California Privacy Notice

This California Privacy Notice supplements our Privacy Policy. It applies to California residents and describes how we collect, use, disclose, retain, and respond to requests regarding personal information.

Some California privacy laws apply only to businesses that meet specific statutory thresholds. To the extent those laws apply, and as a courtesy where practical, we provide the request methods and disclosures below.

1. Categories of Personal Information We May Collect

• Identifiers: Name, email address, phone number, mailing address, IP address, and similar contact or online identifiers.
• Commercial real estate information: Property address, ownership information, unit count, rent roll information, valuation details, transaction interests, and related property records.
• Internet or network activity: Pages visited, referring URL, browser type, device information, and analytics events collected after analytics consent.
• Professional or business information: Company, role, investment criteria, buyer/seller status, and brokerage-related communications.
• Inferences: Investment preferences or property interests inferred from inquiries, communications, or site activity.
• Sensitive personal information: We do not intentionally request sensitive personal information through the Site. Please do not submit Social Security numbers, bank account details, government ID numbers, health information, tenant names, or unredacted tenant files through website forms.

2. 12-Month Disclosure Summary

During the past 12 months, we may have collected and disclosed the categories below for the business purposes described in this notice. We do not sell personal information for money and do not intentionally share personal information for cross-context behavioral advertising.

• Identifiers: Collected from you, public records, referral sources, and service providers; disclosed to service providers, Realty Investment Advisors, professional affiliates, and transaction participants.
• Commercial real estate information: Collected from you, public records, owners, counterparties, listing platforms, and data vendors; disclosed to service providers, brokerage affiliates, and transaction professionals as needed to provide requested brokerage services.
• Internet or network activity: Collected from server logs and, after analytics consent, Google Analytics; disclosed to website hosting, security, and analytics providers.
• Professional or business information: Collected from you, referral sources, public sources, and business records; disclosed to service providers and transaction participants where relevant.
• Inferences: Created from inquiries, communications, and site activity; used to understand property interests and provide more relevant brokerage communications.
• Sensitive personal information: Not intentionally collected through the Site; if received in connection with a requested service, used only to respond, provide services, protect rights, or comply with legal obligations.
• Deidentified or aggregated information: We may create analytics, market, and website performance information that is not reasonably linkable to you.

3. Sources of Personal Information

We may collect personal information from:

• You, when you submit a form, call, email, text, or otherwise communicate with us.
• Public records, including real estate, tax assessor, transaction, and licensing records.
• Service providers, marketing platforms, CRM tools, analytics providers, listing platforms, and data vendors used in commercial real estate brokerage.
• Referral sources, counterparties, escrow/title professionals, lenders, and other transaction participants.

4. Business or Commercial Purposes

We may use personal information to:

• Respond to inquiries and provide requested brokerage or valuation services.
• Prepare broker opinions of value, market analyses, comparable sale research, and listing recommendations.
• Communicate about properties, market updates, transaction opportunities, and services that may be relevant to you.
• Operate, secure, measure, and improve the Site and our marketing efforts.
• Create deidentified, anonymized, or aggregated analytics, market, and performance information.
• Maintain brokerage records, comply with legal obligations, resolve disputes, and enforce agreements.

5. Disclosure of Personal Information

We may disclose personal information to the following categories of recipients:

• Service providers and contractors: Website hosting, FormSubmit form processing, email, CRM, analytics after consent, marketing, file storage, map/video providers, and administrative tools.
• Transaction participants: Escrow, title, lending, legal, accounting, inspection, and due diligence professionals when relevant to a transaction or requested service.
• Brokerage and professional affiliates: Realty Investment Advisors and licensed professionals involved in providing brokerage services.
• Legal or regulatory recipients: Government agencies, courts, regulators, or other parties when required by law or necessary to protect rights and safety.

6. Sale or Sharing of Personal Information

We do not sell personal information for money. We also do not intentionally share personal information for cross-context behavioral advertising. If analytics or advertising cookies are ever deemed a sale or share under applicable law, you may opt out through our Do Not Sell or Share My Personal Information page. Google Analytics is loaded only after a visitor accepts analytics cookies.

7. Retention

We retain personal information for as long as reasonably necessary for the purposes described in this notice, including providing services, maintaining brokerage records, complying with legal obligations, resolving disputes, and enforcing agreements. Retention periods vary based on the type of record, relationship, and legal requirement.

8. California Privacy Rights

California residents may have the following rights, subject to legal limits and verification:

• Right to know/access: Request categories or specific pieces of personal information collected about you.
• Right to delete: Request deletion of personal information, subject to exceptions.
• Right to correct: Request correction of inaccurate personal information.
• Right to portability: Request a portable copy of personal information where required by applicable law.
• Right to opt out: Request that a business stop selling or sharing personal information.
• Right to limit sensitive information: Limit use of sensitive personal information when applicable.
• Right to appeal: Appeal a decision on a privacy request where applicable state law provides an appeal right.
• Right to non-discrimination: Receive equal service and pricing for exercising privacy rights.

We do not use Site-submitted personal information for material automated decision-making, profiling that produces legal or similarly significant effects, or eligibility decisions about housing, financing, brokerage representation, or transaction terms.

9. How to Submit a Request

You may submit a California privacy request by:

• Using our Privacy Request form
• Emailing dfavia@riacre.com
• Calling (424) 377-6002
• Using the instructions on the Do Not Sell or Share page

We may need to verify your identity before completing a request. Verification may require matching information you provide with information we maintain. Authorized agents may submit requests on your behalf, but we may require proof of authorization and may ask you to verify your identity directly.

We aim to confirm receipt of applicable requests within 10 business days and respond within 45 calendar days after receiving a verifiable request. If we need more time where permitted by law, we will tell you why and provide the expected timing.

If we deny a request and applicable law gives you an appeal right, you may appeal by replying to our decision email or submitting a new request through the Privacy Request form with "Appeal" selected.

10. Global Privacy Control

Where required by applicable law, we treat browser-based opt-out preference signals, such as Global Privacy Control, as a request to opt out of sale or sharing for that browser or device. The Site also treats a Global Privacy Control signal as an analytics opt-out for that browser by declining analytics cookies and preventing Google Analytics from loading through our cookie banner code.

11. Contact