Privacy Policy

1.1 Identifiers. Name, email address, telephone number, mailing address and other contact details you provide through forms or correspondence.

1.2 Property information. Property address, asset type, lot size, zoning classification, condition, ownership status and related details submitted for evaluation.

1.3 Transaction information. Records of submissions, inquiries and communications relating to potential acquisitions or capital relationships.

1.4 Technical and usage data. IP address, browser type and version, operating system, device identifiers, referring URLs, access timestamps, pages viewed and navigation paths.

• directly from you, through forms, email, telephone or SMS;
• automatically, through cookies, pixels and analytics technologies;
• from third-party sources, including public records, county assessor databases, title companies and data providers; and
• from service providers that support our CRM, communications and analytics functions.

3.1 Consent. Where you have affirmatively agreed to receive communications or submitted information through the Site.

3.2 Legitimate interests. To evaluate and underwrite properties, communicate with owners and counterparties, secure and improve the Site, and develop the Firm's business.

3.3 Contractual necessity. To perform obligations under agreements with owners, counterparties and capital partners.

3.4 Legal compliance. To satisfy applicable legal, regulatory, recordkeeping and anti-money-laundering obligations, including those described in the Firm's AML & Sanctions Policy.

By submitting your information, you consent to receive communications from AceStone by SMS, telephone and email regarding your inquiry. Message and data rates may apply. You may withdraw consent at any time by replying "STOP" to any SMS, using the unsubscribe link in any marketing email, or contacting us at the address in Section 12. Withdrawal does not affect the lawfulness of processing carried out before withdrawal, and we may still contact you regarding an active transaction.

5.1 General. The Site uses cookies and similar technologies to support Site functionality, maintain security, remember applicable preferences, understand how visitors interact with the Site and improve Site performance and user experience. Cookies are small data files stored on or accessed through a visitor's device when interacting with the Site.

5.2 Strictly Necessary Cookies. Certain cookies are necessary for the Site to operate securely and perform its core functions. These technologies may support functions such as security, network management, session integrity, fraud prevention and the storage of privacy or cookie preferences. Because these cookies are required for core Site functionality, they remain active regardless of a visitor's optional cookie preferences.

5.3 Analytics Cookies. With your permission, AceStone may use analytics cookies or similar technologies to understand how visitors interact with the Site. These technologies may collect or generate information regarding page visits, navigation patterns, device and browser characteristics, referring pages, approximate usage patterns and other Site interactions. AceStone uses this information to evaluate Site performance, identify technical or usability issues, understand aggregate visitor behavior and improve the Site and its content.

5.3.1 Optional analytics technologies must not be activated through the Site's consent mechanism unless the applicable visitor has provided the required permission.

5.4 Advertising and Cross-Context Behavioral Tracking. AceStone does not use cookies for advertising, retargeting or social-media tracking on the Site and does not use information collected through Site cookies for cross-context behavioral advertising.

5.5 Cookie Preferences and Consent. Where applicable, visitors are presented with cookie controls that permit them to accept optional cookies, reject optional cookies or manage their preferences. Strictly necessary cookies cannot be disabled through these controls because they are required for security and core Site functionality.

5.5.1 A visitor's cookie preference may be stored so that the Site can recognize the visitor's selection on subsequent visits. Where consent is required for an optional technology, declining or withholding consent will not prevent access to the Site's core functionality.

5.6 Changing Your Preferences. Visitors may change their available cookie preferences through the Site's cookie preference controls. Visitors may also configure their browser to block, restrict or delete cookies. Browser-level restrictions may affect certain Site functions or prevent stored preferences from operating as intended.

5.7 Duration and Storage. Cookies may operate for the duration of a browsing session or remain on a device for a longer period depending on their purpose and configuration. AceStone seeks to retain information collected through cookies only for as long as reasonably necessary for the purposes for which the applicable technology is used, subject to applicable legal, security, operational and recordkeeping requirements.

5.8 Third-Party Technologies. Certain Site functionality or analytics services may be provided through third-party service providers acting in connection with the operation, security, measurement or improvement of the Site. Information processed through those technologies may be subject to the applicable provider's technical infrastructure and privacy practices, in addition to the safeguards and contractual arrangements maintained by AceStone where applicable.

5.9 No Sale of Personal Information Through Cookies. AceStone does not sell personal information collected through Site cookies and does not share such information for cross-context behavioral advertising.

5.10 Do Not Track. Browser-based "Do Not Track" signals are addressed in Section 10 of this Policy. Nothing in this Section 5 modifies the disclosures contained in Section 10.

We disclose personal information only as follows:

• Service providers — CRM, email, hosting, communications and analytics providers acting on our instructions under written agreements;
• Transaction participants — title companies, closing attorneys, surveyors, lenders and other professionals engaged on an active transaction;
• Affiliates and assignees — affiliated entities, special purpose vehicles, joint venture partners and permitted assignees of a purchase agreement; and
• Legal and regulatory recipients — governmental authorities, regulators, law enforcement and courts, where required by law, subpoena or court order, or to establish or defend legal claims.

AceStone does not sell personal information and does not share it for cross-context behavioral advertising.

7.1 We maintain administrative, technical and physical safeguards designed to protect personal information against unauthorized access, alteration, disclosure or destruction, including encryption in transit (TLS), access controls and periodic review. No method of transmission or storage is entirely secure, and we cannot guarantee absolute security.

7.2 We retain personal information for as long as reasonably necessary for the purposes described in this Policy and to meet legal, recordkeeping, dispute-resolution and enforcement requirements, after which it is deleted or de-identified.

8.1 Subject to applicable law, you may request access to, correction of, or deletion of your personal information; object to or restrict certain processing; and opt out of marketing communications at any time.

8.2 California residents. Under the CCPA, as amended by the CPRA, you may request disclosure of the categories and specific pieces of personal information collected, request deletion or correction, opt out of any sale or sharing (which we do not conduct), and exercise these rights free from discriminatory treatment.

8.3 Other U.S. states. Residents of states with comprehensive privacy statutes, including Virginia, Colorado, Connecticut, Utah and Texas, may exercise comparable rights under the law of their state.

8.4 Verification. We verify requests before acting on them and may decline a request where verification is not reasonably possible or where an exemption applies. Requests should be submitted using the details in Section 12.

The Site is operated from the United States and is intended for users located in the United States. If you access the Site from another jurisdiction, your information may be transferred to and processed in the United States, where data protection law may differ from that of your jurisdiction. To the extent Regulation (EU) 2016/679 ("GDPR") or the UK GDPR applies, we process personal data on the bases described in Section 3 and apply appropriate safeguards to cross-border transfers.

No uniform industry standard exists for responding to browser "Do Not Track" signals, and the Site does not currently respond to them. We will update this Policy if a recognized standard is adopted.

The Site is not directed to individuals under the age of thirteen (13), and we do not knowingly collect their personal information. If we learn that we have collected such information, we will delete it promptly in accordance with the Children's Online Privacy Protection Act.

12.1 We may amend this Policy from time to time. Material changes are reflected in the "Last revised" date above, and continued use of the Site following posting constitutes acceptance.

12.2 Privacy inquiries and rights requests should be directed to: