Privacy Policy

This Privacy Policy was last revised and is effective as of March 1, 2023

PLEASE CAREFULLY READ THIS PRIVACY POLICY WHICH IS INCORPORATED INTO OUR TERMS OF USE AND FORMS A PART OF YOUR AGREEMENT WITH US. BY USING OUR WEBSITE YOU ARE ACKNOWLEDGING YOU HAVE READ, UNDERSTAND AND AGREE TO COMPLY WITH AND BE BOUND BY EVERYTHING WRITTEN HERE. IF YOU CANNOT OR DO NOT AGREE OR DO NOT WISH YOUR PERSONAL INFORMATION TO BE SUBJECT TO THIS PRIVACY POLICY, PLEASE LEAVE OUR WEBSITE IMMEDIATELY AND DO NOT USE OUR WEBSITE.

IF YOU ARE AN INVESTOR OR SUBSCRIBER, YOU MUST ALSO READ OUR INVESTOR AGREEMENT, AS WELL AS ANY PRIVACY NOTICE, BOTH OF WHICH APPLY TO YOU AND WHICH ARE INCORPORATED INTO OUR TERMS OF USE AND FORM PART OF YOUR AGREEMENT WITH US. WHEN YOU BECOME AN INVESTOR OR SUBSCRIBER AND EACH TIME YOU LOG INTO OUR INVESTOR PORTAL, YOU ARE ADDITIONALLY CONFIRMING THAT YOU HAVE READ, UNDERSTAND AND AGREE TO COMPLY WITH AND BE BOUND BY THE TERMS AND CONDITIONS OF EACH OF THESE DOCUMENTS. PLEASE NOTE THAT PRIVACY NOTICES MAY BE SPECIFIC TO THE INVESTMENTS, SUBSCRIPTIONS AND/OR FUNDS TO WHICH OR IN WHICH YOU ARE SUBSCRIBING OR INVESTING, SO READ THE APPLICABLE INFORMATION PROVIDED TO YOU CAREFULLY.

As defined in our Terms of Use, “Company”, “we”, “us” or “our”, “ours” an similar terms, means and refers to Calvera Partners, LLC, and any other term not defined in this Privacy Policy, has the meaning defined or ascribed to it in our Terms of Use.

Your privacy and the protection of information about you is important and this Privacy Policy describes our privacy practices, including how we obtain, collect, store and use information obtained from users of the Website. This Privacy Policy also describes your rights and our obligations, as well as the choices available to you, with respect to your personal information. If, after reading this Privacy Policy, you have any questions or require more information, do not hesitate to contact us. This Privacy Policy only applies to your online activities and information we obtain when you use the Website. It does not apply to any information we obtain offline or through channels other than the Website.

If you are an Investor, certain personal information is critical to the provision of our services to you and if you do not provide or allow us to obtain the necessary personal information from you, you will not be able to access or use our Investor Portal. If, for any reason, you do not agree with all of the provisions of this Privacy Policy, our Terms of Use or our Investor Agreement, you may not and should not use or attempt to use our Investor Portal. Of course, like any other visitor, you may still browse our Website and the provisions of this Privacy Policy will still apply to you. Please understand that if you use our Website you are agreeing to be bound by everything in this Privacy Policy and if you log in, access and use the Investor Portal, you will be agreeing to all of the terms, conditions and provisions of this Privacy Policy. 

What is Personal Information?

If you are a visitor, but not an Investor, our Website provides limited features and functionality, but even if you are just browsing (visiting) and you do not enter or request us to send you any information, we may still obtain information the law considers “personal information” (defined below). Of course, if you do give us personal information (e.g., your name, telephone number, email address), we have the right to use your personal information to respond to you, in addition to any other rights described in this Privacy Policy. 

In this Privacy Policy, we use the term “personal information” to mean and refer to any data or information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular person or household or that could uniquely identify a person. Laws and regulations of some jurisdictions define personal information or personally identifiable information very broadly and even include things such as IP protocols, browser and mobile device data, so if there is any possibility we may be able to determine an individual’s identity using the Website, even if we have no intention of doing so, it may still be covered by these laws. Consequently, for purposes of this Privacy Policy we include all of these within the meaning of “personal information.” Personal information does not include information that is deidentified or aggregated in a way that no individual can be readily identified.  

Our Website is Not for Children

As also mentioned in our Terms of Use, our Website is not intended for children and we do not knowingly collect information from anyone under the age of 18 or not considered an adult (a “child”). If you are a parent or legal guardian and determine or suspect we may have received any information from or about your child, please notify us immediately. We will confirm you are the parent or legal guardian and then promptly take steps to delete your minor child’s information anywhere it may be in our possession or under our control.  

