1. Introduction and Overview

Five25 Capital, LLC (“Five25 Capital” “Five25,” “we,” "525," “us,” or “our”) is a private organization concentrated on commercial real estate lending and investing, and at the core of our business is sound data governance and security principles. We respect the privacy of the visitors to our website, and we are committed to protecting data privacy through our compliance with this privacy policy (“Privacy Policy”). This Privacy Policy applies specifically to the website www.five25capital.com(“the Site”).

This Privacy Policy describes how Five25 Capital collects, stores, uses, and protects your information when you engage with us and use our Site or any other websites, features, or content that direct the viewer to this Privacy Policy and that are owned and operated by Five25 Capital or its respective subsidiaries and affiliated companies. It also describes the rights you have in relation to your personal information.

By using our Site, you understand and agree that collection and use of your personal information will be made in accordance with this Privacy Policy.  If you do not feel comfortable with any part of this Privacy Policy or our Terms of Service, please discontinue use of the Site or engaging withFive25 Capital immediately.

If you have questions about this Privacy Policy or our Site practices, we invite you to send us inquiries or feedback as described in the “Contact Us” section below.

2. Updates to this Privacy Policy

This Privacy Policy went into effect on the “Effective Date” date noted near the top of this page.  We may update this Privacy Policy from time to time. We will notify you of any modifications to this Privacy Policy that might materially affect your rights or the way that we use or disclose your personal information prior to such a change.  We encourage you to look for updates and changes to this Privacy Policy by checking the “Last Updated” date on this Privacy Policy when you access our Site.

3. Information We Collect About You and How We Collect It

Five25 Capital collects personal information when you interact with our Site or otherwise engage with us in-person, over the phone, or offline. Personal information is any information that identifies or makes an individual identifiable. The definition of personal information depends on the applicable law based on your physical location. Only the definition that applies to your physical location will apply to you under this Privacy Policy.

The types of personal information that we may collect about you include, but may not be limited to: information you provide to us, information collected automatically about your use of our Site, and information from third parties.

Information You Voluntarily Provide Us.  The personal information that we collect from you may include:

• Account Registration: information relating to the creation of an account, such as first and last name, email address, postal address, telephone number and/or a unique individual password;
• Form Submissions:  information that you provide by filling in forms that we make available on the Site, such as to request a quote or to contact us to request information or assistance, including your name, title, email address, phone number, company name, loan type, asset type, and amount.
• Mailing List Sign-Ups:  information relating to our newsletter sign-up page, including your email address;
• Technical Support and Customer Service:  information you provide when you report a problem with the Site or otherwise communicate with us by email, via our Site, by telephone, in writing, or through other means, including any records and copies of your correspondence that you provide;
• Third-Party Contact Information:  the name and email address of individuals to whom you send information via our Site, such as if you share a Featured Insight; and
• Job Applications:  your name, email address, phone numbers, and any attachments you upload as part of applying for open positions posted on our Careers webpage or elsewhere.
• Information We Collect Automatically.  As you navigate through our Site or otherwise interact with Five25 Capital, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including:
• Information About Your Use of the Services: when you browse our Site, our systems automatically collect information such as your web request, Internet Protocol (“IP”) address, browser type, browser language, domain names, referring and exit pages and URLs, platform type, pages viewed and the order of these page views, the amount of time spent on particular pages, and the date and time of your request.
• Device Information: if you access the Site through a mobile device (e.g., a smart phone or tablet), we may be able to identify the general location of your mobile device, your mobile device’s brand, model, operating system, resolution, screen size, system version, mobile network information, and your mobile device’s advertising ID.
• Performance Data:  we may collect information about your preferences to make your use of the Site more productive, via the use of cookies or similar tracking technologies, as described in more detail in this Privacy Policy.
• Information We Collect from Third Parties.  When you interact with our Site or accounts on a social media platform, we may collect the personal information that you or the platform make available to us on that page or account, including your social media account ID and/or user name associated with that social media service, your profile picture, email address, friends list or information about the people and groups you are connected to and how you interact with them, and any information you have made public in connection with that social media service. The information we obtain depends on your privacy settings on the applicable social media service; we will comply with the privacy policies of the social media platform and we will only collect and store such personal information that we are permitted to collect by those social media platforms. When you access our Site through social media channels or when you connect our Site to social media services, you are authorizing us to collect, store, and use such information and content in accordance with this Privacy Policy.

