We do not collect any sensitive personal data as defined by the applicable laws and we do not draw inferences from your personal information to build your consumer profile.

You represent that all personal information you share with reAlpha is correct and you obtained prior authorization to share any third-party personal information with reAlpha (e.g., joint subscriber personal information).

We also use cookies and similar internet technologies to automatically collect information as you use our Website or App. See Cookie Collection and E-mail Marketing.

Automated Online Data Collection

We (and our third-party service providers) may place cookies, web beacons, scripts, and similar tracking technologies and device identifiers on your web browser or mobile device when you visit our Website or App. (In this Privacy Policy we use the term “cookies” to refer generally to cookies, tracking technologies, and other device identifiers.) You can use the settings or tools offered on your browser to refuse or deny cookies, or to delete cookies that have already been stored. (See “Cookie Collection and E-mail Marketing” below.)

Log in and identification: To recognize and verify you and your device when you log in to access your account and use our Website or App by storing data including, for example, your password, device and browser type, Internet Service Provider (ISP) and Internet Protocol (IP) addresses), device and browser identifiers and information (including device, application, or browser type, version, plug-in type and version, operating system, and other technical data).

Features and performance: To provide functionality for the features and options you select to use on our Website or App; deliver consistent performance; recognize and implement your preferences; and enable information sharing with third-party providers.

Location: If you visit our Website or App using a mobile device, we obtain geolocation data from device sensors, GPS signals, WiFi access points, and cell towers, unless you disable location information in your device setting. We can also more generally identify your location through IP address or mobile device identifier.

Data analytics: Track and log web usage data about your interactions with our Website or App and online activities including, for example, browsing history, usage rates, settings preferences, content interactions (including searches, page views, downloads, and prints), and user journey history (including clickstreams and page navigation, URLs, timestamps, content viewed or searched for, page interactions, and similar data related to your use of the Services).

Advertising: Cookies used for advertising purposes may be set through our Website or the App by us or our advertising partners. We and our advertising partners may use cookies to build a profile of your interests and show you relevant advertisements on our Website or App and on other websites and mobile applications. Advertising cookies do not store directly personal information, but store data that may uniquely identify your browser and internet device. If you do not allow these cookies, you will still receive advertisements, but they will be less targeted specifically to you.

Email Interconnectivity: If you receive email from us, we use internet tools to capture data related to when you open our message and click on any links or banners it contained. We use this information to track the effectiveness of our communications with you.
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3. HOW REALPHA USES YOUR INFORMATION

In addition to the purposes listed in the table above, we may use the information we collect about you:

• Provide our Services, including authorizing a purchase, or completing a transaction that you requested;
• Create and manage online accounts;
• Communicate about, and administer participation in, special events, promotions, programs, offers, surveys, contests and market research;
• Operate, evaluate and improve our business (including developing, enhancing, analyzing and improving our Services; managing our communications; reviewing and processing employment applications, performing data and statistical analytics; and performing accounting, auditing and other internal functions);
• Provide technical support;
• Protect against, identify and prevent fraud and other unlawful activity, claims and other liabilities;
• Comply with and enforce applicable legal requirements, relevant industry standards, contractual obligations and our terms of service and other policies; 
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4. HOW REALPHA SHARES YOUR INFORMATION

reAlpha does not sell your personal information to third parties or share personal information for monetary or other consideration. To assist us in providing our services and offerings, reAlpha may share some of your personal information with third parties and your personal information may be accessible to third parties in connection with services they provide to us, including the following:

Third-Party Service Providers: We share information, including certain personal information, with our third-party service providers that we use to: process authentication and log-in information; provide hosting for and maintenance of our Website or App, e-mail marketing, solicit investors, scheduling meetings, backup, storage, payment processing, analytics and other services for us. These third-party service providers may have access to or process your personal information for the purposes of providing these services for us. We do not permit our third-party service providers to use the personal information that we share with them for their own commercial purposes.

