Last updated September 22, 2022
For information about our Regulation A Offering, please see our Offering Circular here.
Information Collected by reAlpha
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:
- Visit our websites, www.realpha.com and invest.realpha.com(collectively, the “Website”) or use the reAlpha mobile application (the “App”)
- Register to set up a reAlpha account on the Website or the App
- Complete and submit our Subscription Agreement and other Regulation A Offering materials either directly to us or through DealMaker
- Link your reAlpha account with your DealMaker account or you otherwise authorize DealMaker to share your personal information with us
- Communicate with us in your capacity as an investor or potential investor
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:
- Your first name and last name
- Email address
- Phone number
- Social Security Number
- Residential Address
- Taxpayer Identification Number
- Name of a Joint Subscriber
- Social Security Number of the Joint Subscriber
- If relevant, information related to a custodial account
- Type of account
- EIN of account
- Address of account provider
Automated Online Data Collection
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).
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.
How reAlpha Uses Your Information
We may use the information we collect about you (including Investor Information, to the extent applicable) to effectuate our Regulation A Offering, including to:
- Conduct our Regulation A Offering
- To make our Regulation A Offering available to existing stockholders and prospective investors
- Comply with legal and regulatory obligations related to our Regulation A Offering
- To verify Investor Information
- To communicate with you regarding our Regulation A Offering, including responding to comments, questions, and requests
- Provide, operate, maintain, and improve the Website, the App, our online investor accounts services
- To customize and personalize certain features of the Website and App
- To communicate with you regarding changes to the Website, the App or our Regulation A offering and our Fractional Interest Offering
- Enable you to access and use the Website and the App and improve their functionality and performance
- To provide customer service, and communicate with you for marketing purposes, including information about promotions and rewards offerings
- To improve the technical and non-technical aspects of the website and the App
- Monitor and analyze trends, usage, and activities in connection with the Site for performance, marketing or advertising purposes
- Protect our Site and investors by investigating suspicious activity and unauthorized access
- Comply with valid legal process and respond to governmental requests
How reAlpha Shares Your Information
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 firstname.lastname@example.org. 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.
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.
Cookie Collection and E-Mail Marketing
Opting Out of Marketing Communications. You can opt-out of receiving marketing communications from us by going to email@example.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.
How You Can Restrict Cookies and Targeted Advertising
[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
- Communicating directly with third-parties that we authorize to collect data on our Website or App as explained at:
- Purchasing a utility from an independent software provider that you install on your computer browsers to limit tracking of your browsing activity.
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.
How to Access and Manage Your Personal Information
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 firstname.lastname@example.org. You can update or correct your online account information by logging into your account at the customer portal on our Site.
Protection and Retention of Personal Information
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
Links to Third Party Websites
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.
Information for International Investors
Information about Minors
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 email@example.com.
How to Contact Us