Privacy Policy

DiversyFund,Inc. and its affiliates (collectively, “DiversyFund”provide an online investment platform and related tools to assist potentialinvestors and others who are interested in investing in alternative assets suchas real estate investment funds and single property investments. This privacypolicy (our “Privacy Policy”)describes our data practices regarding the use of Personal Information (definedbelow) collected through our website and its subdomains located (the “Site”), orthrough our app (collectively, the Site and app are the “Services.”) This Privacy Policy does not apply to any PersonalInformation collected by third party websites or apps not operated byDiversyFund.

Byaccessing the Site or using our Services, you are consenting to our use of yourPersonal Information in accordance with this Privacy Policy. Your access to anduse of the Services is also subject to the DiversyFund Terms of Use located at

As afinancial company, federal law (the Gramm-Leach-Bliley Act, or “GLBA”) alsorequires us to tell you how we collect, share, and protect your PersonalInformation. Please see the GLBA Appendix at the end of this Privacy Policy tolearn more about how we treat your Personal Information under GLBA.

Information DiversyFund Collects About You

PersonalInformation You Provide

Weuse the term “Personal Information”to mean any information that could be used to identify you, including yourname, address, email address, birth date, financial information, phone number,or any combination of information that could be used to identify you. ThePersonal Information we collect from you depends on which Services you use andhow you interact with the Site.

SiteVisitors. We have structured our Site so that, as acasual site visitor, you may come to our Site and review selected informationabout our Services without registering. However, if you wish to become anInvestor, we require you to provide certain additional Personal Information.

Investors. If you choose to access ourServices as an Investor, we require that you complete a registration form. AnInvestor is an individual over the age of 18 who has completed the registrationprocess on the Site. Our registration forms specify the information you mustprovide in order to enjoy particular features to which you wish to subscribe,which may include (i) name; (ii) email address; (iii) phone number(s); (iv)mailing address; (v) social security number (for IRS tax reporting purposes);(vi) bank account number; and (vii) birth date. Our registration forms mayadditionally request information that you may, at your option, choose toprovide or withhold. To the extent this additional information constitutesPersonal Information, we will treat it in the manner specified in this PrivacyPolicy.


Wemay require each Investor to provide information designed to verify his or heridentity. This information may include (i) information from a successfullycompleted electronic check transaction, (ii) a credit report, or (iii) othersimilar information designed to authenticate and confirm your identity or tootherwise comply with applicable laws.

Wealso require each Investor to provide certain financial information. Forexample, we require that each Investor provide Internal Revenue Service FormW-9 data, which includes your Social Security Number (or TaxpayerIdentification Number, where applicable). We also require that Investorsprovide us certain account and other payment information, such as informationneeded to make payments via ACH, wire, or electronic checks. Our registrationprocess for Investors provides additional details on the types of paymentinformation needed.

Wealso may require each Investor to provide certain additional information suchas investment objectives, financial goals, income and net worth information andinvestment experience for regulatory compliance purposes.

Usersmay upload media files such as videos, photos, text, and other content to theSite to share with DiversyFund and other users. When you upload this content,we may also collect metadata associated with these media files including date,time, location and device information. DiversyFund’s use of such content willbe governed by our user-generated terms and conditions which are provided atthe time of collection of such content.

LocationData. We may collect your location information through our mobile applicationsby capturing the location (e.g. latitude/longitude) of your mobile device. Ifyou have given the app permission to access your location, we may collect yourdevice’s location even if you are not using the Service and store your locationhistory. If you want to opt-out of the collection of your location data, pleaseadjust your settings in your mobile device to restrict the app’s access to yourlocation data. Geolocation data may be used to enhance the Services, forexample to offer additional functionality and information regarding yourlocation in connection with the location of DiversyFund properties.


Evenif you do not register for an account on the Site, we may collect certaininformation automatically. For example, we may automatically receive and recordin our system the following information:

● your internet protocol (IP) address andlocation;

● referrer URL;

● the type and version of your web browser;

● device identifiers including mobileadvertising identifiers; and

● your operating system.

