Privacy Policy

RealtySlices LLC

(including the VerifyAccredited DBA)

1. Introduction

Welcome to VerifyAccredited.com (“VerifyAccredited,” “Platform,” or “Website”), a service operated under the assumed business name (“DBA”) VerifyAccredited of RealtySlices LLC, a Washington limited liability company (“RealtySlices,” “Company,” “we,” “us,” or “our”). VerifyAccredited and RealtySlices are the same legal entity; references to either are references to RealtySlices LLC. We value your privacy and are committed to protecting your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use any of our websites, applications, and related services, including:

• www.verifyaccredited.com — our Accredited Investor Verification portal operated under the “VerifyAccredited” assumed business name (DBA) of RealtySlices LLC; and
• www.realtyslices.com — our real-estate investment platform

References in this Privacy Policy to the “Platform” include both websites, our mobile applications (if any), and the related services (collectively, the “Services”). VerifyAccredited is not a separate legal entity; it is a DBA of RealtySlices LLC.

By accessing or using the Platform, you agree to the collection and use of information in accordance with this Privacy Policy. If you do not agree with this Privacy Policy, please do not use the Platform. This Privacy Policy is incorporated by reference into our Terms of Use.

2. Scope and Key Definitions

“Marketing Data” means your name, telephone number(s), and email address(es) provided to or through the Platform.

“Verification Materials” means the documents and information you submit through VerifyAccredited to obtain Accredited Investor Verification, including tax returns, brokerage and bank statements, W-2s, K-1s, government-issued identification, and CPA/attorney letters.

“Third-Party Verifier” means an independent licensed CPA, attorney, or other qualified professional engaged independently of RealtySlices to perform Accredited Investor Verification under Rule 506(c) of Regulation D.

“RealtySlices Offerings” means current and future real estate, securities, fund, and other investment opportunities, products, or services marketed by RealtySlices LLC or its affiliates.

“Sensitive Personal Information” has the meaning given in the California Privacy Rights Act (CPRA) and analogous laws and includes, in our case, Social Security and Tax Identification Numbers, financial account information, and government identification numbers.

3. Information We Collect

3.1 Information You Provide Directly

Account Information:

• Name and contact information (email, telephone number, mailing address);
• Date of birth;
• Social Security Number or Tax Identification Number (Sensitive Personal Information);
• Government-issued identification documents (Sensitive Personal Information);
• Username, password, and authentication credentials.

Investor Information (RealtySlices.com):

• Investment qualifications and accreditation status;
• Financial information (income, net worth, investment experience);
• Bank account and payment information (Sensitive Personal Information);
• Investment preferences and objectives;
• W-9 or W-8 tax forms.

Verification Materials (VerifyAccredited.com):

• Tax returns, schedules, and supporting forms (W-2, 1099, K-1, etc.);
• Brokerage, bank, and investment account statements;
• Pay stubs or other income documentation;
• Net-worth statements and supporting evidence (asset and liability documentation);
• Government-issued identification;
• CPA, attorney, registered investment adviser, or registered broker-dealer letters;
• Entity formation, ownership, and authorized-signatory documentation;
• Series 7, 65, or 82 license information (if applicable).

Sponsor Information (RealtySlices.com sponsors only):

• Business entity information;
• Professional licenses and credentials;
• Banking and financial information;
• Project and property details;
• Marketing materials and documentation.

Communications:

• Messages sent through the Platform (including messages to Third-Party Verifiers);
• Customer-support inquiries and tickets;
• Feedback, survey responses, and reviews.

3.2 Information Collected Automatically

Device and Usage Information:

• IP address and inferred general geolocation (we do not collect precise GPS-level location unless you grant explicit device permission);
• Browser type and version;
• Device type, model, and operating system;
• Pages viewed and time spent;
• Referring websites and exit pages;
• Click patterns and interaction data.

Cookies and Tracking Technologies. We use cookies, web beacons, pixels, SDKs, and similar technologies. See Section 10 (Cookies and Tracking Technologies) for category-level detail and your choices.

3.3 Information from Third Parties

Verification Services:

• Identity verification results;
• Background check information;
• Accreditation determination letters issued by Third-Party Verifiers;
• Anti-money-laundering (AML) and sanctions screening results.

Financial Services:

• Payment-processor information;
• Banking verification (e.g., Plaid, ACH validators);
• Credit information (only with your consent).

