Last updated September 22, 2022
This Privacy Policy explains how reAlpha Asset Management Inc. (collectively, “reAlpha”, “us” or “we”) collects, uses and protects your personal information. If you have any questions that this policy does not address, please contact us at support@realpha.com
reAlpha invests in real estate with a focus on properties we believe will be attractive short-term vacation rentals and suitable for third-party rental platforms such as Airbnb or Vrbo. At this time, our Privacy Policy applies to the personal information we collect in connection with our Regulation A offering of our common stock (the “Regulation A Offering”). Prospective investors may subscribe for shares either by submitting a Subscription Agreement directly to reAlpha or through DealMaker, a third-party online platform that facilitates capital raising and communication with investors.
For information about our Regulation A Offering, please see our Offering Circular here.
In this Privacy Policy, we use the term “personal information” to refer to information that can be used by itself or in combination with other available information to identify or be associated with you. Directly identifying information includes, for example, information such as your name, e-mail address, and date of birth. Personal information that is associated or linked to you includes data related to your interaction and usage of our Website, App, services, offerings and products.
We collect personal information when you submit subscription documents to us, if you authorize DealMaker to provide your information to us, or communicate and interact with us in other ways, online and offline.
We collect the information you submit when you:
During our financing phases, we will collect personal information to effectuate our Regulation A Offering (“Investor Information”). Over time as our services, products and offerings change, the Investor Information we collect may change. At this time, when you register with reAlpha on the Website or the App or by executing our Subscription Agreement, we collect the following Investor Information:
We also use cookies and similar internet technologies to automatically collect information as you use our Website and App. See Cookie Collection and E-mail Marketing.
We (and our third-party service providers) may place cookies, web beacons, scripts, and similar tracking technologies and device identifiers on your web browser or mobile device when you visit our Website or App. (In this Privacy Policy we use the term “cookies” to refer generally to cookies, tracking technologies, and other device identifiers.) You can use the settings or tools offered on your browser to refuse or deny cookies, or to delete cookies that have already been stored. (See “Cookie Collection and E-mail Marketing” below.)
Log in and identification: To recognize and verify you and your device when you log in to access your account and use the Website or App by storing data including, for example, your password, device and browser type, Internet Service Provider (ISP) and Internet Protocol (IP) addresses), device and browser identifiers and information (including device, application, or browser type, version, plug-in type and version, operating system, and other technical data).
Features and performance: To provide functionality for the features and options you select to use on our Website or App; deliver consistent performance; recognize and implement your preferences; and enable information sharing with third-party providers.
Location: If you visit our Website or App using a mobile device, we obtain geolocation data from device sensors, GPS signals, WiFi access points, and cell towers, unless you disable location information in your device setting. We can also more generally identify your location through IP address or mobile device identifier.
Data analytics: Track and log web usage data about your interactions with our Website and App and online activities including, for example, browsing history, usage rates, settings preferences, content interactions (including searches, page views, downloads, and prints), and user journey history (including clickstreams and page navigation, URLs, timestamps, content viewed or searched for, page interactions, and similar data).
Advertising: Cookies used for advertising purposes may be set through our Website or the App by us or our advertising partners. We and our advertising partners may use cookies to build a profile of your interests and show you relevant advertisements on our Website or App and on other websites and mobile applications. Advertising cookies do not store directly personal information, but store data that may uniquely identify your browser and internet device. If you do not allow these cookies, you will still receive advertisements, but they will be less targeted specifically to you.
Email Interconnectivity: If you receive email from us, we use internet tools to capture data related to when you open our message and click on any links or banners it contained. We use this information to track the effectiveness of our communications with you.
We may use the information we collect about you (including Investor Information, to the extent applicable) to effectuate our Regulation A Offering, including to:
reAlpha does not sell your personal information to third parties or share personal information for monetary or other consideration. To assist us in providing our services and offerings, reAlpha may share some of your personal information with third parties and your personal information may be accessible to third parties in connection with services they provide to us, including the following:
Third-Party Service Providers: We share information, including certain personal information, with our third-party service providers that we use to: process authentication and log-in information; provide hosting for and maintenance of our Website and App, e-mail marketing, solicit investors, scheduling meetings, backup, storage, payment processing, analytics and other services for us. These third-party service providers may have access to or process your personal information for the purpose of providing these services for us. We do not permit our third-party service providers to use the personal information that we share with them for their own commercial purposes.
Analytics: We may collect, and we may engage third-party analytics providers to collect, metrics and information regarding your use of the Website and App, including evaluating how visitors use our Website and App (“Usage Data”) to develop new features, improve existing features or inform sales and marketing strategies. When we process Usage Data, any personal information is anonymized
Advertising and Marketing: We may use third-party advertising companies to serve advertisements on our Website and App and on selected websites and mobile applications operated by others. These companies may set their own cookies or use similar web technologies to collect information about your online and mobile device activities over time and across different websites. These companies then may direct advertisements to you based on your interests as suggested by the history of your visits to Website, App and other websites or mobile applications.
Community Forums: The Website and App may offer publicly accessible blogs, community forums, comments sections, discussion forums, or other interactive features (“Interactive Areas”). You should be aware that any information that you post in an Interactive Area might be read, collected, and used by others who access it. To request removal of your personal information from an Interactive Area, contact us at support@realpha.com. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.
Affiliates: We may share information, including personal information, with companies affiliated with reAlpha, and they will use that information only for the purposes that are consistent with those described in this Privacy Policy.
Legal or Regulatory Purposes: We share information with governmental and regulatory entities as necessary to fulfill our legal obligations. For our Regulation A Offering and our Fractional Interest offering, we will disclose information to the Security Exchange Commission as required under applicable law.
