1. Scope and Applicability
This Privacy Policy governs the collection, use, processing, and disclosure of information obtained through this website (the "Website"). This Website is intended solely for informational purposes relating to real estate and hospitality development activities. Access to this Website is subject to this Privacy Policy and all applicable laws and regulations.
2. Information Collected
We may collect personal and professional information voluntarily provided by users, including but not limited to name, email address, telephone number, organization, professional title, investment interest, accreditation status, geographic location, and any other information submitted through inquiries, subscriptions, or communications.
We may also automatically collect limited technical information, including IP address, browser type, device identifiers, operating system, referring URLs, pages accessed, timestamps, and usage data through cookies and similar technologies.
3. Purpose and Legal Basis for Processing
Information is processed strictly for legitimate business purposes, including:
- Responding to inquiries and communications
- Managing relationships with prospective investors, lenders, partners, and customers
- Providing general information regarding real estate and hospitality projects
- Internal analytics, risk management, compliance, and recordkeeping
- Website security, fraud prevention, and operational integrity
For EU/EEA users, processing is based on legitimate interests, contractual necessity, legal obligation, or consent, as applicable under the GDPR.
4. Investor-Specific Data Disclaimer
Information submitted by investors or prospective investors is collected solely for preliminary informational and relationship-management purposes. Submission of information through this Website does not constitute an offer to sell or a solicitation of an offer to buy any securities. Any investment opportunity, if made, will be provided exclusively through definitive offering documents and only to qualified persons in compliance with applicable securities laws. Investor information may be subject to regulatory verification, suitability review, and compliance screening.
5. No Offer / No Solicitation Disclaimer
Nothing contained on this Website constitutes or shall be construed as an offer, solicitation, recommendation, or endorsement to acquire or dispose of any investment, security, or financial instrument. Any such offer or solicitation will be made only pursuant to applicable law and through formal legal documentation. Access to this Website may be restricted in certain jurisdictions, and users are responsible for compliance with local laws.
6. Disclosure of Information
We do not sell personal information. Information may be disclosed on a limited basis to:
- Affiliates and related entities
- Professional advisors (legal, accounting, tax, compliance)
- Third-party service providers under confidentiality obligations
- Governmental or regulatory authorities as required by law
Disclosures are limited to what is reasonably necessary for the stated purpose.
7. Cookies and Tracking Technologies
This Website uses cookies and similar technologies to support functionality, performance measurement, analytics, and security. Cookies may collect non-identifying usage information. Users may manage cookie preferences through browser settings; disabling cookies may limit certain Website features.
8. Data Security
We employ commercially reasonable administrative, technical, and physical safeguards designed to protect personal information. However, no electronic transmission or storage method is entirely secure, and we disclaim any guarantee of absolute security to the maximum extent permitted by law.
9. Jurisdiction-Specific Rights
United States
Personal information is processed in accordance with applicable U.S. federal and state laws.
California (CCPA/CPRA)
California residents may request access to or deletion of personal information, subject to statutory exceptions. We do not sell personal information as defined under California law.
European Union / EEA (GDPR)
EU residents have the right to access, rectify, erase, restrict processing, object to processing, and request data portability, subject to legal limitations.
Global Users
Users accessing this Website from outside the United States acknowledge that information may be processed and stored in jurisdictions with different data protection standards.
10. Data Retention
Information is retained only for as long as reasonably necessary for the purposes described herein, unless a longer retention period is required by law or regulatory obligation.
11. Third-Party Websites
This Website may contain links to third-party websites. We disclaim responsibility for the content, security, and privacy practices of third parties.
12. Policy Modifications
We reserve the right to amend this Privacy Policy at any time without prior notice. Changes are effective upon posting.
13. Contact
Questions regarding this Privacy Policy or data practices may be directed through the contact information provided on this Website.