Your Privacy Is Important to Us

In the course of serving our clients, Realsmart may at different points in time obtain personal information about such clients. Obtaining this information is important to our ability to deliver the highest level of service to you, but we also recognize that you expect us to treat your information appropriately. 

This policy describes the types of personal information we may collect about you, the purposes for which we use the information, the circumstances in which we may share the information and the steps that we take to safeguard the information to protect your privacy. As used throughout this policy, the term “Realsmart” refers to Realsmart, Inc. and its subsidiaries and affiliates. 

The Sources of Information 
The personal information we collect about you comes primarily from the platform registration, Realsmart Token purchase and property share purchase applications, or from other forms and materials you submit to Realsmart during the course of your relationship with us. We may also collect information about your transactions and experiences with Realsmart relating to the services Realsmart provides. In addition, depending on the services you require, Realsmart may obtain additional information about you, such as your KYC information. 

Finally, in the provision of financial services to you and subject to strict compliance with all applicable laws and regulations, information may be collected about you indirectly from monitoring or other means (e.g. e-mail monitoring). In these circumstances, the information is not accessed on a continuous or routine basis, but it may be used for compliance or security purposes.

The Information We Have about You
If you deal with Realsmart in your individual capacity (e.g. as a private client), or as a settlor/trustee/beneficiary of a trust, or as an owner or principal of a company or other investment vehicle established to invest on your behalf or on behalf of your family, etc., the typical information we collect about you may include (in addition to any other information as may be determined on a case-by-case basis):

• Your full name, phone number, email address, organization, and other contact details; 
• Extensive financial information, including source of wealth, investment experience and objectives, risk tolerance and, in certain jurisdictions, representations required under applicable law or regulation concerning your financial resources; and 
• A personal identifier such as, depending on your country of residence, your Identification Number, Social Security Number, National Insurance Number, Tax File Number, etc. 

Of course, you are not required to supply any of the personal information that we may request. However, failure to do so may result in our being unable to open or maintain your online account

or to provide services to you. While we make every effort to ensure that all information we hold about our clients is accurate, complete and up to date, we rely on our clients promptly notifying us if there are any changes to their personal information. 

Our Use of Your Personal Information
We may use your personal information to:

• Administer, operate, facilitate and manage your relationship and/or account with Realsmart. This may include sharing such information internally as well as disclosing it to third parties, as described in the following two sections, respectively; 
• Contact you or, if applicable, your designated representative(s) by post, telephone, electronic mail, facsimile, etc., in connection with your relationship and/or account; 
• Provide you with information (such as investment research), recommendations, or advice concerning products and services offered by Realsmart; and 
• Facilitate our internal business operations, including assessing and managing risk and fulfilling our legal and regulatory requirements.

If your relationship with Realsmart ends, Realsmart will continue to treat your personal information, to the extent we retain it, as described in this policy.

Disclosures of Your Personal Information within Realsmart
In order to provide efficient and reliable services and to improve product and service options available to you, more than one entity within Realsmart may be given, or given access to, your personal information. For example, one Realsmart entity might share your information with another in order to facilitate settlement of your transactions or the maintenance of your accounts, or as part of its arranging for the performance of specialized services such as US and international brokerage, asset management and advisory services. When so sharing your personal information, we adhere to applicable legal and industry standards regarding the protection of personal information. Additional information on how your personal information is protected while within Realsmart is provided below, under Information Security: How We Protect Your Privacy.

Disclosures of Your Personal Information to Third Parties
Realsmart does not disclose your personal information to third parties, except as described in this policy. Third party disclosures may include sharing such information with investment partners (e.g. deal sponsors), other financial institutions (e.g. lenders requiring such information pursuant to regulatory requirements) and/or non-affiliated companies that perform support services for your account or facilitate your transactions with Realsmart, including those that provide professional, legal or accounting advice to Realsmart. Each such third party is required to maintain the confidentiality of such information to the extent received and to use your personal information only in the course of providing the services, and only for `the purposes, dictated by Realsmart.

We may also disclose your personal information to fulfill your instructions, to protect our rights and interests and those of our business partners or pursuant to your express consent. Finally, under limited circumstances, your personal information may be disclosed to third parties as permitted by, or to comply with, applicable laws and regulations; for instance, when responding to a subpoena or similar legal process, to protect against fraud and to otherwise cooperate with law enforcement or regulatory authorities or with organizations such as exchanges and clearinghouses. For clients who link or verify bank accounts over our platform, we may use services provided by Plaid Inc. (“Plaid”) to gather your data from financial institutions. By using those features of our service, you grant Client and Plaid the right, power, and authority to act on your behalf to access and transmit your personal and financial information from the relevant financial institution. You agree to your personal and financial information being transferred,stored, and processed by Plaid in accordance with the Plaid Privacy Policy.

You should know that Realsmart will not sell your personal information.

