Privacy Policy

This Privacy Policy describes how Real Street Capital Manager, LLC and its affiliates (collectively, “Real Street Capital,” “we,” “us,” or “our”) collect, use, disclose, and safeguard information when you visit or interact with our website, request access to our investor data room, communicate with us, or evaluate a private investment opportunity (collectively, the “Services”). 

This Privacy Policy is provided for informational purposes and is not legal advice. If you have questions about this Privacy Policy or our privacy practices, please contact us using the information in the “Contact Us” section below. 

1. Scope

This Privacy Policy applies to information we collect through our website and related Services. It does not apply to third-party websites, platforms, or services that may be linked from our site or used to provide certain features (for example, scheduling tools, form tools, or document hosting/data room providers). Those third parties have their own privacy policies that govern their practices. 

2. Information We Collect

We collect information in three primary ways: (a) information you provide to us, (b) information collected automatically when you use the Services, and (c) information we receive from third parties. 

2.1 Information you provide

Depending on how you interact with us, you may provide: 

  • Contact information (such as your name, email address, phone number, and mailing address). 
  • Communications (such as messages you submit through forms, email, or phone, and any attachments you provide). 
  • Investor intake information (such as your self-identification as an Accredited Investor and your acknowledgement of confidentiality when requesting data room access). 
  • If you proceed toward a potential investment, additional information may be requested as part of subscription, verification, suitability, tax, or compliance processes (such as entity documents, identification information, tax forms, wire instructions, and accredited investor verification materials). 

2.2 Information collected automatically

When you visit our website, we (and service providers acting on our behalf) may automatically collect certain information, including: 

  • Device and usage information (such as IP address, browser type, operating system, device identifiers, pages viewed, links clicked, access times, and referring URLs). 
  • Approximate location derived from IP address. 
  • Cookies and similar technologies (see Section 6). 

2.3 Information from third parties

We may receive information from third parties, such as: 

  • Service providers that help us operate the Services (for example, website hosting, analytics, email delivery, or customer relationship management). 
  • Vendors involved in investor onboarding and compliance (for example, accredited investor verification, identity verification, or anti-money laundering screening), if applicable. 
  • Professional advisers (such as attorneys, accountants, auditors, or administrators) when necessary to operate the offering or comply with legal obligations. 

3. How We Use Information

We use the information we collect to: 

  • Provide, operate, maintain, and improve the Services. 
  • Respond to inquiries, schedule calls, and communicate with you about the Services and potential investment opportunities. 
  • Administer the investor intake process and provide access to the investor data room where appropriate. 
  • Conduct internal due diligence, investor relations, and recordkeeping. 
  • Carry out compliance-related processes (including verifying Accredited Investor status for Rule 506(c) offerings, conducting “bad actor” checks, and complying with anti-money laundering/OFAC and other legal requirements, as applicable). 
  • Monitor and help protect the security and integrity of our website and systems, including preventing fraud, abuse, and unauthorized access. 
  • Send administrative messages (for example, confirmations, notices about changes to our Services, or security alerts). 
  • Send marketing or informational communications (where permitted by law). You may opt out of marketing emails at any time (see Section 8). 

4. How We Disclose Information

We may disclose information in the following circumstances: 

  • Service providers: We may share information with vendors and service providers that perform services for us (for example, website hosting, analytics, form processing, CRM, email delivery, scheduling tools, and data room/document hosting). They may access information only as needed to perform services for us and are expected to protect it. 
  • Affiliates: We may share information with our affiliates for purposes consistent with this Privacy Policy, including operating and administering private investment offerings and investor communications. 
  • Professional advisers: We may share information with our attorneys, accountants, auditors, administrators, and other advisers in connection with professional services. 
  • Legal and compliance: We may disclose information to comply with applicable law or legal process; respond to lawful requests from public authorities; enforce our rights; investigate or prevent fraud or security issues; or protect the rights, property, or safety of us, our users, investors, or others. 
  • Business transfers: If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, or sale of assets, information may be transferred as part of that transaction. 
  • With your direction/consent: We may disclose information when you request or authorize us to do so. 

5. Investor Data Room and Confidential Materials

Our Services may include access to confidential materials in an investor data room. Access may be conditioned on completing an intake form and acknowledging confidentiality obligations. We may use third-party platforms to host data room materials. Your use of those platforms is also subject to the platform provider’s terms and privacy practices. 

We may log access to data room materials (for example, user identifiers, access time, and pages or files accessed) to help safeguard confidential information, maintain audit trails, and support compliance and security. 

6. Cookies and Similar Technologies

We may use cookies, web beacons, pixels, and similar technologies to operate our website and help us understand usage. These technologies may be used for: 

  • Essential functionality (for example, enabling core site features). 
  • Preferences (for example, remembering choices). 
  • Analytics (for example, understanding how visitors use the site). 
  • Security (for example, detecting fraud or abuse). 

 

You can control cookies through your browser settings and may be able to disable some cookies. If you disable cookies, some features of the Services may not function properly. Where required, we may provide additional cookie notice and choice mechanisms. 

7. Data Security

We maintain administrative, technical, and physical safeguards designed to protect information against unauthorized access, disclosure, alteration, or destruction. However, no security measure is perfect and we cannot guarantee absolute security. 

8. Your Choices

Marketing emails: You may opt out of marketing emails by using the unsubscribe link in the email or by contacting us. You may still receive non-marketing communications (for example, administrative messages). 

Access, correction, and deletion requests: Depending on your jurisdiction, you may have the right to request access to, correction of, or deletion of certain personal information. You may submit a request using the contact information in Section 12. We will respond as required by applicable law and may need to verify your identity before processing requests. 

9. Additional U.S. State Privacy Disclosures

Certain U.S. states provide residents with additional privacy rights. These may include the right to: 

  • Request access to and receive a copy of personal information we maintain about you. 
  • Request deletion of certain personal information. 
  • Request correction of inaccurate personal information. 
  • Opt out of certain processing activities (for example, targeted advertising) in some jurisdictions. 

 

We do not sell personal information for monetary consideration. If our practices change in a manner that requires additional notice or opt-out mechanisms under applicable law, we will provide them. 

California residents: California law provides certain rights regarding personal information, including the right to opt out of the “sale” or “sharing” of personal information in certain circumstances, and the right to request correction or deletion. You may submit requests using the contact information in Section 12. 

10. International Visitors

Our Services are intended for users in the United States. If you access the Services from outside the U.S., you understand that your information may be processed in the United States and other jurisdictions where our service providers operate, which may have different data protection laws than your jurisdiction. 

11. Children’s Privacy

Our Services are not directed to children under 18, and we do not knowingly collect personal information from children. If you believe a child has provided personal information to us, please contact us and we will take appropriate steps to delete it. 

12. Contact Us

If you have questions about this Privacy Policy or want to submit a privacy-related request, contact us: 
  • Mail: 9200 NW 39th Ave., Suite 130 – 1002, Gainesville, FL 32606 

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will post the updated version on this page and update the “Last Updated” date at the top. Your continued use of the Services after the effective date of the updated Privacy Policy constitutes acceptance of the updated terms, to the extent permitted by law.