1. Introduction

At Finquity Capital, we are committed to protecting the privacy and security of your personal information. This Privacy Policy explains how we collect, use, share, and safeguard your data when you interact with our services, both online and offline.

This Policy applies to personal information collected through our website (www.finquitycapital.com) and other communication channels used in connection with our real estate investment activities. By accessing or using our services, you acknowledge and agree to the terms outlined in this Privacy Policy.

If you have any questions or concerns about this Privacy Policy, please contact us using the details provided in the Contact Information section.

2. Information We Collect

Finquity Capital (“Finquity”) collects only the essential personal information required to verify investor eligibility and facilitate communication. The following categories of personal data may be collected:

2.1 Categories of Personal Information Collected

• Full Name
• Email Address
• Phone Number
• State
• Self-reported Accredited Investor Status

Finquity does not collect sensitive personal data such as Social Security Numbers, government-issued identification, or financial account details through its website

2.2 How We Collect Your Information

Finquity obtains personal information through the following means:

• Direct Submission – When users voluntarily provide information through our website’s registration form or other official communication channels.
• Regulatory Compliance Processes – When verifying investor eligibility as required by applicable laws and financial regulations.

All collected data is securely stored and used solely for the purposes outlined in this Privacy Policy

3. Purpose of Data Collection and Processing

Finquity does not use personal data for unrelated marketing or advertising purposes and strictly adheres to data privacy regulations. Finquity Capital (“Finquity”) collects and processes personal information strictly for investment facilitation and regulatory compliance. The primary purposes of data collection include:

3.1 Self-Reported Investor Status and Eligibility Verification

• To allow users to self-report their accredited investor status under Rule 501 of Regulation D under the Securities Act of 1933, as amended during the registration process.
• Self-reported accreditation does not constitute verification, and users are not automatically considered accredited investors by Finquity.
• Accredited investor status is only confirmed after appropriate verification through a third-party service (e.g., VerifyInvestor.com) or other acceptable methods, such as:
  • A letter from a certified public accountant (CPA), licensed attorney, or registered investment advisor (RIA).
  • Submission of supporting financial documents, such as tax returns or brokerage account statements, directly to the verifying entity.
• Users must complete the verification process before gaining access to investment opportunities.

3.2 Communication and Investor Support

• To respond to inquiries about Finquity investment opportunities.
• To provide notifications, confirmations, and updates related to investment offerings.
• To send administrative messages, including account status updates and compliance notices.

3.3 Legal and Regulatory Compliance

• To fulfill obligations under federal and state securities regulations, including anti-money laundering (AML) and know-your-customer (KYC) requirements.
• To maintain accurate investment records in accordance with regulatory requirements.

3.4 Business Operations and Security

• To detect and prevent fraudulent activities related to investment inquiries.
• To safeguard Finquity’s website and investor communications against unauthorized access.

4. Information Sharing and Third-Party Disclosure

Finquity Capital (“Finquity”) values your privacy and only shares personal information when necessary to facilitate investment operations, comply with regulatory obligations, or ensure the security of our services. Finquity does not sell personal data to third parties.

4.1 Third Parties with Whom Finquity Shares Data

Personal information may be shared only with the following categories of third parties:

       1. Affiliated Companies

Finquity may share limited personal information with its affiliates, Anchorage Solutions and Intent Reality, in connection with investment operations, due diligence, and regulatory compliance. These entities follow the same data protection standards outlined in this Privacy Policy.

       2. Accredited Investor Verification Services

Finquity partners with third-party verification providers (e.g., VerifyInvestor.com) to confirm accredited investor status. Users are responsible for submitting required documents directly to the verification service, not through the Finquity website.

       3. Regulatory and Legal Entities

Information may be disclosed to government agencies, regulators, or law enforcement if required to comply with:

• Federal and state securities laws.
• Anti-money laundering (AML) and know-your-customer (KYC) regulations.
• Court orders, subpoenas, or legal investigations.

        4. Financial Institutions and Payment Processors

If an investment transaction requires fund transfers, Finquity may share limited user details with banks or financial institutions only as necessary to facilitate the transaction.

