Privacy Policy

1. Information we collect

We collect information in three categories:

• Account information — name, email, phone, mailing address, password (stored hashed), and login activity. You provide this when you create an account or update your profile.
• Accreditation and KYC information — documents and attestations submitted through our verification partner VerifyInvestor.com (including income or net-worth documentation, tax forms, identity documents, and entity formation paperwork where applicable) plus the verification status returned to us.
• Investment and payment information — the projects you view, the offers you commit to, electronically signed subscription documents, and limited payment-method metadata (bank-account masked digits, card brand and last four, transaction identifiers). Full payment instrument numbers are handled directly by our PCI-compliant payment processor and are not stored on our servers.
• Technical information — IP address, device and browser identifiers, pages requested, referrers, and timestamps, used to operate the site, secure accounts, and detect fraud.

2. How we use information

• To create and administer your investor account.
• To confirm accredited-investor status under SEC Regulation D (Rule 501) and to fulfill our recordkeeping obligations as the issuer or platform of record for each offering.
• To process investments, distributions, capital calls, transfers, and tax reporting (including issuance of K-1s or 1099s as applicable).
• To meet anti-money-laundering, sanctions screening, and other financial-services compliance requirements.
• To communicate about projects you’ve invested in, account security, and product changes. You can opt out of marketing communications at any time; transactional and legally required notices cannot be suppressed.
• To improve, troubleshoot, and secure the Platform — including detecting abuse, debugging errors, and analyzing aggregate usage.

3. How we share information

We share information only as described here, and never sell it:

• Service providers we rely on to run the Platform — hosting (Railway), accreditation verification (VerifyInvestor.com), payments (Stripe), email and analytics infrastructure, and professional advisors (auditors, counsel, tax preparers) bound by confidentiality.
• Sponsors and counterparties for each project you invest in — limited to what is required to allocate units, pay distributions, and meet the project’s legal obligations.
• Regulators, law enforcement, and courts when required by law, subpoena, or a good-faith determination that disclosure is necessary to protect rights, safety, or the integrity of the Platform.
• Successors in connection with a merger, financing, acquisition, or sale of assets, with notice to you where required by law.

4. Cookies and tracking

We use first-party cookies to keep you signed in, remember session state, and measure aggregate site performance. Most browsers let you control cookies through their settings. Blocking essential cookies will prevent the investor dashboard from working.

5. Data retention

We retain account, investment, and accreditation records for as long as you maintain an account and for the period required by securities, tax, and AML rules thereafter (generally at least five years from your last transaction). Technical logs are kept for a shorter operational window.

6. Security

We protect information with encryption in transit (TLS), encryption at rest for sensitive fields, access controls on production systems, and continuous monitoring. No system is perfectly secure — if we ever experience a breach affecting your personal information we will notify you as required by law.

7. Your choices and rights

You can view and edit your profile information from your dashboard, request a copy of the data we hold on you, ask us to correct inaccuracies, or close your account. Residents of jurisdictions with applicable privacy laws (including California and the EEA/UK) have additional rights under CCPA/CPRA and the GDPR — including the right to access, port, delete, or restrict processing, subject to our legal obligation to retain certain investment records. To exercise any right, contact privacy@freeholdcrowd.com.

8. International transfers

Freehold Crowd is based in the United States and our service providers are primarily US-based. If you use the Platform from outside the United States, you consent to the transfer and processing of your information in the US under US law.

9. Children

The Platform is intended for accredited investors aged 18 or older. We do not knowingly collect information from minors.

10. Changes to this policy

We may update this Privacy Policy from time to time. Material changes will be posted here with a revised “Last updated” date, and we will notify active investors by email where the change affects how their data is used.

11. Contact

Privacy questions: privacy@freeholdcrowd.com. General questions: visit our contact page.