We also may supplement your business contact information with information from third party sources, in order to verify your identity or to enrich what we know about your or your company through business intelligence services.

4. How We Use Your Information

Five25 Capital uses your information for business and commercial purposes, including to provide the commercial real estate lending, investing, and advisory services that you request; to perform customer service functions; for security and fraud prevention; for marketing and promotional purposes; and to perform website analytics.

We may use the information we collect about you in the follow ways:

a.  To Provide You Our Services:  providing any services or products that you request or purchase in connection with the Site, such as to process your application, fulfill our contracted for services, and provide information in relation to our financing options, loan platforms, and real estate investment sales;

b.  To Provide You with Service-Related Communications:  contacting you regarding the administration of any features or functions of the Site you have registered to use, and notifying you about changes to our Site and services, our policies, terms or any products or services we offer or provide though our Site;

c.  To Provide Customer Support or to Respond to You:  responding to your questions or other requests;

d.   To Send You Marketing and Promotional Emails: contacting you with newsletters, marketing or promotional materials and other information that may be of interest to you based on the services that you already use or the offerings that you have already inquired about, unless you have opted not to receive such information;

e.  For Internal Use and Services Improvement:  accumulating and reporting aggregate, statistical information in connection with the Site and user activity, including determining which features and services users like best to help us operate, enhance and improve our Site;

f.   To Enforce Compliance with Our Agreements or Policies: keeping you secure and safe while interacting with us or using our Site, which requires us to process your personal information in accordance with this Privacy Policy to combat spam, malware, malicious activities, fraud, or security risks, as part of our ongoing maintenance and enforcement of our security measures;

g.  To Maintain Legal and Regulatory Compliance: processing personal information to pay our taxes, fulfill our business obligations, ensure compliance with employment and recruitment laws, or as necessary to manage risk under applicable law;

h.  For Research Purposes: for research purposes and to provide reporting for external clients and business partners that does not contain personal information;

i.  With Your Consent: for any other purpose disclosed to you prior to you providing us your personal information or which is reasonably necessary to provide the services or other related services requested, with your permission or upon your direction; and

j.  For Employment Purposes:  processing job applications, including to communicate with you and to conduct applicant and employment-related statistical evaluation and record-keeping.

5. How We Share Your Information

We share your information as needed to fulfill the purposes described in this Privacy Policy and as permitted by applicable law.  We may share your information in the following circumstances:

• We may share information between and among Five25 Capital subsidiaries and affiliated companies for purposes of management and analysis, decision making, and other business purposes;
• We may share your information with service providers that provide us with support services, such as website hosting, email and postal delivery, service delivery, analytics;
• We may disclose your information if we believe that the disclosure is required by law, if we believe that the disclosure is necessary to enforce our agreements or policies, in response to valid requests by public authorities (e.g., a court or a government agency), or if we believe that the disclosure will help us protect the rights, property, or safety of Five25 Capital or our customers;
• We may disclose your personal information for any purpose with your consent; and
• We may share your information in a way that does not directly identify you. For example, we may share information about your use of our Site in a manner that does not identify you, or we may combine information about the nature or frequency of your transactions with similar information about other people and share the aggregated information for statistical analysis and other business purposes.

6. Cookies and Similar Technologies

We and business partners we allow on our Site may use a variety of technologies to collect information about your device and use of our Site, including cookies. Cookies are small files that a site or its service provider transfers to your computer’s hard drive through your Web browser (if you allow it) that enables the site’s or service provider’s systems to recognize your browser and capture and remember certain information.