Wealso record page views and other general statistical and tracking information.We use this data to help us administer and operate our Site, to betterunderstand how our users access and interact with the Site, and for securityand monitoring purposes.

Wemay send email messages that use a “click-through URL” linked to content on ourSite. When you click one of these URLs, you pass through our web server beforearriving at the destination web page. We track this click-through data to helpdetermine interest in particular topics and measure the effectiveness of ourcustomer communications. If you prefer not to be tracked, simply do not clicktext or graphic links in the email.

How We Use Your Personal Information

Weuse your Personal Information for the following business purposes:

● to process transactions that you haveauthorized us to make;

● to facilitate your activities with respectto our Site;

● to contact you regarding administrativeissues, such as questions about your specific request, or otherwise respond toyour comments or requests;

● to verify and authenticate your identity,to help us ensure that the individuals who use the Site and Services are whothey claim to be;

● to prevent, detect, mitigate, andinvestigate fraud, security breaches, and potentially prohibited or illegalactivities, including, for example, activities prohibited by the Anti-MoneyLaundering Act;

● to help us operate our Site;

● to deliver notices regarding your account;

● to comply with IRS requirements and for taxreporting purposes;

● to provide you with information, such asnotices of investment opportunities via our Site or updates concerninginvestments that you have participated in;

● to send you information we believe isrelevant to you, such as news, bulletins, marketing materials, or otherinformation;

● to enforce this Privacy Policy and ourTerms of Use;

● to conduct user surveys and questionnaires;and

● to comply with applicable laws.

Weuse aggregated information to analyze the effectiveness of our Site, to improveour Services, and for other similar purposes. In addition, from time to time,we may undertake or commission statistical and other summary analyses of thegeneral behavior and characteristics of users participating in our Services andthe characteristics of visitors at our Site, and may share aggregatedinformation with third parties, including advertisers. We may collectaggregated information through features of the software that support ourServices, through cookies, and through other means described in this PrivacyPolicy.

Toenable us to better understand the characteristics of our Investors and/or toprovide services tailored to your needs, we may combine the PersonalInformation an Investor provides with certain automatically-collectedinformation that would not otherwise be personally identifiable. If we combineor link any automatically-collected, non-individually identifiable informationwith your Personal Information, the resulting combination will be treated asPersonal Information under this Privacy Policy.

How We Share Personal Data

We donot disclose your Personal Information to unaffiliated third parties except asprovided in this Privacy Policy, as follows:

ServiceProviders. To assist us in running our business and to perform certainservices and functions, we may share your Personal Information with third-partyproviders of hosting, payment processing, transfer agent, compliance and auditservices, email communication and customer support services, analytics,marketing, and advertising service providers (including Google, Facebook,Instagram and Zendesk among others), which companies provide integratedservices to us as part of our product.

For users who choose to link their bankaccounts, we use Plaid Technologies, Inc. (“Plaid”) and/or GIACT (“GIACT”) tofacilitate the automatic connection with, and gather required transaction datafrom, your financial institution. In particular, as well as facilitatingtransactions, we use Plaid and GIACT  toprevent overdrafts on your account and to prevent, detect, and mitigate fraud.By using our joint services, you grant us, Plaid and GIACT the right, power,and authority to act on your behalf to access and transmit your personal andfinancial information from the relevant financial institution. You agree toyour personal and financial information being transferred, stored, andprocessed by Plaid and GIACT in accordance with the Plaid Privacy Policy(located at andGIACT Privacy Policy (located at


IRA. We team up with third-partycustodians to allow you to invest your IRA funds in diversified alternativessuch as commercial real estate investments. These parties are not affiliatedwith DiversyFund, but act as a directed custodian for IRAs and other custodialaccounts. If you elect to initiate the opening of a self-directed IRA accountwith DiversyFund, we streamline the enrollment process by sharing certainPersonal Information with these custodians, including but not limited to yourname, Social Security number, date of birth, and contact information. You arenot required to invest your IRA funds as a condition of using the Services.

