Privacy Policy
FBR INVESTMENT FUND — PRIVACY POLICY
Last updated: November 2, 2022
At FBR Investment Fund, our mission is to help our investors create exceptional passive income returns and grow generational wealth through our real estate investment syndication offerings. And to fulfill this mission, we collect information about you, our:
- Investors using Cash Flow Portal to provide investment opportunities, verify your Accredited Investor status and means to investment your funds into an FBR deal
- Visitors to use FBR Investment Fund’s websites, or anyone contacting FBR Investment Fund’s support
Your privacy is important to us. This privacy policy (this “Privacy Policy”) outlines how we at FBR Investment Fund collect, use, disclose, and have over your information.
Please read this Privacy Policy carefully. By using our Services (as defined below), you acknowledge that you have read, understand and agree to be legally bound by this Privacy Policy and other policies incorporated herein by reference.
This Privacy Policy was last updated and is effective on November 2, 2022.
FBR Investment Fund reserves the right to modify this Privacy Policy at any time, in our sole discretion. We may modify this Privacy Policy by providing notice via one of the following methods: (i) by email to the email account used by you to access our Services, (ii) by updating the ‘last updated’ date listed above, or (iii) by your acknowledgement as part of your login to our Services. By continuing to use our Services you confirm that you agree to the modified Privacy Policy. If you do not agree with the changes to this Privacy Policy, you must immediately stop using our Services and close your account within 30 days of the change.
Our Services and how this Privacy Policy applies
FBR Investment Fund makes its multi-family and single family assets available for Accredited Investors to invest in through syndication and offers these syndication opportunities through it’s website at https://fbrinvestmentfund.com , and accessible via our Client Account Portal at Cash Flow Portal. Through this platform, our Customers can access specific investment properties we have available, provide proof of their Accredited Investor status and transfer funds to invest in the investment opportunity. Herein for this Privacy Policy, we refer to our Client Account Portal, websites and mobile applications collectively as our “Services”.
This Privacy Policy applies to our Services, and other interactions you may have with FBR Investment Fund, such as visiting our websites, customer service inquiries, attendance at events, etc. By using our Services, or otherwise interacting with FBR Investment Fund you agree to the collection and use of your personal information in accordance with this Privacy Policy. Personal information is any information or data relating to you that may be used to identify you, either directly or indirectly, or to contact you.
Our Services may contain links to other websites, products, or services that we do not own or operate. When using our Services, you may decide to share your data and any related personal information with a third-party service of your choice (for example, your accountant). Any processing of your information by these third parties is governed by their own privacy policies and terms. We recommend you carefully review their privacy policies and terms, as FBR Investment Fund is not responsible for such third-party services.
Some of our Services are made available to you by our affiliates. Personal information supplied by you through our Services to our affiliates will be governed by this Privacy Policy.
Our Services are not intended for use by children and should only be accessed by individuals who are at least 18 years old. If we learn that we have inadvertently collected personal information of persons under the age of 18 years old, we shall immediately take steps to delete the information as soon as possible. If you learn that a child has provided us with personal information in violation of this Privacy Policy, then you may alert us at [email protected]
What information we collect about you and why
A. Investors
If you are an Investor using FBR Investment Fund’s website and the Cash Flow Portal to access investment opportunities, we collect and use your personal information to provide you with our Services. We collect the following personal information when you sign up to invest in a property, when you use our Services, or when you otherwise provide us information. We also may collect personal information from other sources, including business partners or referral partners. Generally, we use this information to provide and customize our Services for you.
What we collect
Information you provide us about you and your business, like your name, company name, email address, and phone number.
Information of others that we process at your direction, such as the names and contact information of your clients, employees, etc.
Payment and billing information that you provide us, or our third-party payment processor, such as your credit or debit card number.
Information about products or services you purchased, obtained, or considered.
Information about how you access our Services and your account, including information about the device and browser you use, your network connection, your IP address, and details about how you browse and interact with our websites and platform.
Customer support information (such as questions and issues) and general feedback that you choose to provide (for example, Service reviews).
Audio information (such as recordings when you call us for customer support).
Information, such as demographic information, we receive from other third parties, including referral, promotional, and joint marketing partners and business partners who provide complementary services or products to our Services.