Analytics and Marketing:

• Analytics data from service providers (e.g., Google Analytics);
• Social-media profile information if you connect an account;
• Marketing and advertising interaction data.

4. How We Use Your Information

4.1 Platform Operations

• Create and manage user accounts;
• Facilitate investment transactions on RealtySlices.com;
• Route Verification requests to Third-Party Verifiers and deliver verification letters via VerifyAccredited;
• Process payments and fees;
• Provide customer support;
• Send transactional and service communications.

4.2 Compliance and Security

• Verify identity and prevent fraud;
• Comply with legal, tax, and regulatory requirements (including Securities Act Rule 506(c), GLBA, IRS reporting, AML/BSA, and OFAC sanctions screening);
• Conduct AML/KYC checks;
• Enforce Terms of Use and policies;
• Protect against security threats, intrusion, and abuse.

4.3 Business Purposes

• Analyze and improve Platform functionality;
• Develop new features and services;
• Conduct research and analytics;
• Personalize user experience;
• Send marketing communications, subject to Section 5 and Section 8 and applicable law.

4.4 Investment and Verification Activities

• Connect investors with RealtySlices Offerings;
• Facilitate due-diligence processes;
• Manage investment documentation;
• Provide investment reporting;
• Enable investor–sponsor and investor–verifier communications.

4.5 Use of Sensitive Personal Information

We use Sensitive Personal Information (such as Social Security Numbers and financial account information) only for the purposes for which it was collected, including identity verification, tax reporting, investment processing, fraud prevention, AML/KYC, and legal compliance. We do not use Sensitive Personal Information for inferring characteristics or for behavioral advertising.

5. Marketing Data and the VerifyAccredited Exchange

This section describes the data-for-service arrangement that applies when you use VerifyAccredited.com.

5.1 What You Grant

In exchange for, and as a material condition of, the no-cost Accredited Investor Verification service offered through VerifyAccredited.com, you grant RealtySlices a non-exclusive, worldwide, royalty-free, perpetual (subject to your opt-out rights), transferable license to use your Marketing Data (name, telephone number, and email address only) for the limited purposes set out in Section 5.2.

5.2 How RealtySlices Uses Marketing Data

RealtySlices uses Marketing Data only to:

• Send marketing, promotional, and informational communications about RealtySlices Offerings;
• Communicate with you as an existing or prospective investor in RealtySlices Offerings;
• Conduct investor relations, customer service, suitability outreach, and account servicing;
• Perform internal analytics, segmentation, and product development directly related to RealtySlices Offerings; and
• Comply with legal, regulatory, audit, and recordkeeping requirements.

5.3 What Marketing Data Is NOT

Marketing Data is limited to name, phone, and email. Your Verification Materials and other Sensitive Personal Information are NOT included in the marketing-use license, are NOT used for marketing, and are protected under the additional restrictions described elsewhere in this Privacy Policy and applicable law.

5.4 No Sale; No Third-Party Marketing

RealtySlices does not, and will not, sell, rent, lease, license, or otherwise transfer your Marketing Data to any unaffiliated third party for that third party’s own marketing purposes. Marketing Data may be processed by service providers (e.g., email and SMS platforms, CRM) acting on our behalf under written confidentiality and data-use restrictions, and may be disclosed in the limited circumstances set out in Section 7.

5.5 Opt-Out Effect on Service

You may opt out of marketing communications at any time using the channels in Section 8.5. Because the Marketing Data license is the consideration for free Verification, RealtySlices reserves the right, upon receipt of an opt-out, to (i) charge reasonable fees for any future Verification requests, and/or (ii) decline to provide future Verification at no cost. Existing verification letters remain valid for their stated period.

6. Categories of Personal Information (CCPA/CPRA Disclosure)

In the prior twelve (12) months, we have collected the following categories of personal information, in each case for the business purposes described in Sections 4 and 5:

Category

Examples

Sources

Identifiers

Name, address, email, phone, IP address, account identifiers

You; cookies; service providers

Customer Records (Cal. Civ. Code § 1798.80)

Signature, SSN/TIN, financial account details, identification numbers

You; verification services

Protected classifications

Age (over 18), citizenship/residency for KYC

You

Commercial information

Investment history, Platform engagement

You; the Platform

Internet or network activity

Browsing, clickstream, device and usage data

Cookies; analytics providers

Geolocation (general)

City/region inferred from IP

Automatically

Professional/employment

Sponsor credentials, professional licenses

You; verification services

Inferences

Investor profile, interest categories

Derived internally

Sensitive Personal Information

SSN/TIN, financial account log-ins, government ID

You

7. How We Share Your Information

We do not sell your personal information. We share information only in the circumstances below.