Analytics: We may collect, and we may engage third-party analytics providers to collect, metrics and information regarding your use of the Website or App, including evaluating how visitors use our Website or App (“Usage Data”) to develop new features, improve existing features or inform sales and marketing strategies. When we process Usage Data, any personal information is anonymized. 

Advertising and Marketing: We may use third-party advertising companies to serve advertisements on our Website and App and on selected websites and mobile applications operated by others. These companies may set their own cookies or use similar web technologies to collect information about your online and mobile device activities over time and across different websites. These companies then may direct advertisements to you based on your interests as suggested by the history of your visits to our Website, App and other websites or mobile applications.

Affiliates: We may share information, including personal information, with companies affiliated with reAlpha, and they will use that information only for the purposes that are consistent with those described in this Privacy Policy.

Our business partners: With our third-party clients or business partners, such as realtors, landlords, and other professionals to facilitate your transactions, and other third parties for their own commercial or marketing purposes, such as to serve targeted advertisements.

Legal or Regulatory Purposes: We share information with governmental and regulatory entities as necessary to fulfill our legal obligations. We will disclose information to the Security Exchange Commission as required under applicable law.
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5. COOKIE COLLECTION AND E-MAIL MARKETING

Restricting Online Data Collection. By using the Services, you consent to the processing of personal information by both reAlpha and our analytics services provider. You can restrict how cookies are used to track and log data about your visits to our Website and other websites. Note that if you restrict the use of cookies some of the features on our Services may not be fully functional.

Opting Out of Marketing Communications. You can opt-out of receiving marketing communications from us by going to claire@realpha.com and providing the names/email address that you would like removed from our marketing databases and added to our ‘Do Not Contact’ list” or by following the unsubscribe instructions included in our marketing communications. 

You can stop receiving promotional e-mails at any time by clicking on the “unsubscribe” link at the bottom of any promotional e-mail that you receive from us.

You can opt-out of receiving text messages from us by replying “STOP” to the text message you receive from us. Please note that this will only opt you out of the specific text messaging program associated with that number. 
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6. HOW YOU CAN RESTRICT COOKIES AND ADVERTISING

Company does not publish third-party personalized advertisements on the Website or within the App nor do we publish personalized advertisements on other companies’ websites. Cookies enable the Company to measure and analyze the visits to the Website and App and collect data on the activities of users of Services. We use Google Analytics and/or other third-party data analytics services to place the cookies, track Website and App usage data, and provide reports to us. The Company does not disclose any directly identifying personal information to a third-party data analytics service. However, the service may monitor a user’s visits to the Website and App and combine this data with data from other websites monitored by the same service provider and then use the aggregated findings for its own commercial purposes. The service provider may have means of correlating data from our Website to an identifiable individual, in which case the processing of personal information will be the responsibility of the service provider.

By using the Services, you consent to the processing of your personal information by both the Company and our analytics services providers, including Google Analytics. You can restrict how cookies and other internet technologies are used to track and log data about your computer and mobile device usage of our Services by managing the preference settings on your browser or device. You can learn how Google collects data on its partner sites and how to restrict that data collection at here.

Note that if you restrict the use of cookies some of the features on our Services may not be fully functional. The controls you may be able to use include:

• Communicating directly with third-parties that we authorize to collect data on our Website or App as explained at:
• Google
• Facebook
• Twitter
• Purchasing a utility from an independent software provider that you install on your computer browsers to limit tracking of your browsing activity.

Do Not Track (DNT) is an optional browser setting that is used by some website operators and third parties. Our Services do not respond to DNT signals.