Affiliates.We may share information with our affiliates, meaning an entitythat controls, is controlled by, or is under common control with DiversyFund.Our affiliates may use the Personal Information we share in a manner consistentwith this Privacy Policy.

ForLegal Reasons. We may share your Personal Information tothe extent we reasonably believe we are required to do so by law or to complywith legal or regulatory requirements, or to protect against fraud, illegalactivity, or to otherwise protect DiversyFund against liability.

InConnection with a Corporate Transaction. In the event of atransaction or proposed transaction involving the transfer of substantially allof the assets of DiversyFund or one or more of its businesses to anotherentity, whether an affiliate or a third party, or in connection with abankruptcy, we may share your Personal Information in the diligence process orto otherwise facilitate the transaction, and with individuals assisting in thetransaction or in connection with a bankruptcy. Your Personal Information mayalso be one of the transferred assets as part of the transaction or bankruptcy.

ForSafety & Security. We may reveal your Personal Informationto third parties, including law enforcement agencies, in order to protect thesafety and security of our users or of any third party.

Cookies and Similar Technologies

A cookie is a small amount of data, oftenincluding a unique identifier, which is sent to your browser from a website andstored on your computer’s hard drive. You can read more about how we usecookies in our Cookie Policy.

Feedback, Questionnaires and Surveys.

OurSite allows site visitors and Investors to participate in surveys andquestionnaires which from time to time we may post on the Site. We alsoencourage our users to provide feedback to us about our Site and our Services.You are free to choose whether you participate in these activities. We may askthat, in addition to providing your responses, you also provide us with yourcontact information. In these instances, we use any Personal Information youchoose to provide to us in connection with these activities for the purposesfor which you submit the information.

Weaggregate information derived from survey and questionnaire information – withyour Personal Information removed – for monitoring or improving the use andappeal of this Site (with no other obligation to you and, specifically, with noobligation to compensate you for these uses). You are not obligated toparticipate in any of these activities.

Links to Other Sites

Thisprivacy statement applies only to Personal Information collected by our Site.Our Site contains links to other sites that are not owned or controlled byDiversyFund. DiversyFund is not responsible for the privacy practices of suchother sites, and we encourage you to be aware when you leave our Site and toread the privacy statements of each and every web site that collects PersonalInformation.


International users

The Site may beaccessed by users located outside the United States. If you choose to use theServices from the European Union or other regions of the world with lawsgoverning data collection and usethat may differ from U.S. law, please note that you are transferring yourpersonal information outside of those regions to the United States, and that byproviding your personal information on or through the Site you consent to thattransfer.

Data Security

We have put in placecommercially-reasonable security systems intended to prevent unauthorizedaccess to or disclosure of Personal Information, and we take reasonable stepsto secure and safeguard this Personal Information against loss, theft, andunauthorized use, disclosure, or modification. With that said, there is no suchthing as 100% security of the networks, servers, and databases we operate orthat are operated on our behalf. For example, email sent to or from the Sitemay not be secure. Before submitting any Personal Information via the Site,please be aware of these inherent risks and understand that you do so at yourown risk.


Data Retention

Wekeep your Personal Information for as long as reasonably necessary for thepurposes described in this Privacy Policy, while we have a legitimate businessneed to do so in connection with your account, or as required by law (e.g., for tax, legal, accounting orother purposes), whichever is longer.

Your Choices

Ingeneral, you may browse the Site without providing Personal Information.However, if you choose not to provide certain Personal Information through ourSite, we may not be able to provide certain services or process certain of yourrequests. You will not be able to become an Investor or use all of the featuresand products that we offer through this Site.

Dependingon the functionality associated with the Site feature you are using, you may beable to update or delete certain of your Personal Information on the Site.Accordingly, at your request, we will take reasonable steps to remove yourPersonal Information from our databases. Please note, however, that:

● we may not be permitted to delete yourPersonal Information completely, due to IRS and regulatory reportingrequirements, investments on the platform and the rights thereof, and databackups and records of deletions;

● if you request deletion of your PersonalInformation, you may be unable to use certain features of the Site and anyassociated Services;

● certain of your Personal Information mayremain in our databases following the deletion of your account; and

● we may not be able to remove de-identified,anonymous, or aggregate data from our databases.