7.1 With Third-Party Verifiers (VerifyAccredited)

When you request Verification, we share your Verification Materials and related communications with the independent Third-Party Verifier assigned to your matter. The Third-Party Verifier is not an agent of RealtySlices; they are bound by their own professional obligations (e.g., AICPA Code of Professional Conduct, state bar rules) and any engagement agreement between you and the verifier.

7.2 With Service Providers

We share information with vetted service providers who assist us under written contracts that restrict use to providing services on our behalf, including:

• Payment processing;
• Identity verification, AML/KYC, and sanctions screening;
• Email, SMS, and other communication platforms;
• Analytics and marketing-automation providers;
• Cloud storage and hosting (e.g., Microsoft Azure);
• Legal, accounting, audit, and professional services.

7.3 With Other Platform Users

• Sponsors on RealtySlices.com can view investor information for their projects in which the investor participates;
• Investors may see limited sponsor information for projects they consider or invest in;
• Forum participants (if applicable) can see names and profile information they choose to display.

7.4 With Affiliates

We may share information among RealtySlices LLC and its current and future affiliates (including the VerifyAccredited DBA) for the purposes described in this Privacy Policy. Affiliates are bound by the same restrictions in this Privacy Policy.

7.5 For Legal Reasons

We may disclose information when reasonably necessary to:

• Comply with applicable laws, regulations, subpoenas, or legal processes;
• Respond to lawful government requests or court orders;
• Protect the rights, property, or safety of RealtySlices, users, or others;
• Prevent or investigate fraud or illegal activity;
• Enforce our agreements and policies.

7.6 Business Transfers

In connection with a merger, acquisition, financing, reorganization, bankruptcy, or sale of assets, your information may be transferred to the successor or acquirer, who will assume the obligations of this Privacy Policy.

7.7 With Your Consent

We may share information for other purposes with your explicit consent.

8. Marketing Communications, CAN-SPAM, and TCPA

8.1 Service vs. Marketing Communications

Service Communications are communications necessary to provide the Services (e.g., delivery of verification letters, account notices, security alerts, transaction confirmations, tax forms, legally required disclosures). You cannot opt out of Service Communications while maintaining an account, except as required by law.

Marketing Communications are commercial messages promoting RealtySlices Offerings or other products and services. Marketing Communications are subject to the channel-specific consent requirements in Sections 8.2–8.4 and may be opted out of at any time.

8.2 Email (CAN-SPAM)

By providing your email address, you consent to receive commercial email from RealtySlices in compliance with the CAN-SPAM Act of 2003 (15 U.S.C. §§ 7701 et seq.). Every commercial email will include a one-click unsubscribe link and our physical mailing address.

8.3 Telephone and SMS (TCPA)

Marketing calls and text messages will be sent only if you provide separate, express prior written consent as required by the Telephone Consumer Protection Act (47 U.S.C. § 227) and the FCC’s implementing rules (47 C.F.R. § 64.1200), including for calls or texts made using an automatic telephone dialing system, an artificial or prerecorded voice, or for marketing purposes. Consent to marketing calls or texts is not a condition of receiving the Services. Standard message-and-data rates may apply.

To stop SMS at any time, reply STOP. For help, reply HELP. To stop marketing calls, follow the instructions in Section 8.5.

8.4 WhatsApp and Other Messaging Channels

Marketing messages on WhatsApp or other messaging platforms will be sent only with your express opt-in consent. Service Communications via these channels may occur with your opt-in for that channel.

8.5 How to Opt Out of Marketing

You may opt out of Marketing Communications at any time by:

• Clicking the “unsubscribe” link in any marketing email;
• Replying STOP to any marketing SMS or WhatsApp message;
• Adjusting communication preferences in the My Profile section of the Platform; or
• Emailing ir@realtyslices.com with the subject line “OPT OUT.”

We will honor opt-out requests within the time required by law (generally ten (10) business days for email under CAN-SPAM, and as soon as reasonably practicable for telephone and SMS).

