When we need to collect information from you to complete a requested transaction or provide you with a particular service, we will generally ask you to voluntarily supply us with the information we need. This information may include personal data used to verify your identity, allow you to log onto the site, verify your age, guard against potential fraud, and otherwise operate the Site consistent with legal and regulatory requirements, personal and financial data used to verify your status as an accredited investor, and other personal financial information used for a variety of purposes. We may also collect information about you from other sources, including but not limited to: (i) our communications with you, including information obtained when you register for a SBRE Funds product or service or otherwise volunteer information; (ii) your transactions with us, our affiliates, or others; (iii) outside companies, such as credit reporting agencies, to evaluate your creditworthiness and credit history; and, (iv) public sources, such as bankruptcy records and real estate records.
We divide information about you into two groups: (i) General Customer Information; and, (ii) Restricted Customer Information. “General Customer Information” is information about you and/or your business, including names, addresses, telephone numbers and email addresses, and similar information including information that may have been gleaned from “Restricted Customer Information.” “Restricted Customer Information” refers to information such as social security or tax identification numbers, dates of birth, tax returns, financial statements, employment status and salary information, business plans, reports obtained from credit reporting agencies, credit agreements with parties other than SBRE Funds or its affiliates or partners, bank account numbers, including routing numbers, and credit card numbers.
HOW SBRE FUNDS USES AND DISCLOSES THE INFORMATION WE COLLECT
We may use and/or disclose General Customer Information and Restricted Customer Information to companies related to us by common control or ownership (“affiliates”), as well as any third parties, contractors, consultants, and advisers we may engage to assist us in carrying out any transaction that you have requested of us or authorized, or as may be necessary to complete our contractual obligations with you. We may also use and disclose to affiliates and third-parties both types of information for auditing, research and analysis to operate and improve SBRE Funds’ services.
We may also use General Customer information in other ways, including, without limitation, to send you educational or promotional materials that we think may be of interest to you. From time to time we may also share your General Customer information with third parties so that these third parties can send you promotional materials regarding websites or the purchase of products or services that we think may be of interest to you. If you do not want us to share your General Customer Information with third-parties, you may opt-out by sending us an e-mail at optout@Fairwayamerica.com. Once we receive your opt out request, we will stop sharing your General Customer Information with these third-parties as soon as reasonably practical. Opting out of having your General Customer Information shared with third-parties will not remove you from our e-mail lists. If you no longer wish to receive promotional e-mails from SBRE Funds, please use the unsubscribe feature found in our commercial e- mails. Please note that you will, however, continue to receive service-related e-mail messages that concern products and services you obtain from or through SBRE Funds.
SBRE Funds may also share aggregated information that does not identify your identity with outside companies. “Aggregated Information” refers to information SBRE Funds gathers by aggregating non-identifiable information to provide summaries of our customers and their use of the Site. Aggregated Information is used to show usage patterns and to do such things as negotiate with providers of products and services that we may want to offer our customers.
Except as set forth above or as otherwise required or permitted by law, SBRE Funds will not share Restricted Customer Information with third-parties without your prior authorization.
Regardless of whether or not you have opted out of sharing your General Customer Information or provided us authorization to share your Restricted Customer Information, we reserve the right to use and disclose Aggregated Information, General Customer Information and Restricted Customer Information, as required, to comply with the law, applicable regulations, governmental and quasi-governmental requests, judicial proceedings, court orders or subpoenas, to enforce agreements between you and us, our affiliates, or partners, and to protect our and our affiliates’ rights, property or safety or to protect the rights, property or safety of others (e.g., to a credit reporting agency for fraud protection, or to prevent or limit fraud).
STORAGE OF INFORMATION
The security of the information you provide is extremely important to us. We maintain physical safeguards, such as secure areas in buildings, and electronic and procedural safeguards, such as passwords and access limitations. Access to Restricted Customer Information about you is restricted to authorized employees obtaining the information for business purposes.
After information reaches SBRE Funds, it is stored on a secure server that resides behind firewalls designed to block unauthorized access from outside of SBRE Funds. Remember, no method of transmission over the Internet, or method of electronic storage, is 100% secure (for example, any information you provide us by email is not encrypted). Therefore, while we will use commercially reasonable efforts to protect the information you provide us, we cannot guarantee its absolute security.
We may retain General Customer Information and Aggregated Information indefinitely. Restricted Customer Information will be retained for as long as you are a client or customer of SBRE Funds and thereafter to the extent required by applicable record retention policies or regulatory requirements.
BROWSING OUR WEBSITE
The Site does not collect personally identifiable information from your computer when you browse the Site and request pages from our servers. This means that, unless you voluntarily and knowingly provide us with personally identifiable information, we will not know your name, your email address, or any other personally identifiable information. SBRE Funds’ servers may automatically record non-personally identifiable information when you visit the Site or use some of our products. When you request a page from our website, our servers log the information provided in the HTTP request header including the IP number, the date and time of the request, the URL of your request, the language used, the browser type and any other information that is provided in the HTTP header. We collect the HTTP request header information in order to make our website function correctly and provide you the functionality that you see on this website. We also use this information to better understand how visitors use our website and how we can better tune it, its contents andfunctionality to meet your needs.
As is true of most websites, if you visit the Site, we will gather certain information automatically and store it in log files. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and click stream data.
We use this information, which does not identify individual users, to analyze trends, to administer the site, to track users’ movements around the site and to gather demographic information about our user base as a whole. We do not link this automatically-collected data to General Customer Information or Restricted Customer Information.
LINKS TO OTHER SITES
ENHANCEMENT OF INFORMATION
We may purchase marketing data from third parties and add it to our existing user database, to better target our advertising and to provide pertinent offers in which we think you would be interested. To enrich our database of individual customers, we tie this information to the information they have provided to us.
In the event that SBRE Funds goes through a business transition, such as a merger, acquisition by another company, or sale of all or a portion of its assets, your General Customer Information and Restricted Customer Information as well as Aggregated Information will likely be among the assets transferred. By using the Site, you consent to any such transfer of your information to SBRE Funds’ acquirers, successors, and assigns.