We Use Service Providers

We may also use third-party operational service providers, website and communications support resources and other professionals in the hosting, operation, maintenance and support of the Website, including our Investor Portal (“Service Providers”) and when we use terms such as “us”, “we”, “our” or “ours” in this Privacy Policy, we are also referring to and include those third parties. If we do use Service Providers, although they may change from time to time and at any time, based on our business and operations, we will have agreements with each of them that obligate them to the same requirements regarding your personal information that apply to us under this Privacy Policy. If a change in any of our Service Providers requires a transfer of your personal information to a new Service Provider, you agree we have the right to do so and you consent to the transfer, subject to our ensuring we have an agreement in place obligating them to comply with these requirements. 

Juniper Square, Inc., a Delaware corporation (“Juniper Square”) is one of our Service Providers. Juniper Square hosts and operates the Investor Portal and provides certain investor management and communication services to Calvera and our investors (the “JS Services”). As operator of the Investor Portal, Juniper Square has access to, stores and processes all personal information received and collected about you by means of the Investor Portal, as well as information that we furnish to Juniper Square about you, for the purpose of hosting and operating the Investor Portal and facilitating provision of products and the JS Services to you. Juniper Square does not direct or control our use or storage of personal information about you. Juniper Square’s collection, use and disclosure of your personal information is described in the Juniper Square privacy policy, which is available at https://www.junipersquare.com/privacy-policy. If Juniper Square, or substantially all of Juniper Square’s assets, are acquired, or in the unlikely event that Juniper Square were to go out of business or enter bankruptcy, all user information will be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of Juniper Square may continue to use your personal Information as set forth in this Privacy Policy as supplemented by the Juniper Square Privacy Policy (as it may be amended from time to time).

Laws that Apply to You

Although the principal location of our business is in the United States, we use cloud-based technology and/or servers that may also be located in other jurisdictions in order to provide optimal experiences for visitors and Investors. We use Service Providers in the hosting, operation, maintenance and support of the Website, including the Investor Portal portion of our Website, and when we use terms such as “us”, “we”, “our” or “ours” in this Privacy Policy, we are also referring to and include those third-party Service Providers. If and when we use Service Providers, we will have agreements with each of them that obligate them, at a minimum, to the same requirements regarding your personal information that apply to us under this Privacy Policy. If you are not a citizen or legal resident of the United States, your country may not consider the privacy or data protection laws and regulations of the United States adequate and if you choose to use the Website you are expressly consenting to and authorizing the export, transmission, storage and use of your information, including personal information, to, from and within the United States of America, and understand and agree it will be subject to the provisions of this Privacy Policy, as well as the Federal and State laws and regulations applicable in the United States of America and not the laws of any other jurisdiction.

How We Obtain Information

Browsing: When you use our Website, we may automatically collect and store non-personal elements of information related to your use. Generally, all this non-personally identifiable information is recorded in such a way that it does not reflect or reference any identifiable individual. However, even though this information does not identify you, as mentioned above, the law may include this information within the definition of personal information. For example, non-personally identifiable information may include the type of Internet browser and operating system you are using, your IP address, the domain of the website you came from (sometimes called a referring URL), how many times and the dates and times of your visits and the average amount of time you spend on the Website. Sometimes the Website may also be able to identify the application or device you are using, your mobile network (e.g., carrier name and phone number) and the interaction of your apps, browser and devices with the Website. Technology may enable us to determine when you search on the Website for particular words and the content your browser opens. We may keep track of pages you visit, content your browser displays, as well as third-party advertisements and content and even the hypertext links you select on the Website. Gathering this information can help us better understand how to improve the Website and the user experience when you visit. Sometimes, with varying degrees of accuracy, your location can be determined by your IP address, GPS, sensor data from your device or from nearby technology (e.g., Wi-Fi access points; cell towers; Bluetooth-enabled devices) and the capability to capture this type of information often depends on your device location settings, which you generally have the ability to turn on or off.  

Our Website may also use technology to remember whether you have been there before. A “cookie” (i.e., a text file placed on your hard disk by a web page server) is one example, but there are currently many different types of technology that perform similar functions (e.g., pixel tags, server logs, invisible GIFs, web beacons, application data caches). Some of the technology the Website uses makes things more efficient and may provide faster loading times for content that benefit users or Investors who visit the Website repeatedly. Similarly, unique, non-personal identifiers (“tags”) enable us to track information without identifying you or any individual. Tags may simply be strings of characters that can uniquely identify a browser, app, or device. You may be familiar with an IMEI number associated with your mobile device - a unique identifier incorporated into the device by the manufacturer. Most browsers and some devices give you the ability to configure your settings to refuse cookies or indicate when a cookie is being sent or prevent certain data gathering or tracking technologies. While you should configure those settings in any way you prefer, some features, functions and content on the Website may not function or be displayed fully or properly based on your choice of settings. 