9. Data Retention

We retain personal information for as long as necessary to provide the Services, comply with legal and tax obligations, resolve disputes, and enforce agreements. General retention periods include:

• Account information: duration of the account plus seven (7) years;
• Investment transaction records: seven (7) years after completion;
• Verification Materials and verification letters: at least five (5) years (consistent with Rule 506(c) recordkeeping practice); Third-Party Verifiers may retain copies for longer under their own professional rules;
• Tax documents: seven (7) years;
• Communications: three (3) years;
• Marketing Data: retained until you opt out or as required by law (subject to suppression-list retention for compliance);
• Backup and audit-log copies: retained on standard backup-rotation and audit schedules and deleted on those schedules.

When personal information is no longer needed, we securely delete, anonymize, or de-identify it.

10. Cookies and Tracking Technologies

We use the following categories of cookies and similar technologies:

• Strictly necessary cookies — required for the Platform to function (e.g., session management, security, load balancing). These cannot be disabled.
• Functional cookies — remember preferences such as language and display settings.
• Analytics cookies — help us understand usage to improve the Platform (e.g., Google Analytics).
• Marketing cookies — used to deliver relevant marketing and measure campaign effectiveness. We do not use these in a way that constitutes a “sale” or “share” of personal information under the CPRA, but you may opt out via the methods below.

10.1 Your Cookie Choices

• Adjust browser settings to refuse or delete cookies (may impair Platform functionality);
• Use a Platform cookie-preferences banner where presented;
• Honor Global Privacy Control (GPC) signals from your browser — we treat valid GPC signals as an opt-out of “sale” and “sharing” for the device or browser sending the signal.

10.2 Do Not Track

The Platform does not currently respond to legacy Do Not Track signals because no industry consensus exists for their interpretation. We do, however, honor GPC signals as described above.

11. Data Security

We implement appropriate technical and organizational measures to protect personal information, including:

• Encryption of sensitive data in transit (TLS) and at rest;
• Secure cloud infrastructure (Microsoft Azure) and data-center controls;
• Role-based access controls, multi-factor authentication, and audit logging;
• Regular vulnerability assessments and penetration testing;
• Employee training on data protection;
• Vendor due-diligence and written data-processing agreements;
• Incident-response procedures, including notifying affected individuals and regulators where required by law.

Despite these measures, no method of transmission or storage is 100% secure. You are responsible for maintaining the security of your account credentials and for promptly notifying us at ir@realtyslices.com if you suspect unauthorized access.

12. Your Privacy Rights and Choices

12.1 Access and Update

You can access and update your account information and preferences in the My Profile section of the Platform or by contacting ir@realtyslices.com.

12.2 Communication Preferences

Marketing Communications are not opted-in by default. Marketing calls and texts require your separate express written consent as described in Section 8. You may opt out of any Marketing Communications at any time using the methods in Section 8.5. Service Communications are necessary for the Services and may continue while you have an account.

12.3 Cookie Choices

See Section 10.

12.4 Deletion

You may request account deletion, subject to legal retention requirements (e.g., Rule 506(c) records, IRS recordkeeping, AML/BSA, and pending transactions). We will confirm receipt and respond within the time required by applicable law.

12.5 Verifying Your Request

To protect your information, we will verify your identity before responding to access, deletion, or correction requests. Verification may require confirming details associated with your account or providing a sworn declaration if you do not have an active account. Authorized agents must provide written permission and proof of identity.

12.6 Appeals

If we deny your request, you may appeal by emailing ir@realtyslices.com with the subject line “PRIVACY APPEAL.” We will respond within the time required by applicable law. If your appeal is denied, you may contact your state attorney general.

13. State-Specific Privacy Rights

13.1 Washington

Washington residents have the right to know what personal data we collect, access and correct it, request deletion (subject to exceptions), and opt out of certain processing. The Washington My Health My Data Act may apply only to limited categories of data we typically do not collect; if it does, we will honor applicable consumer health-data rights. Contact ir@realtyslices.com to exercise these rights.

13.2 California (CCPA/CPRA)

California residents have the rights to:

• Know what personal information is collected, used, disclosed, and shared;
• Access specific pieces of personal information collected in the prior 12 months (or longer where applicable);
• Correct inaccurate personal information;
• Delete personal information, subject to exceptions;
• Limit use and disclosure of Sensitive Personal Information;
• Opt out of “sale” or “sharing” of personal information — we do not sell personal information, and we honor GPC signals as an opt-out of “sharing”;
• Not be subject to discrimination for exercising these rights.

Shine the Light. California residents may request information about personal information disclosed to third parties for their direct marketing purposes. We do not disclose personal information for such purposes.