Social Media

Our Services include social media features which will redirect you to third-party social media companies. These third-party social media companies may collect your internet protocol (IP) address, which page you were visiting on the Website, and the social media platform may set a cookie to recognize you and enable the feature to function properly. Social media features and widgets are either hosted by the third-party social media company or hosted directly on the Website. Your interactions with these features are governed by the privacy practices of the third-party social media companies that provide them. This Privacy Policy applies solely to information under our control. Company is not responsible for the privacy practices of the social media platforms you use in connection with our Services. Company is not responsible for the privacy practices of social media platforms. We recommend that you review their privacy policies and practices.
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7. HOW TO ACCESS AND MANAGE YOUR PERSONAL INFORMATION

You have certain rights regarding your personal information. To request access to the personal information we maintain about you or to ask us to stop processing your personal information, including for direct marketing and promotional purposes, please contact us at claire@realpha.com. You can update or correct your online account information by logging into your account at the customer portal on our Services.

Your Privacy Rights 

Some states have enacted privacy laws that provide consumers with specific rights regarding their personal information. The scope of your rights may vary depending on which state you reside. This section generally describes your rights and explains how to exercise those rights.

• Right To Know What Information We Collect, With Whom We Share Your Information, And The Right To Data Portability – You may request that we disclose to you the categories of personal information we collect about you, the categories of sources from which we collected that personal information, the categories of personal information we sold or disclosed, our business or commercial purposes for collecting and selling such personal information, the categories of third parties with whom we shared such personal information, and the specific pieces of personal information we collected about you over the past 12 months. 

• Right To Request Deletion Of Your Information – You may request we delete some or all of the personal information we maintain about you, subject to certain exceptions. If we cannot delete all of your personal information, we will give you a reason why we cannot do so. Note that some personal data may be retained as permitted by law (e.g. to comply with legal obligations, to prevent fraud, etc.).  
• Opt-out of “Sale”/ “Sharing” of Your Personal Information ––We do not currently consider the ways we shared consumer personal information in the past 12 months to comprise the “sale” of personal information. For purposes of this Privacy Policy, “sell” means the sale of your personal information to an outside party for monetary or other valuable consideration or sharing personal information for cross context behavioral advertising, subject to certain exceptions in applicable privacy laws. 
• Right to Correct Inaccurate Personal Information. Taking into account the nature of the personal information and the purposes of the processing, this right provides an individual with the ability to seek to correct or update personal data that individual considers that we hold about that individual.
• Right to Limit Use of Sensitive Information. This right is limited to sensitive personal information used for the purpose of inferring characteristics about an individual. We do not collect sensitive personal information, nor do we use sensitive personal information for the purpose of inferring characteristics about an individual, therefore we do not offer a path to exercise this right.
• Right of Non-Discrimination and Non-Retaliation. We will not discriminate against you because you made any of these requests. 
• Shine the Light. California's “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Services that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an e-mail to claire@realpha.com or write us at: Attn: Legal Department, 6515 Longshore Loop Suite 100, Dublin, OH 43017.

• Right to opt out of the processing of your personal data for the purposes of targeted advertising and for profiling in furtherance of decisions, including, solely automated decisions that produce legal or similarly significant effects.
• Right to appeal any decision or indecision related to the exercise of any right the consumer is granted under the applicable state law.
• Right to access. You have the right to confirm whether or not we are processing your personal information and access such personal information. Please note that this right might be subject to certain limitations. 

How To Exercise My Rights

If you would like to exercise any of these rights please contact us: 

• Calling us at +1 707-732-5742
• Emailing us at claire@realpha.com

We may deny certain requests, or fulfill a request only in part, based on our legal rights and obligations. 

Your request must:

• Provide sufficient information for us to reasonably verify that you are the person about whom we collected personal information or an authorized representative of such person; and
• Describe your request with sufficient detail for us to properly understand, evaluate, and respond to it.

If you wish to submit a verifiable consumer request on behalf of another individual, we will also need sufficient information to verify that the individual is the person about whom we collected personal information and that you are authorized to submit the request on their behalf. For requests to know, access, correct or delete personal information, we may ask you to provide sufficient evidence to show that you have provided the authorized agent signed permission to act on your behalf, verified your own identity directly with us pursuant to the instructions set forth in this Privacy Policy, and directly confirmed with us that you provided the authorized agent permission to submit the request on your behalf.