If you connect our Services directly to your business bank account and authorize us to receive information directly from your business bank account, we receive your bank institution information (such as bank name and institution ID), business bank account information (for example, balances and last four digit of the account number), and transaction information (such as amount, vendor name, date, and category).
Copies of government-issued identification about you or your business that you provide to us
Why we collect
To set up your account and provide you with the use of our Services (e.g., to confirm your identity, to contact you about issues with our platform, to invoice you)- To market products or features to you
- To comply with legal requirements
- To provide you with our Services
- To provide you use of, and to improve, our platform and other related services (e.g., identifying ways to make our platform easier to use or navigate)
- To personalize the platform for you
- To debug, identify and repair errors that may impact intended functionality
- To detect security incidents and protect against malicious, fraudulent or illegal activity
- To provide you with customer support when using our Services
B. Visitors
We collect the following personal information about you when you visit our website or contact us through our website:What we collect
Information about you that you provide us about yourself, like your name, address, email address, and phone number.
Information about how you access our Services, including information about the device and browser you use, your network connection, your IP address, and details about how you browse through our apps and sites, including search terms you may enter.
Information about products or services you purchased, obtained, or considered.
Information you provide us for surveys, contests and events (such as webinars or in-person events), including your contact information, your business name and address, and general information about your organization that you choose to provide, such as annual company revenue, number of employees, and industry.
Inferences that are drawn from your preferences, characteristics, or behavior while visiting or interacting with our website or our Services.
Why we collect
To set up your account and provide you with the use of our Services (e.g., to confirm your identity, to contact you about issues with our platform, to invoice you)
- To market products or features to you
- To communicate with you via email or via chatbot
- To advertise and market products or features to you
- To comply with legal requirements
- To provide you use of, and to improve, our websites and related Services (e.g., identifying ways to make our websites easier to use or navigate)
- To personalize your experience using our websites (e.g., by changing the layout of our webpages)
- To register you for the survey, contest or event, and provide you with the results or contents of the event
C. Prospective Investors
In order to offer our Services to prospective Investors who may want to invest in our syndicated properties and find our Services useful, we collect personal information, such as names, emails addresses, and phone numbers, from business partners and public sources. We may also collect information about how you access our Services, including information about the device and browser you use, your network connection, your IP address, and details about how you browse and interact with our websites and platform.
How we use your information
We use the personal information we collect from you to provide you with our Services, to fulfill a contractual obligation (for example, to process your investment into a property syndication), to improve our Services or where we need your personal information for a legitimate business interest, including to better understand business trends, such as how our products and services are used, and share these insights with our affiliates and business partners. These legitimate interests include:
- verifying your or your business’ identity
- preventing risk and fraud (for example, to detect and protect FBR Investment Fund and other third parties against error, negligence, breach of contract, fraud, theft and other illegal activity, and to audit compliance with FBR Investment Fund’s policies and contractual obligations)
- answering questions or providing other types of support
- providing, securing, debugging and improving our Services and website
- providing reporting and analytics
- testing out features or additional services
- assisting with marketing, advertising, or other communications
- understanding your needs and eligibility for products and services
- personalizing your experience on our Services, such as presenting tailored content
- complying with legal and regulatory requirements
- enforcing our Terms of Use and / or compliance with this Privacy Policy
We may also collect and use your personal information for any other purpose to which you consent.
We only collect the personal information we consider necessary for achieving these purposes.
We may use information that is aggregated or de-identified so that it is no longer reasonably associated with an identified or identifiable natural person for any business purpose.
Your use of others’ personal information
In using our Services, you may provide us with the personal information of others (for example, the names and addresses of your accounting or or legal advisors, or employees) , and if you are an accounting or legal advisor or employee of one of our Investors, we may receive your personal information from our Investors. In these circumstances, we are only a “service provider” of such information.
As your service provider, we process (collect, use, disclose, etc.) such information as directed by you for the purpose of providing you our Services. For example, we do not use your advisors’ or employees’ information to independently market or advertise to them unless they are also using our Services directly.
You are responsible for the personal information of others that you disclose to us via our Services and for ensuring that your instructions regarding the processing of such information complies with applicable data protection laws.