Our Website does not support Do Not Track and we do not respond to Do Not Track requests. “Do Not Track” or “DNT” is a preference you can set in your browser to inform websites you do not want to be tracked. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser. 

Contacting Us

When you enter your personal information for any reason (e.g., to ask us to contact you, you request information, during registration as an Investor) you understand, acknowledge and agree that by doing so you are requesting us and giving us your permission and explicit consent to allow us to use your personal information to respond to you or perform services necessary to handle your request. If you ask us to respond to you by email, you will always be given the ability to opt out of receiving future unsolicited emails by using the unsubscribe link at the bottom of each email we send you, or by contacting us at the address below in this Privacy Policy. 

If you are an Investor, we encourage you to set up an online account and use our Investor Portal. When you do register, you will be providing us with additional personal information that helps us authenticate you so that you can log in to the Investor Portal portion of our Website. As an Investor, you are similarly giving us your permission and explicit consent to use any and all of your personal information to interact, communicate and process any transactions relevant to your account and status as an Investor. While you also have the right to opt out of receiving unsolicited emails as mentioned above, you understand we will always have the right to contact you about your account, your transactions, and other account and customer service related matters that apply to you as an Investor. 

How We Store, Use, Share and Disclose Information

Storing: We may store personal information on servers and storage media of ours or our Service Providers and we may share personal information in aggregate or anonymous form with third parties for storage purposes and to help gather statistics and Website analytics or to respond to your requests. Service Providers with whom we share personal information are prohibited from using personal information and are required to treat and handle personal information, at a minimum, in a manner consistent with this Privacy Policy.  

Using: There are a number of purposes for which we use the information, including personal information, that we obtain and below is a summary of those purposes. Although some are already mentioned above, they are worth repeating: 

  • To process your transactions and communicate with you regarding your Investor account;  
  • To permit Service Providers that are performing services for, or functions on behalf of, us or any limited partnership, limited liability company, or other entity which we sponsor, to perform such services, such as accountants, auditors, banks, attorneys or administrators; 
  • To give effect to, administering or enforcing a transaction requested or authorized by any current or former Investor in any of our affiliated real estate partnerships or limited liability companies;
  • For required institutional risk control or resolving disputes or inquiries of a current or former Investor; 
  • To respond to your inquiries, provide Investors with customer service and help resolve any issues;  
  • To personalize your experience as an Investor when you use the Website and sometimes notify you of promotions, offers or other content we may offer or make available to Investors; 
  • To help operate, administer, maintain and improve the quality and performance and operation of the Website and obtain analytical data and metrics so we can better understand how our Website is being used and improve your experience when using our Website;  
  • To track outages or troubleshoot problems;   
  • To provide information or to contact you in response to your requests or otherwise as permitted by law; 
  • To allow us to deliver and improve Content, including Links and Third-Party Materials, we believe may be of interest to users of our Website generally and Investors more specifically; and 
  • To respond to threats or attacks on the security or integrity of the Website and protect us and others from harm and to prevent, detect, respond and address fraud, abuse and security risks (e.g., SPAM, malware or malicious code) that could do harm.  
  • To protect and/or defend against damage or harm or violations of any our rights, property or safety, or the rights, property or safety of others, including, without limitation, the public as and if required by law; and 
  • To enforce any and all terms and conditions of our Agreement with you applicable to the Website. 

Sharing and Disclosing  

If you are an Investor, we may use your information to deliver targeted advertising to you when you visit our Website. Since many of these technologies ‘remember’ the websites you have visited and searches you have made using your browser, even when you visit other third-party websites, the technology may allow and enable targeted advertising to appear that is related to your browsing and searching history. This is often referred to as “behavioral advertising” and is used to customize and deliver advertising we believe is more tailored to your personal interests and preferences. As previously mentioned, you can choose to configure the settings in your browser and devices you use, to block certain technologies from doing so and you should consult the manufacturer’s or browser provider’s instructions that explain how to change your settings, but you must do this on each device and browser you use in order to be effective.  

