Website Privacy Policy
Effective: January 30, 2018
1. Introduction. Welcome to the Sares Regis MultiFamily Funds (“Sares Regis”) website, www.srgfunds.com. Sares Regis purchases, operates, manages, and sells multi-family real estate assets in the western United States. This Privacy Policy describes how Sares Regis collects, uses, shares and secures personal information and other information through your use of Site (the “Site”). By using the Site, you agree and consent to the use of your information as set forth in this Privacy Policy and in Sares Regis’ Terms of Use.
2. Scope. This Privacy Policy applies to your use of the Site. This Privacy Policy does not apply to any information or other data not collected through this Site. Any information collected in connection with providing investor management and communication services (the “Services”) is governed by contractual agreements in connection with that particular Service.
3. Information we Collect.
3.1 Personal Information. Personal Information is information that identifies you, such as your name or email address. For example, when you send us an email, we will collect your name, email address, and other Personal Information associated with your email that you voluntarily provide or that is contained in the data file of the email that you send.
3.2 Automatically-Collected Information. When you visit or engage with our Site we may collect information that could be used to identify you. For example, when you visit the Site, we automatically collect information about you from our computer or mobile device, such as your IP address or unique device identifier, web browser type and version, and the name and version of your operating system, through cookies and similar technologies. Please see the “Cookies” section below to learn more about how we use cookies and similar technologies.
3.3 Cookies are small data files that a website transfers to your computer’s hard drive through your browser. We use cookies and other similar technologies to help provide additional functionality to our website. We may also use analytics tools, such as Google Analytics, to collect non-personally identifiable data, such as your IP address, your internet service provider, the web page you linked to our Site from, and other clicking and browsing behavior. For information about how to opt out of having your information used by Google Analytics, visit https://tools.google.com/dlpage/gaoptout/.
4. Use of Information. We may use your information for the following purposes:
4.1 To provide you with information related to the Site or the Services;
4.2 to improve the Site and Services, such as by better tailoring content to users’ needs and preferences;
4.3 to provide you with required notices;
4.4 to analyze, administer, support, and/or improve use of the Site and the Services; and
4.5 to combine, compile or aggregate any of the information collected through the Site for our business purposes, including sharing such information with affiliates and business partners.
5. Disclosure of Information. We may disclose your information in the following circumstances:
5.1 As necessary to provide you with the products, Services or information related to the Site;
5.2 to third party service providers who provide certain services to us to assist us in meeting business operation needs;
5.3 as required by law to comply with a subpoena or other legal process, or to comply with regulatory reporting obligations;
5.4 when we believe in good faith that disclosure is necessary (A) to protect Sares Regis’ rights, the rights of other users of the Site, the integrity of the Site, or your safety or the safety of others, or (B) to detect, prevent or respond to fraud, intellectual property infringement, violations of the Site’s Terms of Use, violations of law or other misuse of the Site; or
5.5 to affiliates, service providers, advisors and other third parties to the extent reasonably necessary to proceed with the negotiation or completion of a merger, acquisition or sale of all or a portion of Sares Regis’ assets.
6. Role of SecureDrawer via eFileCabinet. eFileCabinet, Inc., a Utah corporation (“eFileCabinet”) hosts and operates the investor portal log-in page at https://srgfunds.securedrawer.com/#/login (the “Investor Portal”) on behalf of Sares Regis. As operator of the Investor Portal, eFileCabinet 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 Sares Regis furnishes to eFileCabinet about you, for the purpose of hosting and operating the Investor Portal and facilitating provision of products and services by Sares Regis to you. Sares Regis does not direct or control eFileCabinet’s use or storage of Personal Information about you. eFileCabinet’s collection, use and disclosure of your Personal Information is described in the eFileCabinet privacy policy, which is available at the link “https://www.efilecabinet.com/privacy-policy/”.
7. Third-Party Websites. The Site may contain links to websites operated by third parties. By providing such links we do not endorse such third party sites and we are not responsible nor do we have any control over the data practices or privacy policies of such sites. We encourage you to review the privacy policies of each website you visit.
8. Business Transfer. If our company or substantially all of our assets are acquired, or in the unlikely event that we were to go out of business or enter bankruptcy, your Personal information and Other Information may be transferred to a successor or affiliate as part of that transaction.
9. Do Not Track (DNT) Signals. We currently do not respond to “Do Not Track” (DNT) signals and operate as described in this Privacy Policy whether or not a DNT signal is received.
10. Children’s Information. The Site is not directed to, nor does Sares Regis knowingly collect information from, children under the age of 13. If you become aware that a child who is under 13 has provided personal information please contact us using the contact information provided below.
11. Your California Privacy Rights. If you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your Personal Information to third parties for their direct marketing purposes during the immediately preceding calendar year. You may make one request each year by emailing us at kgladstein@staging.hdsf.com or by writing to us at Sares Regis Multifamily Funds, Attn: Kenneth Gladstein, 901 Mariners Island Boulevard, Suite 700, San Mateo, CA 94404.
12. Changes to this Privacy Policy. From time to time Sares Regis may revise or update this Privacy Policy by posting the revised or updated Privacy Policy on this Site. We recommend you consult this Privacy Policy regularly for any changes. Your continued use of the Site after such changes have been made constitutes acceptance of those changes.
13. Contact Information. If you have any questions about this Privacy Policy or the collection or use of information about you, please write to Sares Regis at kgladstein@staging.hdsf.com or Sares Regis Multifamily Funds, Attn: Kenneth Gladstein, 901 Mariners Island Boulevard, Suite 700, San Mateo, CA 94404.