This privacy policy (our “Privacy Policy”) describes our data practices regarding Personal Information (defined below).

 
This Privacy Policy applies to Personal Information collected through our website, located at www.Sandstone Equity.com (the “Site”), or through our mobile apps (collectively, the Site and mobile apps are the “Services.”) This Privacy Policy does not apply to any Personal Information collected by third party websites or apps not operated by Sandstone Equity.


As a financial company, federal law (the Gramm-Leach-Bliley Act, or “GLBA”) also requires us to tell you how we collect, share, and protect your Personal Information. Please see the GLBA Appendix at the end of this Privacy Policy to learn more about how we treat your Personal Information under GLBA.

By accessing the Site and/or using our Services, you are consenting to our use of your Personal
Information in accordance with this Privacy Policy. Further, your access to and use of the Services is subject
to the Sandstone Equity Terms of Use located at https://sandstoneequity.com/terms-of-service/.


Information Sandstone Equity Collects About You



We use the term “Personal Information” to mean any information that could be used to identify you, including your name, address, email address, birth date, financial information, cell or land-line phone number, or any combination of information that could be used to identify you.

What Personal Information we collect from you depends on what Services you choose to use and
how you interact with the Site:


Site Visitors


We have structured our Site so that, as a casual site visitor, you may come to our
Site and review selected information about our Services without registering or providing Personal
Information. However, if you wish to become an Investor, then we require you to provide certain Personal
Information.



Investors

If you choose to access our Services as an Investor, we require that you complete a
registration form. An Investor is an individual who is over the age of 18 and has completed the registration
process on the Site. Our registration forms will specify the information which you must provide in order to
enjoy the particular features to which you wish to subscribe, which may include such items as (i) name; (ii)
email address; (iii) phone number(s); (iv) mailing address; (v) Social Security number (for IRS tax reporting
purposes); (vi) bank account number; and (vii) birth date.

Our registration forms may additionally request information that you may, at your option, choose to provide or withhold. To the extent this additional information constitutes Personal Information, we will treat it in the manner specified in this Privacy Policy. We may require each Investor to provide information designed to verify his or her identity.

This information may include (i) information from a successfully completed electronic check transaction, (ii) a credit report, or (iii) other similar information designed to authenticate and confirm your identity or to otherwise comply with applicable law.

We also require each Investor to provide certain financial information. For example, we require that each Investor also provide Internal Revenue Service Form W-9 data, which includes your Social Security number (or Taxpayer Identification number, where applicable). We also require that Investors provide us with certain account and other payment information, such as information needed to make payments via ACH, wire, or electronic checks. Our registration process for Investors provides additional details on the types of payment information needed.

Users also may choose to upload media files such as videos, photos, text, and other content to the Site to share with Sandstone Equity and other users. When you upload this content, we may also collect metadata associated with these media files including date, time, location and device information. Sandstone Equity’s use of such content will be governed by our user-generated terms and conditions which are provided at the time of collection of such content.



Location Data


We may collect your location information through our mobile apps by capturing the location (e.g. latitude/longitude) of your mobile device. If you have given the app permission to access your location, we may collect your device’s location even if you are not using the Service and store your location history.

  • If you want to opt-out of the collection of your location data, please adjust your settings in your mobile device to restrict the app’s access to your location data. Geolocation data may be used to enhance the Services, for example to offer additional functionality and information regarding your location in connection with the location of Sandstone Equity properties.

  • Automatically-Collected Information. We, our service providers, and marketing partners, may
    automatically log information, such as the type of computer or mobile device accessing our Services,
    interactions over time with our Services, our communications (including emails and alerts), and other online
    services, such as:


  • Device data, such as the computer or mobile device’s operating system type and version,
    manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device
    type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising
    purposes), language settings, mobile device carrier, radio/network information (e.g., WiFi, LTE,
    4G), and general location information such as city, state or geographic area.

  • Online activity data, such as pages or screens viewed, how long was spent on a page or screen,
    browsing history, navigation paths between pages or screens, information about activity on a page
    or screen, access times, and duration of access, and whether marketing emails were opened or
    links within them clicked.


 

We use Google Analytics, a web analytics service provided by Google LLC (“Google”) to help collect and analyze Usage Information.


We use the following tools for automatic data collection:

  • Cookies, which are text files that websites store on a visitor‘s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping navigate between pages efficiently, remembering preferences, enabling functionality, helping us understand user activity and patterns, and facilitating online advertising.

  • Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data, including on devices outside of browsers in connection with specific applications.

  • Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.