Promotional and Reward Partners: We may share information, including personal information, to third-party service providers who provide promotional and reward items and offers associated with investing in the Regulation A Offering.
Restricting Online Data Collection. By using the Website, you consent to the processing of personal information by both reAlpha and our analytics services provider. You can restrict how cookies are used to track and log data about your visits to our Website and other websites. Note that if you restrict the use of cookies some of the features on our Website may not be fully functional.
Opting Out of Marketing Communications. You can opt-out of receiving marketing communications from us by going to support@realpha.com and providing the names/email address that you would like removed from our marketing databases and added to our ‘Do Not Contact’ list” or by following the unsubscribe instructions included in our marketing communications.
[Company does not publish third-party personalized advertisements on the Website or App nor do we publish personalized advertisements on other companies’ websites.]
Cookies enable the Company to measure and analyze the visits to the Website and App and collect data on the activities of users of the Site and our online portal. We use Google Analytics and/or other third-party data analytics services to place the cookies, track Website and App usage data, and provide reports to us. The Company does not disclose any directly identifying personal information to a third-party data analytics service. However, the service may monitor a user’s visits to the Website and App and combine this data with data from other websites monitored by the same service provider and then use the aggregated findings for its own commercial purposes. The service provider may have means of correlating data from our Website to an identifiable individual, in which case the processing of personal information will be the responsibility of the service provider.
By using the Website or App, you consent to the processing of your personal information by both the Company and our analytics services providers, including Google Analytics. You can restrict how cookies and other internet technologies are used to track and log data about your computer and mobile device usage of our Website or App by managing the preference settings on your browser or device. You can learn how Google collects data on its partner sites and how to restrict that data collection at here
Note that if you restrict the use of cookies some of the features on our Site may not be fully functional. The controls you may be able to use include:
Do Not Track (DNT) is an optional browser setting that is used by some website operators and third parties. Our Website and App does not respond to DNT signals.
Our Website includes social media features which will redirect you to third-party social media companies. These third-party social media companies may collect your internet protocol (IP) address, which page you were visiting on the Website, and the social media platform may set a cookie to recognize you and enable the feature to function properly. Social media features and widgets are either hosted by the third-party social media company or hosted directly on the Website. Your interactions with these features are governed by the privacy practices of the third-party social media companies that provide them. This Privacy Policy applies solely to information under our control. Company is not responsible for the privacy practices of the social media platforms you use in connection with our Site. Company is not responsible for the privacy practices of social media platforms. We recommend that you review their privacy policies and practices.
You have certain rights regarding your personal information. To request access to the personal information we maintain about you or to ask us to stop processing your personal information, including for direct marketing and promotional purposes, please contact us at support@realpha.com. You can update or correct your online account information by logging into your account at the customer portal on our Site.
reAlpha maintains administrative, technical, and physical safeguards to protect the security, confidentiality, and integrity of Investor Information appropriate to the nature of the Investor Information we collect. While the measures we implement are intended to reduce the likelihood of security problems, we cannot guarantee that these measures will prevent unauthorized access to your Investor Information. In particular, information transmitted over the Internet may be beyond the control of reAlpha, and you are advised that such transmission may not be secure.
We will retain your personal information as long as we provide services to you, as necessary to comply with our legal obligations, resolve any disputes, and enforce our agreements.
Our Website and App permits you to register an account. When you do you will be prompted to create a password. You are responsible for maintaining the confidentiality of your password, and you are responsible for any access to or use of your account by someone else who has obtained your password, even if that person was not authorized by you. You should notify us of any unauthorized use of your password or account, and, if any unauthorized use is suspected, you should immediately reset your password.
If you have reason to believe that your interaction with us is no longer secure or your security has been compromised, you must immediately notify us of the problem by contacting us. See “How to Contact Us” below
Our Website and App may contain links to other sites that are not operate or owned by us. If you click on a third-party link, you will be directed to that third-party’s site. We strongly advise you to review the Privacy Policy of every site you visit.
DealMaker shares your information with us pursuant to its Privacy Policy which can be found here. Per DealMaker’s Privacy Policy, we only receive Investor Information or any other information when authorized by you as described in the relevant portion of the application or agreement between you and DealMaker. DealMaker only shares information with us when you decide to invest through our Regulation A Offering. Your registration and eligibility to use or access DealMaker’s products and offerings is independent from our products, services or offerings.
We have no control over, and assume no responsibility for the content, services, products, privacy policies or practices of any third-party sites, services or providers.
We reserve the right to make changes to this Privacy Policy at any time. Upon making a material change to the way we collect, use, or share your personal information, we will provide you notice on the website. Your continued use of your reAlpha account, the Website and/or App after a change to this Privacy Policy constitutes your consent to be bound by the revised Privacy Policy. We encourage you to periodically review this page for the latest information on our privacy practices.
reAlpha operates under United States laws and regulations. If you reside or are located in a different country, the data protection and privacy laws of that country may differ from the laws of the United States in the way in which your personal information is protected. We want you to understand that when you provide your personal information to us, or engage in a transaction with us, you are giving your consent to (1) the transfer of your personal information outside of your country of residence, and (2) the processing of your information in accordance with the laws of the United States and the guidelines of this Privacy Policy. If you are resident in the European Economic Area, the United Kingdom, or Switzerland, we will process your information in order to fulfill your requests and to otherwise pursue our legitimate business interests as described in this Privacy Policy. If you are resident in a country that provides specific rights regarding the processing or disposition of personal information, we will make commercially reasonable efforts to accommodate your request to exercise such rights.
We do not intentionally collect personal information from individuals who we have reason to believe are under the age of 18. If you become aware of any personal information we have collected from individuals under age 18, please contact us at support@realpha.com.
If you have any questions or complaints regarding this Privacy Policy or about reAlpha’s privacy practices, please contact us at support@realpha.com