Authorized Agent. You may designate an authorized agent to submit a request on your behalf to access or delete your personal information. To do so, you must: (1) provide that authorized agent written and signed permission to submit such request; and (2) verify your own identity directly with us. Please note, we may deny a request from an authorized agent that does not submit proof that they have been authorized by you to act on your behalf.

Response timing and format

We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please contact us at claire@realpha.com.

We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. 

Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
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8. PROTECTION AND RETENTION OF PERSONAL INFORMATION

reAlpha maintains administrative, technical, and physical safeguards to protect the security, confidentiality, and integrity of Investor Information appropriate to the nature of the Investor Information we collect. While the measures we implement are intended to reduce the likelihood of security problems, we cannot guarantee that these measures will prevent unauthorized access to your Investor Information. In particular, information transmitted over the Internet may be beyond the control of reAlpha, and you are advised that such transmission may not be secure.

We will retain your personal information as long as we provide services to you, as necessary to comply with our legal obligations, resolve any disputes, and enforce our agreements.

Our Services permit you to register an account. When you do you will be prompted to create a password. You are responsible for maintaining the confidentiality of your password, and you are responsible for any access to or use of your account by someone else who has obtained your password, even if that person was not authorized by you. You should notify us of any unauthorized use of your password or account, and, if any unauthorized use is suspected, you should immediately reset your password.

If you have reason to believe that your interaction with us is no longer secure or your security has been compromised, you must immediately notify us of the problem by contacting us. See “How to Contact Us” below
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9. LINKS TO THIRD PARTY WEBSITES

Our Services may contain links to other sites that are not operate or owned by us. If you click on a third-party link, you will be directed to that third-party’s site. We strongly advise you to review the Privacy Policy of every site you visit.

In you participated in any of our offerings, DealMaker shares your information with us pursuant to its Privacy Policy which can be found here. Per DealMaker’s Privacy Policy, we only receive Investor Information or any other information when authorized by you as described in the relevant portion of the application or agreement between you and DealMaker. DealMaker only shares information with us when you decide to invest through our offerings. Your registration and eligibility to use or access DealMaker’s products and offerings is independent from our products, services or offerings.

We have no control over, and assume no responsibility for the content, services, products, privacy policies or practices of any third-party sites, services or providers.
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10. CHANGES TO THIS PRIVACY POLICY

We reserve the right to make changes to this Privacy Policy at any time. Upon making a material change to the way we collect, use, or share your personal information, we will provide you notice on the Website. Your continued use of the Services after a change to this Privacy Policy constitutes your consent to be bound by the revised Privacy Policy. We encourage you to periodically review this page for the latest information on our privacy practices.
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11. INFORMATION FOR INTERNATIONAL INVESTORS

reAlpha operates under United States laws and regulations. If you reside or are located in a different country, the data protection and privacy laws of that country may differ from the laws of the United States in the way in which your personal information is protected. We want you to understand that when you provide your personal information to us, or engage in a transaction with us, you are giving your consent to (1) the transfer of your personal information outside of your country of residence, and (2) the processing of your information in accordance with the laws of the United States and the guidelines of this Privacy Policy. If you are resident in the European Economic Area, the United Kingdom, or Switzerland, we will process your information in order to fulfill your requests and to otherwise pursue our legitimate business interests as described in this Privacy Policy. If you are resident in a country that provides specific rights regarding the processing or disposition of personal information, we will make commercially reasonable efforts to accommodate your request to exercise such rights.
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12. INFORMATION ABOUT MINORS

We do not intentionally collect personal information from individuals who we have reason to believe are under the age of 18. If we learn that we collected any personal information of children under the age of 18 we will immediately delete such information and the corresponding account.  If you become aware of any personal information we have collected from individuals under age 18, please contact us at support@realpha.com.