Information Security: How We Protect Your Privacy
Realsmart is committed to protecting the privacy and confidentiality of your personal
information. We limit access to your personal information to authorized Realsmart employees or
agents and, as described above in Disclosures of Your Personal Information to Third Parties,
third parties are held to stringent standards of privacy. We also maintain physical, electronic and
procedural safeguards to protect the information against loss, misuse, damage or modification
and unauthorized access or disclosure. Some of the other central features of our information
security program are:

• A dedicated group within Realsmart that designs, implements and provides oversight to our information security program; 
• The use of specialized technology such as firewalls; 
• Testing of the security and operability of products and services before they are introduced to the Internet, as well as ongoing scanning for publicly known vulnerabilities in the technology; 
• Internal and external reviews of our Internet sites and services; 
• Monitoring of our systems infrastructure to detect weaknesses and potential intrusions; 
• Implementing controls to identify, authenticate and authorize access to various systems or sites; 
• Protecting information during transmission through various means including, where appropriate, encryption; and 
• Providing Realsmart personnel with relevant training and continually updating our security practices in light of new risks and developments in technology.

The following additional information will be of interest to you as a visitor to this site: 

• Realsmart.io is built upon a secure infrastructure with multiple layers of protection. Realsmart uses industry standard encryption technologies to protect your information from external compromise. 
• Security is a cooperative effort between Realsmart and the users of Realsmart.io. Please remember that your login and password are personal to you and should not be made available to any other person. Also, you should discontinue their use and notify us if you have any reason to suspect that someone else may be using them. 
• We may collect certain aggregate and non-personal information when you visit Realsmart.io. We may collect this information through “cookie” technology. Cookies are bits of text that can be placed on your computer’s hard drive when you visit certain Websites. Cookies may enhance your online experience by saving your preferences while you are visiting a particular Website. The “help” portion of the toolbar on most browsers will tell you how to stop accepting new cookies, how to be notified when you receive a new cookie, and how to disable existing cookies. Remember, though, without cookies, you may not be able to take full advantage of all of the Realsmart.io features. 
• “Clickstream” data (e.g., information regarding which of our Web pages you access, the frequency of such access, and your product and service preferences) may be collected by Realsmart itself, or by our service providers, using cookies, Web beacons, page tags, or similar tools that are set when you visit our Web site or when you view an advertisement we have placed on another Web site. Clickstream data and similar information may be shared internally within Realsmart and used: for administrative purposes; to assess the usage, value and performance of our online products and services; to improve your experience with our Web sites; and as otherwise permitted by applicable law or regulation. If you are a Realsmart client, this information helps us suggest products or service offerings that may be of interest to you. This information may be processed by us for the purposes described above, or on our behalf by third parties, solely in accordance with our instructions. 
• Realsmart may make available on this Web site third party applications such as content linking or sharing facilities. Information collected by providers of such applications is governed by their privacy policies.

Other Privacy Policies or Statements; Changes to Policy; Contact
This policy provides a general statement of the ways in which Realsmart protects your personal information. You may, however, in connection with specific products or services offered by Realsmart, be provided with privacy policies or statements that supplement this policy. This policy may be changed from time to time to reflect changes in our practices concerning the collection and use of personal information. The revised policy will be effective immediately upon posting to our Website. This version of the Policy is effective 4 February, 2021. If you require further information regarding our privacy policies and practices please contact help@realsmart.io.

Statement on Cookies
By using our Website with your browser settings adjusted to accept cookies, you consent to Realsmart’s use of cookies and other tools to provide the products and services available on our site. If you would like to modify your browser to notify you when you receive a new cookie or to disable cookies altogether, please refer to Managing Cookies below.

Cookies at Realsmart and How We Use Them
Cookies are small text files that may be placed on your Web browser when you visit our Website or when you view advertisements we have placed on other Websites. Cookies allow your browser to remember some specific information which the web server can later retrieve and use. Realsmart does not use cookies to store any personal information that could be read or understood by others. When you quit your browser, some cookies are stored in your computer’s memory, while some expire or disappear. 

Cookies are used primarily for administrative purposes, to improve your experience with our Website. Examples of this include the use of cookies: 

• To improve site security by “authenticating” you (i.e., verify that you are who you say you are) when you sign-in to our site. 
• To keep track of your specified preferences such as language, time zone and timeouts after periods of inactivity. 
• To allow you to navigate our sites more easily by “remembering” your identity so that you do not have to input your password multiple times as you move between pages or services. 

In addition to administrative uses, Realsmart may also use cookies in one or more of the following ways: 

• To conduct research and analytics to improve our Website and our products and services. This includes compiling statistical information concerning, among other things, the frequency of your use of our Website, the pages visited and the length of each visit. 
• To display Realsmart advertisements when you visit Websites of third parties with whom we have marketing relationships and to help us gauge the effectiveness of our advertising efforts. These parties may gather information concerning your use of other Websites and provide us with de-identified information about you (such as demographic information or the names of sites where you have been shown ads) which we may use to provide you with more relevant and useful advertising.