Anydeletion requests may be sent to

If you no longer wish to receive marketingemails from us, you can opt out of these communications by clicking on the“unsubscribe” link included in those emails, or by contacting us Please understand that you will not be allowed toopt-out of transactional notices or other legal and related notices concerningyour relationship to the Site or your account.


Children’s Privacy

OurSite is not directed to children under the age of 18. We do not knowingly seekto collect or maintain Personal Information or other information from childrenunder the age of 18. We will use commercially reasonable efforts to delete anyPersonal Information or other information later determined to be provided by achild under the age of 18. Use of the Site by children under the age of 18 isnot permitted. If you become aware that a minor has provided PersonalInformation through our Site, please email us at

Changes to This Privacy Policy

We reserve the right to alter, modify,update, add to, subtract from or otherwise change this Privacy Policy at anytime, which will become effective as of posting on the Site. We encourage youto periodically review this Privacy Policy to stay informed about how wecollect, use, and share Personal Information.

AdditionalNotice to California Residents

We are required by the California ConsumerPrivacy Act of 2018 (“CCPA”) toprovide this CCPA notice (“CCPA Notice”)to California residents to explain how we collect, use, and share theirPersonal Information and the rights and choices we offer California residentsregarding our handling of their Personal Information.

CCPAScope And Exclusions

This CCPA Notice, including the descriptionof our privacy practices and California residents’ privacy rights, applies onlyto California residents whose interactions with us are limited to:

● visiting our consumer websites;

● signing up for email alerts; and

● applying for our job openings on ourwebsites (however, note that the CCPA limits some of the privacy rights for jobapplicants).

This CCPA Notice does not apply to thePersonal Information we collect, use, or disclose about:

● consumers who initiate or complete theprocess of becoming an investor through DiversyFund. This is because thisinformation is subject to the federal Gramm-Leach-Bliley Act and implementingregulations or the California Financial Information Privacy Act (for additionalinformation relating to your choices about this information specifically, seethe GLBA Appendix at the end of this Privacy Policy); or

● representatives of businesses that seek toobtain our products or services, or to provide products or services to us.


The CCPA grants California residents thefollowing rights:

● Information. California residents canrequest information about how we have collected, used and shared their PersonalInformation during the past 12 months. We have made this information available toCalifornia residents without having to request it by including it in thisPrivacy Policy.

● Access. California residents canrequest a copy of the Personal Information that we maintain about them.

● Deletion. California residents canask us to delete the Personal Information that we collected or maintain aboutthem.

● Opt out of sale of Personal Information.California residents may request and obtain from us once a year, free ofcharge, a list of the third parties to whom we have disclosed their Personal Informationfor such third parties’ direct marketing purposes in the prior calendar year,as well as the type of Personal Information disclosed to those parties. DiversyFunddoes not share your Personal Information with third parties for their directmarketing purposes.

Please note that the CCPA limits theserights by, for example, prohibiting us from providing certain sensitiveinformation in response to an access request and limiting the circumstances inwhich we must comply with a deletion request. We will also respond to requestsfor information and access only to the extent we are able to associate with areasonable effort the information we maintain with the identifying details in arequest. If we deny a request, we will communicate our decision to therequester. California residents are entitled to exercise the rights describedabove free from discrimination.

How We Respond to “Do Not Track” Signals

Our Site currently does not respond to “DoNot Track” (DNT) signals and operates as described in this Privacy Policywhether or not a DNT signal is received. If we do so in the future, we willdescribe how we do so in this Privacy Policy.


If you have any questions about thisPrivacy Policy, the practices of our Site or Services, or your dealings withour Site or Services, please contact us at:


Symphony Tower

750 B Street, Suite 1930

San Diego, CA 92101