Updated April 4, 2019
Information We Collect
Stanton Road collects personal and financial information from you when you register on the Site. The majority of information is collected during the registration and/or application process and, while some items are optional, most are required for legal or security purposes. You may choose to provide additional information during subsequent visits to the Site, but keep in mind that some of this information will be required if you wish to partake in the Services.
In general, the type of information we collect includes, but is not limited to:
Investor registration and lending applications will require you to provide basic personal data. Such information typically includes your name, email address, home address and phone number, date of birth, social security number and/or tax identification number, employer and job title. Stanton Road uses this data to: (i) enable you to log in to the Site; (ii) establish your ability to view offering materials and to make investments through the Site (for U.S. residents, such ability is restricted to “accredited investors” with a certain level of annual income or net worth); (iii) determine your credibility to partake in lending opportunities; (iv) verify that you are at least 18 years of age; (v) guard against potential fraud; (vi) contact you if there is a problem with your account; and (vii) maintain regular communications with you as may be necessary to inform you of upcoming investment opportunities and other company updates, including SMS communications to users who have opted-in to Stanton Road’s SMS Communications program.
Stanton Road will also gather the names and email addresses of users who contact us through the Site with questions about our company or investment platform. We collect this information for the sole purpose of responding to such inquiries and do not store the contact information unless requested to do so, as in the case of job applicants who submit resumes.
Financial Data for Investors
When you subscribe to make an investment in one of our offerings on the platform, you will again be asked for your personal data. You will also be required to provide financial data, such as your bank routing number and bank account number, to enable us to utilize your bank account to make subsequent investment disbursements to you.
Non-Identifiable Data and Aggregated Personal Data
Stanton Road (or our service providers) may also collect web surfing data related to your use of the Site. Such information may include: your Internet Protocol (IP) address, browser type, and internet service provider (ISP); your operating system; which of our web pages you access and how frequently you access them; referral or exit pages; click stream data; and the dates and times that you visit the Site. This data may be collected using cookies, web beacons, page tags or similar tools. As with cookies, the web surfing information is anonymous, “click stream” transactional data that is not associated with any users as individuals.
Web surfing data and similar information may be aggregated for administrative purposes. Stanton Road may, for example, use this aggregated information in the administration of the Site to improve its usability and to evaluate the success of particular marketing and advertising campaigns, search engine optimization strategies, and other marketing activities. We also use it to help optimize the Site based on the needs of our users.
How and When Your Information Is Shared With Other Parties
Stanton Road does not sell or rent personal information about its users for marketing purposes. We do, however, work with a number of trusted partners who perform vital functions as part of our operations.
Yardi Investor Portal
Yardi Systems, Inc. (“Yardi”), a California corporation, is a provider of high-performance software applications and solutions for the real estate and asset management industries. Yardi’s software is available only in the Yardi Cloud, which includes all of Yardi’s hardware, software, storage, firewalls, intrusion detection devices, load balancing units, switches, and other hardware. Yardi Cloud Services include the installation, maintenance, and service of all of the hardware and software comprising the Yardi Cloud. When using the investor portal that is part of our Site, Users may transmit and enter User data into the Yardi database that is part of the Yardi Cloud. The Yardi investor portal may also allow investors to access published materials such as quarterly reports, distributions notices and funding amounts, K1’s, legal agreements, and other information. The Yardi investor portal sends emails to Users notifying them of new documents that have been uploaded to the Yardi Cloud. The Yardi investor portal also tracks User related information including whether User has made changes to their profile, logged in, or viewed or downloaded documents. The Yardi investor portal also has the ability to restrict access by document type.
We have entered into a Software as a Service Subscription Agreement with Yardi that allows us to have database hosting, software maintenance and upgrades, and server maintenance and management all handled by Yardi so that we can focus on our core business. Yardi will store User data on a virtual database server in the Yardi Cloud. Yardi also reserves the right to locate its virtual servers and other equipment that makes up the Yardi Cloud either at Yardi’s facilities or at the facilities of independent service providers. Yardi may also change the location of the virtual servers and other equipment making up the Yardi Cloud from time to time. Yardi may also aggregate, compile, and use User data in order to improve, develop or enhance the Yardi Cloud Services, provided that no User data is identifiable as originating from, or can be traced back to, a particular User in such aggregated form.
Moreover, in accordance with Yardi’s obligations to credit bureaus, credit reporting agencies, and including Yardi’s obligation to help prevent and detect potentially fraudulent and/or suspicious activity, Yardi may conduct random as well as regular monitoring of Users’ access to and use of the Yardi Cloud Services in order to validate that such use is for legitimate purposes. In addition, we have agreed to cooperate with Yardi in connection with Yardi’s obligations under any laws or regulations concerning the prevention of identity theft, financial fraud, money laundering, terrorist financing, and “know your client” requirements, processes and procedures.