Except as specifically provided in this Privacy Policy, we do not share, sell, rent or lease any of your personal information to anyone, unless we have your permission. We may share and provide information to third parties, including information that may have been derived from personal information, for marketing, advertising, research or other uses, including, without limitation, aggregated information regarding activity on the Website, but we do so only in aggregated form that does not enable identification of any individual.  

We always reserve the right and may use, preserve and/or disclose personal information of or about you in response to: (a) requests from local, state, or federal law enforcement officials; (b) judicial, administrative, or similar proceedings or orders, such as a subpoena; (c) a legal compulsion or requirement; and/or (d) to investigate suspected fraud, harassment, physical threats, or other violations of your Agreement with us, the rights of third parties, any law or regulation, or to investigate suspected conduct we reasonably determine is improper. 

Disclosing Information 

We may also disclose your personal information under the following limited circumstances:  

  • If we have your consent;  
  • To fulfill the purposes for which we obtained it, as well as satisfying any legal, audit or reporting requirement; 
  • To legal or beneficial owners of a current or former Investor that are authorized to receive such information; 
  • To persons acting in a fiduciary or representative capacity on behalf of a current or former Investor and authorized to receive such information by such current or former Investor;
  • To our subsidiaries and affiliates; 
  • For required institutional risk control or resolving disputes or inquiries of a current or former Investors; 
  • To the extent specifically permitted or required under the law, to law enforcement agencies, self-regulatory organizations or for an investigation into public safety, all of which must be in accordance with the Right to Financial Privacy Act of 1978; 
  • To a consumer reporting agency in accordance with the Fair Credit Reporting Act; 
  • To provide you information regarding potential real estate investment opportunities; 
  • To a buyer or other successor in connection with a proposed or actual sale, merger, transfer or exchange of all or a portion of our or any of our affiliated entity's business or operations, provided such Investor is currently an investor at such time. If we are involved in a merger, acquisition, or sale of assets, we will continue to ensure the confidentiality of your personal information and give affected users notice before transferring any personal information or your becoming subject to a different privacy policy; 
  • To parties involved in any divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, receivership or similar proceeding, in which personal information held by us about you is among the assets transferred; 
  • To comply with applicable law, civil, criminal or regulatory investigations or any subpoena or summons or other legal compulsion, including compliance with bona fide legal requirements, judicial orders or the order of government regulatory authorities having jurisdiction over us, you or any entity in which you are an Investor;  
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us (including our Agreement, as well as for billing and collection purposes) as well as any between you and any entity we sponsor or to which we provide management services; and 
  • To notify you about changes to our Website or any products or services we offer or provide though our Website;  

We will always ask for your consent before we use personal information for a purpose that is not covered by or provided for in this Privacy Policy and if we do provide personal information to third parties outside the scope of these criteria, we only provide aggregated, compiled or derivative information that does not reveal or allow the identification of any individual person or their personal information. Even if we delete some or all of your information, unless prohibited by law or regulation, we may continue to retain and use your information, including personal information, as long as we have transformed, aggregated and anonymized it so that it cannot be identified to you or any other person.  

Links to Other Websites and Social Media

As mentioned in our Terms of Use, our Website may contain Links and Third-Party Materials that are not controlled by us. If you click on a Link or any Third-Party Material, your browser may be directed to a third party’s website (URL) and we strongly advise you to review the privacy policy of every website you visit, because their terms of use and privacy policies will apply, not ours. Visiting any other websites or using apps of others is at your own risk.

Our Website may also contain links to social media platforms, and if you choose to connect to them, depending on the social media platform and your settings, if you post or enter information or interact with the platform or others, your information may also be visible to others. You do so at your own risk and like any other third-party links, we have no control over and are not liable or responsible for any use of your information by or through any social media platforms. Our Website may also contain various videos from YouTube, a platform operated by YouTube, LLC, 901 Cherry Ave., San Bruno, CA 94066 and Vimeo, a platform operated by Vimeo.com, Inc., 555 West 18th Street, New York, NY 10011. These videos are embedded on our Website with the aid of a plugin or by embedding code they provide – in each case, a program that allows you to view the videos directly through the Website. Although they appear on our Website, your browser is actually establishing a direct connection to YouTube or Vimeo servers, as the case may be and they can detect the websites you have accessed, including our Website. If you have a YouTube or Vimeo account, they may also be able to associate this information with your personal user account with them. You may be able to avoid this if you log out of your YouTube or Vimeo account before viewing the videos (which use these plug-ins or embedded code), but to be sure, you should consult YouTube’s and/or Vimeo’s privacy policy and terms of us since that is the only source of accurate information in each case. 