Additional Information for EEA and EU Residents:
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13. LEGAL BASIS FOR PROCESSING PERSONAL INFORMATION 

Under European data protection law, we can only use certain personal information if we have an appropriate reason for doing so. We rely on various legal bases to process your personal information, including:

• Consent. You may have consented to the use of your personal information, for example to send you electronic marketing communications or for the use of certain cookies. Consent can be withdrawn at any time. This will not affect the lawfulness of the processing before you withdrew your consent.
• Contract. We need your personal information to provide you with our Services, to complete your requested transactions, and to respond to your inquiries. 
• Legal. We may also process your personal information when necessary to protect your or another individual’s vital interests. We may use your personal information as reasonably necessary to assess and ensure compliance with applicable laws, legal requirements, and company policies; to protect our assets or to investigate or defend against any claims of illegality or wrongdoing (including to obtain legal advice or to establish, exercise or defend legal rights); and in response to a court order or judicial or other government subpoena or warrant.
• Legitimate Interest. We or a third party have a legitimate interest in using your personal information, such as preventing fraud or promoting our events and programs. We only rely on this legal basis when such legitimate interests are not overridden by your interests or your fundamental rights and freedoms.
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14. YOUR RIGHTS AND CHOICES UNDER THE GDPR 

As provided under applicable law and subject to any limitations in such law, you have the following rights:

• Access. You may ask us to provide you with a copy of the personal information we maintain about you, including a machine-readable copy of the personal information that you have directly provided to us, and request certain information about its processing. 

• Rectification. You may ask us to update and correct inaccuracies in your personal information. You also may ask us to complete information you believe is incomplete.

• Erasure. You may ask to have your personal information anonymized or deleted, under certain conditions.

• Restrict Processing. You may request that we restrict the processing of your personal information, under certain conditions.

• Object to Processing. You may object to processing of your personal information, under certain conditions.

• Data Portability. You may request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.

• Consent Withdrawal. You may withdraw any consent you previously provided to us regarding the processing of your personal information at any time and free of charge. We will apply your preferences going forward. This will not affect the lawfulness of the processing before you withdrew your consent.

• Right Not to Be Subject to Automated Individual Decision-Making. You have the right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you. 

International transfers

To provide the Services, we may transfer your personal information outside of the country in which it was collected and where the level of protection of personal information may be different than in your country. Personal information may be transferred to United States of America, and countries in the European Economic Area (“EEA”). If we do so, we will comply with applicable data protection laws, in particular by relying on an EU Commission adequacy decision, on contractual protections for the transfer of your Personal Data, or on another approved derogation for a specific situation, such as your explicit consent. For more information about how we transfer Personal Data internationally, or to obtain a copy of the safeguards we use for such transfers, please contact us as specified below.

How to Contact the Appropriate Authority

We hope that we can resolve any query or concern you raise about our use of your personal information. If you are an EEA or EU resident and wish to report a complaint or if you feel that we have not addressed your concern in a satisfactory manner, you have the right under the GDPR to lodge a complaint with a supervisory authority, including in your country of residence, place of work, or where you believe an incident took place. The EU Commission has a list of supervisory authorities here:  http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.
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15. HOW TO CONTACT US

If you have any questions or complaints regarding this Privacy Policy or about reAlpha’s privacy practices, please contact us at If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your information described here your choices and rights regarding such use, or wish to exercise your rights, please do not hesitate to contact us at:

Phone: +1 707-732-5742

Website: www.realpha.com 

Email: claire@realpha.com

Postal Address: 

6515 Longshore Loop Suite 100, Dublin, OH 43017

Attn: Michael Logozzo, President, COO & Interim CFO

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If you need to access this Policy in an alternative format due to having a disability, please contact claire@realpha.com and 216-230-5793.

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