Sharing of Investor Information
Stanton Road also works with (among others) providers of hosting services for the Site, electronic signature providers, and electronic payment service providers. We may engage third parties to help us carry out certain other internal functions such as account processing, client services, or other data collection relevant to our business. Examples of third parties might include those that perform data processing, reporting, tax documentation, custody or escrow services. Information is shared with these third parties only to the extent necessary for us to process the transactions you initiate or perform other specific services, like collections. Our partners are legally required to keep your information private and secure.
We may share your information with law enforcement or other government agencies as required by law or for the purposes of limiting fraud. We reserve the right to disclose your personally identifiable information when we believe that disclosure is necessary to protect our rights or to comply with a judicial proceeding, court order or legal process. We further reserve the right to disclose any of your personal information that we believe, in good faith, appropriate or necessary to take precautions against liability, to investigate and defend against any third-party claims or allegations, to assist government enforcement agencies, to protect the security or integrity of the Site or our services, or to protect the rights, property or personal safety of Stanton Road, its users, issuers, or others.
Notifications and Communications from Our Site
Stanton Road will send you email notifications from time to time. Some notifications are required elements of your transactions on our platform, such as confirmations of particular actions you have taken. These mandatory notices are sent typically to notify you of a change in status. For example, you will receive a notice when you are confirmed as an investor.
We also send out notices that are required for legal or security purposes. For example, certain notifications are sent for your own protection to ensure that another person cannot make a change to your account without your knowledge. In other cases, these notifications involve changes to various legal agreements or Site policies. Generally, you may not opt out of such service-related emails.
When you register as an investor, you will receive emails that confirm specific actions you requested. These will include emails to which you must respond to complete your registration and notifications confirming your registration. Thereafter, you will receive emails when a new investment opportunity is offered, as well as updates concerning the progress of the funding of such offering and/or other relevant information. If you make an investment through the Site, Stanton Road or Yardi Systems will also send you confirmations of the investment as well as occasional updates as to the status of that investment and the timing of distributions relating to that investment.
When you register as an investor and opt-in to Stanton Road’s SMS Communications program, you are consenting to receive text messages sent by an automatic telephone dialing system and acknowledge that data usage charges may apply by your cell phone company. You may receive text messages regarding system notifications, investment opportunity updates, and special offers and promotions, and can manage your opt-in status in your user profile.
We may also send you responses to emails you send us, if appropriate. From time to time, we will also send user surveys, requests for user feedback regarding user experience and Site operations, or marketing offers from us or from us on behalf of our marketing partners. Completing these surveys, answering requests for feedback, or accepting any offer is strictly voluntary. If you do not wish to receive these surveys, user feedback emails, and/or marketing offers, please opt out in any offer email you receive from us.
Where You Can View and Correct Your Information
Links to Other Sites
The Site may be accessed by users located outside the United States. If you choose to use the Service from the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your personal information outside of those regions to the United States, and that by providing your personal information on or through the Site then you consent to that transfer.
We limit access to the personal information we have about you to those employees who have a legitimate business need to access such information. In keeping with industry standards and practices, we maintain appropriate physical, electronic and procedural safeguards and controls to protect your information. The Site is built upon a secure infrastructure with multiple layers of protection, and we use industry-standard encryption technologies to safeguard your information.
Users are required to identify and authenticate themselves prior to accessing sensitive portions of the Site. Generally, identification and authentication take place through the use of your username and a password and/or while logging in with one of our technical support staff.
Notifications of Security Systems Breach
If we learn of a security systems breach, then we may attempt to notify you electronically so that you can take appropriate protective steps. We may also post a notice on or through the Site in the event of a security breach. Depending on where you live, you may have a legal right to receive notice of a security breach in writing.
Take Precautionary Measures
You can take several precautions to protect the security of your computer and personal information. For instance, you can use a well-chosen password and restrict access to your email account. You can also install and regularly update antivirus and firewall software to protect your computer from external attacks by malicious users. When you are finished with a session on the Site, be sure that you log out and close the browser window.
You should also be aware of fraudulent attempts to gain access to your account information through “phishing,” whereby scammers try to bring unsuspecting people to a website by using a genuine-looking email purporting to be from a legitimate company. Sometimes, either in the email itself or on this fake site, scammers will ask for login information to gain access to people’s accounts and withdraw their money.
Stanton Road will never send you an email asking you for your login information. In general, you can protect yourself against phishing by never providing personal or login information via a link contained in an email; instead, go the website directly. You might also make it a habit to check the URL of a website to be sure that it begins with the correct domain. In the case of Stanton Road, you should always ensure the URL begins with https://www.stantonroadcapital.com.