You Can Control Your Privacy Choices

We want you to have choices and control over how we collect and use your personal information. If you contact us, ask us to provide you with information or receive any unsolicited marketing or promotional emails from us, you will always be able to opt out of receiving those types of email communications from us.  

You always have the right to ask us to provide you with a digital file containing a copy of your personal information and request that we delete all or any portion of your personal information. However, if you are registered to use our Investor Portal and you exercise this right and ask us to delete any of your information, you may no longer be able to log in to the Investor Portal portion of our Website or use any online capabilities, features or functions available through the Investor Portal. Of course, we still must and do reserve the right to retain any of your personal information as long as necessary to fulfill and service any transactions or requests you have made or initiated prior to your request to delete any of your information. To be sure your rights are clear to you, in summary, you have the right: 

  • To know what categories of personal information we collect;  
  • To know the purposes for which we collect and use personal information and to whom personal information is disclose and/or shared;  
  • To know what specific personal information we have about you and with whom we shared or provided it;
  • To tell us not to sell your personal information;  
  • To request us to delete all or any portion of your personal information; provided, however, we have the right to deny or delay responding to your requests, if retaining your information is necessary for us to: 
    • Complete and fulfill a transaction, any contractual obligation, any associated request, customer service or other purpose related to your continued existing relationship with us;
    • Complete and take any action consistent with the purpose for which we collected the information and for which you previously consented or agreed, whether based on the Agreement you have with us or otherwise; 
    • Detect and identify security incidents, protect against illegal activity and provide evidence necessary to prosecute, cooperate with law enforcement or other governmental agencies or enforce our rights;  
    • Repair or correct errors, malfunctions or deficiencies in our Website, our systems or communications capabilities; and/or 
    • Comply with our legal and regulatory obligations. 

If we need to retain any of your personal information for business or legal purposes, we will keep it only as long as necessary for us to comply with those requirements. You can appreciate, we also need to be sure your personal information is not accidentally or maliciously altered or deleted without your permission or knowledge, so there could be a delay in deleting information in our systems and backups to make sure we are following your instructions. 

Exercising Your Privacy Rights

If you want to exercise any of the rights you have, such requests must be submitted to us in writing either to info@calverapartners.com or at: 2 Embarcadero Center, 8th Floor San Francisco, CA 94111. Bear in mind that only you or someone legally authorized to act on your behalf under applicable laws is allowed to send us a request to exercise these rights. That means your request must include enough information to enable us to verify you are the individual that is the subject of your request or that enables us to authenticate anyone else you authorize to make the request on your behalf. We may request additional information or confirmation from you to do so. You should describe your request, consistent with your rights, in enough detail so that we can understand and respond to it properly and you should understand it will only cover the 12-month period preceding your verifiable and understandable request. If you do not, or if we cannot verify your identity or the authority of another person to make the request on your behalf and make sure the request relates to your information, we will not be able to honor your request until you meet these conditions.

We will generally respond to a complete and proper request, at no charge to you, within 45 days of receiving your verifiable and understandable request. If we need more time, we will notify you, but it will not be longer than another 45 days. If we send you a digital file to allow for data portability, we will use a file format that is widely used and which should allow you to transmit the information from easily.  

Compliance, Questions and Comments

We establish and maintain reasonable security measures, administrative, physical and digital, to try to protect your personal information and we try to keep track of known security threats and prevent problems before they occur. As you know, no method of transmitting information using the Internet can be completely secure and if we cannot prevent threats or problems, we try to detect and correct them promptly, in compliance with the laws and regulations that apply. We review Website information (e.g., logs and archive information) immediately before a problem started to help us identify and fix those problems more quickly. We also regularly review this Privacy Policy and our compliance with it, to make sure we keep up to date with our legal obligations. We may update this Privacy Policy from time to time and will post the new Privacy Policy on this web page, as well as any other areas of the Website that link back to this Privacy Policy. Unless we provide a future effective date, the new updated Privacy Policy will be effective when we post it, so check back here often so you remain aware of all of the terms and conditions that apply to you.

Contact Us

If you have questions or comments about this Privacy Policy or any of the terms and conditions of our Agreement with you, you can send an email to info@calverapartners.com or by regular mail to:  

Calvera Partners, LLC
2 Embarcadero Center, 8th Floor
San Francisco, CA 

 

CONTACT
SAN FRANCISCO OFFICE:
2 Embarcadero Center, 8th Floor
San Francisco, CA 94111

MINNEAPOLIS OFFICE:
729 Washington Ave N, Suite 600
Minneapolis, MN 55401

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