To exercise rights, email ir@realtyslices.com or call our contact information listed in Section 19.

13.3 Colorado, Connecticut, Virginia, Utah, Oregon, Texas, Montana, Iowa, Delaware, New Hampshire, New Jersey, Nebraska, and Indiana

Depending on your state of residence, you may have rights to access, correct, delete, and obtain a copy of your personal data; to opt out of targeted advertising, sale of personal data, and certain profiling; and the right to appeal denials. We do not sell personal data and do not engage in targeted advertising of the kind regulated by these laws. To exercise rights, contact ir@realtyslices.com. We will respond within the time period required by applicable law (generally 45 days, extendable once for an additional 45 days).

13.4 Nevada

Nevada residents may opt out of the sale of certain covered information by contacting ir@realtyslices.com. We do not sell covered information as defined by Nevada law.

14. Gramm-Leach-Bliley Act (GLBA) Notice

14.1 Information We Collect

Under GLBA, we collect nonpublic personal information about you from:

• Information you provide on applications and forms;
• Information about your transactions with us;
• Information from consumer reporting agencies.

14.2 Information Sharing

We do not sell or share your nonpublic personal information with non-affiliated third parties except:

• To service providers who help us process transactions;
• To Third-Party Verifiers to complete Accredited Investor Verification at your request;
• As permitted or required by law;
• With your consent.

14.3 Protecting Your Information

We maintain physical, electronic, and procedural safeguards under the GLBA Safeguards Rule (16 C.F.R. Part 314) to protect your nonpublic personal information.

14.4 Opting Out

You cannot opt out of certain information sharing necessary for servicing your account or required by law. You may opt out of marketing under Section 8.

15. International Users

15.1 U.S. Operations

The Platform is operated in the United States. If you access the Platform from outside the United States, your information will be transferred to and processed in the United States, which may have different data-protection laws than your jurisdiction.

15.2 European Economic Area, United Kingdom, and Switzerland (GDPR/UK GDPR)

While our Platform primarily serves U.S. users, EEA, UK, and Swiss residents who access the Platform have the following rights, where applicable:

• Access to personal data;
• Rectification of inaccurate data;
• Erasure (“right to be forgotten”), subject to exceptions;
• Restriction of processing;
• Data portability;
• Objection to processing;
• Withdrawal of consent (without affecting prior lawful processing);
• Lodging a complaint with a supervisory authority.

Legal bases for processing include consent, contract performance, compliance with legal obligations, and legitimate interests (e.g., operating and securing the Platform, preventing fraud, and conducting limited marketing of RealtySlices Offerings).

16. CHILDREN’S PRIVACY

The Platform is not intended for individuals under 18 years of age. We do not knowingly collect personal information from children under 13 (in compliance with the Children’s Online Privacy Protection Act, COPPA), and we do not knowingly permit minors under 18 to register for an account. If we learn we have collected information from a child, we will delete it promptly. Parents and guardians who believe their child may have provided information may contact ir@realtyslices.com.

17. Third-Party Links and Services

The Platform may contain links to third-party websites and services, including the websites of Third-Party Verifiers, payment processors, or sponsor projects. We are not responsible for the privacy practices of these third parties. We encourage you to review their privacy policies.

18. Changes to This Privacy Policy

We may update this Privacy Policy periodically. We will notify you of material changes by:

• Posting the updated policy on the Platform;
• Sending email notification to registered users;
• Displaying a prominent notice on the Platform.

The “Effective Date” at the top indicates when the policy was last revised. Material changes will be effective no sooner than thirty (30) days after notice, except where a shorter period is necessary for legal or security reasons.

19. Contact Information

For questions about this Privacy Policy or our privacy practices, contact us at:

RealtySlices LLC

Attn: Privacy Officer

14846 NE 17th Pl

Bellevue, WA 98007

Email: ir@realtyslices.com

VerifyAccredited Privacy: ir@realtyslices.com

Data Security Concerns: ir@realtyslices.com

Phone: +1 425-477-4777

California Residents: ir@realtyslices.com

20. Accessibility

We are committed to ensuring this Privacy Policy is accessible to individuals with disabilities. If you need this policy in an alternative format, contact ir@realtyslices.com.

BY USING THE PLATFORM, YOU ACKNOWLEDGE THAT YOU HAVE READ AND UNDERSTOOD THIS PRIVACY POLICY AND AGREE TO ITS TERMS.