How We Use Personal Information

We use your Personal Information for the following business purposes:


  •  to process transactions that you have authorized us to make;

  • to facilitate your activities with respect to our Site;

  • to contact you regarding administrative issues, such as questions about your specific request, or otherwise respond to your comments or requests;

  • to verify and authenticate your identity, to help us ensure that the individuals who use the Site and Services are who they claim to be; to prevent, detect, mitigate, and investigate fraud, security breaches, and potentially prohibited or illegal activities, including, for example, activities prohibited by the Anti-Money Laundering Act;

  • to help us operate our Site;


  • to deliver notices regarding your account;


  • to comply with IRS requirements and for tax reporting purposes;

  • to provide you with information, such as notices of investment opportunities via our Site or updates concerning investments that you have participated in;

  • to send you information we believe is relevant to you, such as news, bulletins, or other information;

  • to enforce this Privacy Policy and our Terms of Use;


  • to conduct user surveys and questionnaires; and


  • to comply with applicable laws


Marketing and advertising. We and our advertising partners may collect and use Personal Information for marketing and advertising purposes, including:


  • Direct marketing. We may from time-to-time send direct marketing communications including, but not limited to, communications about special promotions, offers and events. Recipients may opt out of our marketing communications as described in the “Opt out of marketing communications” section below.


  • Interest-based advertising. We may engage third-party advertising companies and social media companies to display ads promoting our services across the web. These companies may use cookies and similar technologies to collect information about interactions (including the data described above) over time across the Internet and use that information to serve online ads that they think will be of interest. This is called interest-based advertising.


  • We use aggregated information to analyze the effectiveness of our Site, to improve our Services, and for other similar purposes. In addition, from time to time, we may undertake or commission statistical and other summary analyses of the general behavior and characteristics of users participating in our Services and the characteristics of visitors at our Site, and may share aggregated information with third parties, including advertisers. We may collect aggregated information through features of the software that support our Services, through cookies, and through other means described in this Privacy Policy.


  • To enable us to better understand the characteristics of our Investors and/or to provide services tailored to your needs, we may combine the Personal Information an Investor provides with certain automatically-collected information that would not otherwise be personally identifiable. If we combine or link any automatically-collected, non-individually identifiable information with your Personal Information, the resulting combination will be treated as Personal Information under this Privacy Policy.


How We Share Personal Information


We do not disclose your Personal Information to unaffiliated third parties except as provided in this Privacy Policy, as follows:


  • Service Providers. We may share Personal Information with third party companies and individuals that provide services on our behalf or help us operate our Services, such as hosting services, cloud services, information technology services, email communication software, email newsletter services, advertising and marketing services, payment processors, customer relationship management and customer support services, and web analytics services.

  • We may share Personal Information with third party advertising companies for interest-based advertising purposes as described above.


Your Personal Information


May also be one of the transferred assets as part of the transaction or bankruptcy.

For Safety & Security. We may reveal your Personal Information to third parties, including law

enforcement agencies, in order to protect the safety and security of our employees and employees of our

affiliates, users or of any third party.


Feedback, Questionnaires and Surveys


Our Site allows site visitors and Investors to participate in surveys and questionnaires, which from

time to time we may post on the Site. We also encourage our users to provide feedback to us about our

Site and our Services.


You are free to choose whether you participate in these activities. We may ask that,

in addition to providing your responses, you also provide us with your contact information. In these

instances, we use any Personal Information you choose to provide to us in connection with these activities

for the purposes for which you submit the information.


We aggregate information derived from survey and questionnaire information – with your Personal

Information removed – for monitoring or improving the use and appeal of this Site (with no other obligation

to you and, specifically, with no obligation to compensate you for these uses). You are not obligated to

participate in any of these activities.


Links to Other Sites


This privacy statement applies only to Personal Information collected by our Site. Our Site contains
links to other sites that are not owned or controlled by Sandstone Equity. Sandstone Equity is not responsible for the privacy practices of such other sites, and we encourage you to be aware when you leave our Site and to read the privacy statements of each and every web site that collects Personal Information.


Changes to This Privacy Policy


We reserve the right to alter, modify, update, add to, subtract from or otherwise change this Privacy
Policy at any time, which will become effective as of posting on the Site. We encourage you to periodically
review this Privacy Policy to stay informed about how we collect, use, and share Personal Information.


Contact Us


If you have any questions about this Privacy Policy, the practices of our Site or Services, or your
dealings with our Site or Services, please contact us at: info@sandstoneequity.com.

© 2022 Sandstone Equity LLC. All Rights Reserved.

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