in these areas may be read, collected and used by others who access them. Accordingly, you should exercise caution when deciding to disclose your personal information in these areas. To request removal of your personal information from these publicly accessible areas, contact us at email@example.com. In some cases, we may not be able to remove your personal information and we will let you know if this is the case and why.
LINKS TO OTHER WEBSITES
The Services may be accessed and/or used by Users located outside the United States. If you choose to use the Services from the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your personal information outside of those regions to the United States and by providing your personal information on or through the Services you consent to that transfer.
OTHER TERMS AND CONDITIONS
Your access to and use of this Site is subject to the Terms of Service.
CONTACT AKRAS CAPITAL, LLC