Information We Collect
E.M collects personal and financial information from you when you visit the Site. Most of the information is collected during the registration and/or investment process and, while some items are optional, most are required for legal or security purposes. You may choose to provide additional information during subsequent visits to the Site, but keep in mind that some of this information will be required if you wish to partake in the Services.
In general, the type of information we collect includes, but is not limited to:
Personal data required to verify your identity;
Personal and financial data necessary to assess your eligibility to utilize our Services; and
Identifiable and aggregated personal data pertaining to your Site visits that help us maintain appropriate features, functionality and user experience
Investor registration will require you to provide basic personal data. Such information typically includes your name, email address, home address, phone number, date of birth, and tax identification number. E.M uses this data to: (i) enable you to log in to the Site; (ii) establish your suitability to view offering materials and to make investments through the Site; (iii) verify that you are at least 18 years of age; (iv) guard against potential fraud; (v) contact you if there is a problem with your account; and (vi) maintain regular communications with you as may be necessary to inform you of upcoming investment opportunities and other company updates.
When you subscribe to make an investment in one of our offerings on the Platform, you will again be asked for your personal data. You will also be required to provide financial data, such as your bank account information, to enable us or our broker-dealer partners to utilize your bank account to originate funds transfers and make subsequent investment disbursements to you.
Non-Identifiable Data and Aggregated Personal Data
E.M (or our service providers, such as Google Analytics) may also collect web surfing data related to your use of the Site. Such information may include: your Internet Protocol (IP) address, browser type, and internet service provider (ISP); your operating system; which of our web pages you access and how frequently you access them; referral or exit pages; click stream data; and the dates and times that you visit the Site. This data may be collected using cookies, web beacons, page tags or similar tools. As with cookies, the web surfing information is anonymous, "click stream" transactional data that is not associated with any users as individuals.
Web surfing data and similar information may be aggregated for administrative purposes. E.M may, for example, use this aggregated information in the administration of the Site to improve its usability and to evaluate the success of marketing and advertising campaigns, search engine optimization strategies, and other marketing activities. We also use it to help optimize the Site based on the needs of our users.
How and When Your Information is Shared with Other Parties
E.M does not sell or rent personal information about its users for marketing purposes. We do, however, work with trusted partners who perform vital functions as part of our operations. For example, North Capital Private Securities Corp. ("North Capital" or “NCPS”), a Delaware corporation, is a securities broker-dealer registered with the U.S. Securities and Exchange Commission and a member of FINRA and SIPC. North Capital is a provider of execution and other brokerage services and escrow services related to the sale of REIT shares and other equity securities transactions. North Capital is headquartered at 623 E. Fort Union Boulevard, Suite 101, Midvale, UT 84047.
Additional Sharing of Investor Information
E.M also works with (among others) providers of hosting services for the Site, electronic signature providers, and electronic payment service providers. We may engage third parties to help us carry out certain other internal functions such as account processing, client services, or other data collection relevant to our business. Examples of third parties might include those that perform data processing, reporting, tax documentation, or custody services. Information is shared with these third parties only to the extent necessary for us to process the transactions you initiate or perform other specific services. Our partners are legally required to keep your information private and secure.
We may share your information with law enforcement or other government agencies as required by law. We reserve the right to disclose your personally identifiable information when we believe that disclosure is necessary to protect our rights or to comply with a judicial proceeding, court order or legal process. We further reserve the right to disclose any of your personal information that we believe, in good faith, appropriate or necessary to take precautions against liability, to investigate and defend against any third-party claims or allegations, to assist government enforcement agencies, to protect the security or integrity of the Site or our Services, or to protect the rights, property or personal safety of E.M, its users, or others.
Notifications and Communications from Our Site
E.M will send you email notifications from time to time. Some notifications are required elements of your transactions on our Platform, such as confirmations of particular actions you have taken. These mandatory notices are sent typically to notify you of a change in status. For example, you will receive a notice when you are confirmed as an investor.
We also send out notices that are required for legal or security purposes. For example, certain notifications are sent for your own protection to ensure that another person cannot make a change to your account without your knowledge. In other cases, these notifications involve changes to various legal agreements or Site policies. Generally, you may not opt out of such service-related emails.
When you register as an investor, you will receive emails that confirm specific actions you requested. These will include emails to which you must respond to complete your registration and notifications confirming your registration. Thereafter, you will receive emails when a new investment opportunity is offered, as well as updates concerning the progress of the funding of offerings and/or other relevant information. If you make an investment through the Site, E.M and/or North Capital will also send you confirmations of the investment as well as occasional updates as to the status of that investment and the timing of distributions relating to that investment.
We may also send you responses to emails you send us, if appropriate. From time to time, we will also send user surveys, requests for user feedback regarding user experience and Site operations, or marketing offers from us or from us on behalf of our marketing partners. Completing these surveys, answering requests for feedback, or accepting any offer is strictly voluntary.
Where You Can View and Correct Your Information
California Consumer Privacy Act (CCPA)
The California Consumer Privacy Act of 2018 (CCPA) gives consumers more control over the personal information that businesses collect about them and the CCPA regulations provide guidance on how to implement the law. This landmark law secures new privacy rights for California consumers, including:
The right to know about the personal information a business collects about them and how it is used and shared;
The right to delete personal information collected from them (with some exceptions);
The right to opt-out of the sale or sharing of their personal information; and
The right to non-discrimination for exercising their CCPA rights.
Links to Other Sites
Security Policy - Access Limitations
We limit access to the personal information we have about you to those employees who have a legitimate business need to access such information. In keeping with industry standards and practices, we maintain appropriate physical, electronic and procedural safeguards and controls to protect your information. The Site is built upon a secure infrastructure with multiple layers of protection, and we use industry-standard encryption technologies to safeguard your information.
Users are required to identify and authenticate themselves prior to accessing sensitive portions of the Site. Generally, identification and authentication take place through the use of your username and a password and/or while logging in with one of our technical support staff.
Notifications of Security Systems Breach
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 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.
Take Precautionary Measures
You can take several precautions to protect the security of your computer and personal information. For instance, you can use a well-chosen password and restrict access to your email account. You can also install and regularly update antivirus and firewall software to protect your computer from external attacks by malicious users. When you are finished with a session on the Site, be sure that you log out and close the browser window.
You should also be aware of fraudulent attempts to gain access to your account information through "phishing," whereby scammers try to bring unsuspecting people to a website by using a genuine-looking email purporting to be from a legitimate company. Sometimes, either in the email itself or on this fake site, scammers will ask for login information to gain access to people's accounts and withdraw their money.
E.M will never send you an email asking you for your login information. In general, you can protect yourself against phishing by never providing personal or login information via a link contained in an email; instead, go the website directly. You might also make it a habit to check the URL of a website to be sure that it begins with the correct domain.
Third Party Services
We have installed a Microsoft Clarity cookie on every page of our site. Clarity captures the interactions on our website such as how the page has rendered and what interactions users undertake such as mouse movements, clicks, scrolls, etc. By default, any sensitive content such as passwords, usernames, etc. are masked before sending to Clarity. Clarity is GDPR complaint as a data controller.