         5. Security and Fraud Prevention Partners

Finquity may collaborate with fraud detection and cybersecurity firms to:

• Prevent unauthorized access to user accounts.
• Investigate suspicious activity or fraudulent investment attempts.

          6. Professional Service Providers

Finquity may share limited personal data with legal, accounting, and compliance consultants to ensure adherence to regulatory requirements.

4.2 Situations Where Finquity May Disclose Information

Finquity will only disclose personal information in the following situations:

• To fulfill regulatory requirements, including accredited investor verification.
• To protect Finquity’s legal interests, including fraud prevention or dispute resolution.
• To complete a business transaction, such as a merger, acquisition, or restructuring, provided that appropriate confidentiality measures are in place.

Finquity does not share user data for marketing purposes and ensures that any third-party recipient maintains strict data protection policies in accordance with applicable regulations.

5. Data Security Measures

Finquity Capital (“Finquity”) prioritizes the security of Users’ personal information and employs industry-standard security measures to protect data from unauthorized access, disclosure, alteration, or destruction.

6.1 Technical Safeguards

Finquity implements the following security controls to protect User data:

• Encryption: Personal information is stored using encryption protocols to prevent unauthorized access.
• Secure Storage: Data is stored in secure systems with controlled access, including cloud-based and on-premise servers with appropriate security measures.
• Access Controls: Only authorized personnel with a legitimate business need can access sensitive data.
• Secure Transmission: Data transfers are protected using encryption and secure protocols (e.g., HTTPS, TLS).

6.2 Organizational Protocols

Finquity has established internal procedures to ensure proper handling of sensitive data:

• Employee Training: Staff members undergo regular training on data protection and security best practices.
• Incident Response Plan: Finquity has a structured plan to detect, respond to, and mitigate security breaches.
• Third-Party Security Compliance: Vendors and service providers handling User data must comply with Finquity’s security standards and data protection requirements.

6.3 Reporting Security Concerns

Users who suspect unauthorized access, data breaches, or other security incidents related to Finquity services should report them immediately using the contact information provided in Section 9 – Contact Information. Finquity investigates all reported incidents and takes appropriate action to mitigate risks.

7. Data Retention and Deletion

Finquity Capital (“Finquity”) retains personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, comply with legal obligations, resolve disputes, and enforce our agreements.

7.1 Data Retention Periods

The retention period for each category of personal information varies based on business, regulatory, and legal requirements. Finquity follows these general guidelines:

• Registration Information (Full Name, Email, Phone Number, State of Residence, Self-Reported Accredited Investor Status)
  • Retained for the duration of the User’s engagement with Finquity and for five (5) years after the last interaction or as required by applicable laws.
• Accredited Investor Verification Records (Collected by Third Parties, Not by Finquity)
  • Retained by the third-party verification provider (e.g., VerifyInvestor.com) as per their policies and applicable regulations.
  • Finquity does not store copies of these verification documents.
• Communication Records (Emails, Phone Inquiries, Customer Support Requests)
  • Retained for three (3) years for operational and legal compliance purposes.
• Security and Fraud Prevention Logs
  • Retained for up to five (5) years, unless required for ongoing investigations or legal actions.

7.2 Data Deletion Requests

Users may request deletion of their personal data by contacting Finquity (see Section 9 – Contact Information). However, certain data cannot be deleted due to regulatory or legal obligations, such as:

• Compliance with securities laws requiring retention of investment-related records.
• Obligations under anti-money laundering (AML) laws and other financial regulations.
• Retention needed for fraud prevention or security investigations.

If Finquity is unable to fulfill a deletion request due to legal requirements, Users will receive an explanation outlining the reason for data retention.

8. Policy Updates and Notifications

Finquity Capital (“Finquity”) may update this Privacy Policy periodically to reflect changes in legal requirements, industry practices, or business operations.

Updates to this Privacy Policy will be communicated through one or more of the following methods:

• Website Notification: A banner or notice posted on the Finquity website.
• Email Notification: Users who have provided an email address will receive a summary of significant changes.
• Account Dashboard Notification: If applicable, a message will be displayed within the User’s account.

The “Effective Date” at the top of this Privacy Policy will be updated to reflect the latest revision.