For instance, we use cookies to understand and save users’ preferences for future visits and to compile aggregate data about site traffic and site interactions in order to offer better site experiences and tools in the future. We may also use trusted third-party services that track this information on our behalf.

You may be able to reject cookies, web beacons, entity tags and HTML5 local storage by adjusting the appropriate settings in your browser.

• Browser Settings.  Each browser is different, but many browsers have preferences or options that may be adjusted to allow you to either accept or reject cookies and certain other technologies before they are set or installed, or allow you to remove or reject the use or installation of certain technologies altogether. If you want to learn the correct way to modify your browser settings, please use the Help menu in your browser or review the instructions provided by the following browsers: Internet Explorer, Google Chrome, Mozilla Firefox, Safari Desktop, Safari Mobile; and Android browser.
  Please note that if you turn cookies off, some features of the Site will be disabled, will not run as efficiently, or may not function properly.
• Google Analytics.  For more information on how to opt-out of tracking technology from Google Analytics, click here.
• Interest-Based Advertising Opt-Outs.  Many advertising companies that collect information for interest-based advertising are members of the Digital Advertising Alliance (DAA) or the Network Advertising Initiative (NAI), both of which maintain websites where people can opt out of interest-based advertising from their members for a particular web browser. To opt-out of website interest-based advertising provided by each organization’s respective participating companies, visit the DAA’s opt-out portal available at http://optout.aboutads.info/, or visit the NAI’s opt-out portal available at http://optout.networkadvertising.org/?c=1.
• “Do Not Track” Technology.  Some newer web browsers have a “Do Not Track” preference that transmits a “Do Not Track” header to the websites you visit with information indicating that you do not want your activity to be tracked. We currently do not respond to browser “Do Not Track” signals, as there is no standard for how online services should respond to such signals.

7. How We Protect Your Information

Five25 Capital protects your information using administrative, technical, and physical security measures to reduce the risk of loss, misuse, unauthorized access, disclosure or modification of your information. We strive to ensure that information is only accessible by a limited number of persons who have special access rights to such systems and are required to keep the information confidential.

However, no system can be guaranteed to be 100% secure, and due to the inherent nature of the Internet, we cannot guarantee that data, including personal information, is absolutely safe from intrusion or other unauthorized access by others. You are responsible for protecting your password(s) and maintaining the security of your devices at all times.

8. Retention and Disposal of Your Information

We store personal information as needed to accomplish the purposes identified in this Privacy Policy and to meet legal requirements, including record retention, resolving disputes, and enforcing our agreements.  The storage period may extend beyond the term of your relationship with Five25 Capital.

When personal information is no longer needed, or in any event, after legal authority to retain it has expired, personal information will be destroyed, in accordance with local law and pursuant to procedures established in relation to the relevant Five25 Capital system or process.

9. Your Communications Preferences and Account Management

In order to provide service to you, we may send you communications related to your transactions, security, or the administration of the Site. From time to time, we may also send you other messages or updates about Five25 Capital, our sites, and our service offerings or other activities. If you do not wish to receive non-transaction or security-related communications from us, you may opt-out by clicking the “unsubscribe” link in the communication or by contacting us as specified in the “Contact Us” section below. Please note that if you opt out of receiving communications from us, we may still send you service communications such as emails about your account or the status of your application.

10. Your California Privacy Rights

This section applies solely to individuals who reside in the State of California.  The purpose of this section is to inform California residents (“consumers” or “you”), at or before the time of collection of personal information (as defined in California Civil Code Section 1798.140(o)), about our data collection practices and your privacy-related rights under California law, including the California Consumer Privacy Act, as amended (“CCPA”). Your “right to know” about personal information collected, used, and disclosed by Five25 Capital includes what categories of personal information we collect from you and the purpose for its collection; how we use those categories of personal information; and how we share the personal information you entrust to us.

In the preceding twelve months we may have disclosed these categories of personal information for a business purpose:

• Identifiers
• Personal information categories listed in the CCPA
• Commercial information
• Internet or similar electronic network activity
• Professional or employment-related information
• Education information
• Inferences drawn