California Consumer Protection Act of 2018
California residents and California consumers (collectively referred to herein as “consumers”) have special rights under the California Consumer Protection Act of 2018 (the “CCPA”). This section provides a brief overview of certain of those rights and our obligations in connection therewith. The rights listed herein below do not apply to parties who are not California residents or California consumers.
Businesses that Collect Consumer’s Personal Information
A consumer shall have the right to request that Stanton Road, as a business that collects consumers personal information, disclose to that consumer the categories and specific pieces of personal information the business has collected. Stanton Road that collects a consumer’s personal information shall, at or before the point of collection, inform consumers as to the categories of personal information to be collected and the purposes for which the categories of personal information shall be used. Stanton Road shall not collect additional categories of personal information or use personal information collected for additional purposes without providing the consumer with notice consistent with this section. Stanton Road shall provide the information collected to a consumer only upon receipt of a verifiable consumer request. Stanton Road that receives a verifiable consumer request from a consumer to access personal information shall promptly take steps to disclose and deliver, free of charge to the consumer, the personal information collected. The information may be delivered to the consumer by mail or electronically, and if provided electronically, the information shall be in a portable and, to the extent technically feasible, in a readily useable format that allows the consumer to transmit this information to another entity without hindrance. Stanton Road may provide personal information to a consumer at any time, but shall not be required to provide personal information to a consumer more than twice in a 12-month period. Stanton Road shall not be required to retain any personal information collected for a single, one-time transaction, if such information is not sold or retained by Stanton Road or to reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information.
Right to Request Deletion
A consumer shall have the right to request that Stanton Road delete any personal information about the consumer which Stanton Road has collected from the consumer. If Stanton Road receives a verifiable request from a consumer to delete the consumer’s personal information, then Stanton Road shall delete the consumer’s personal information from its records and direct any service providers to delete the consumer’s personal information from their records. Stanton Road or a Stanton Road service provider shall not be required to comply with a consumer’s request to delete the consumer’s personal information if it is necessary for Stanton Road or the service provider to maintain the consumer’s personal information in order to:
(1) Complete the transaction for which the personal information was collected, provide a good or service requested by the consumer, or reasonably anticipated within the context of Stanton Road’s (or the service provider’s) ongoing business relationship with the consumer, or otherwise perform a contract between Stanton Road (or the service provider) and the consumer.
(2) Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity.
(3) Debug to identify and repair errors that impair existing intended functionality.
(4) Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law.
(5) Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code.
(6) Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when Stanton Road’s (or the service provider’s) deletion of the information is likely to render impossible or seriously impair the achievement of such research, if the consumer has provided informed consent.
(7) To enable solely internal uses that are reasonably aligned with the expectations of the consumer based on the consumer’s relationship with Stanton Road or the service provider.
(8) Comply with a legal obligation.
(9) Otherwise use the consumer’s personal information, internally, in a lawful manner that is compatible with the context in which the consumer provided the information.
Right to Disclosure from Businesses that Collect Personal Information
A consumer shall have the right to request that Stanton Road disclose to the consumer the following:
(1) The categories of personal information it has collected about that consumer.
(2) The categories of sources from which the personal information is collected.
(3) The business or commercial purpose for collecting or selling personal information.
(4) The categories of third parties with whom the business shares personal information.
(5) The specific pieces of personal information it has collected about that consumer.
Upon receipt of a verifiable request from the consumer, Stanton Road shall disclose to the consumer the information specified in items (1) through (5) above and collected by Stanton Road. To identify the consumer and ensure that the request is verifiable, we may associate the information provided by the consumer in the request to any personal information previously collected by us about the consumer. In addition, we may identify by category or categories the personal information collected by Stanton Road about the consumer in the preceding 12 months by making reference to the enumerated category or categories of information described in items (1) through (5) above that most closely describes the personal information collected. However, Stanton Road is not required to retain any personal information about a consumer collected for a single one-time transaction if, in the ordinary course of business, that information about the consumer is not retained. Moreover, Stanton Road is not required to reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information.
Right to Disclosure from a Business that Discloses for a “Business Purpose”
Stanton Road does not sell any of consumer’s personal information. However, Stanton Road may from time to time disclose consumer’s personal information for a “business purpose,” as such term is defined under the CCPA. Under the CCPA, “business purpose” means the use of personal information for the business’ or a service provider’s operational purposes, or other notified purposes, provided that the use of personal information shall be reasonably necessary and proportionate to achieve the operational purpose for which the personal information was collected or processed or for another operational purpose that is compatible with the context in which the personal information was collected. Business purposes are:
(1) Auditing related to a current interaction with the consumer and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.
(2) Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
(3) Debugging to identify and repair errors that impair existing intended functionality.
(4) Short-term, transient use, provided the personal information that is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction.
(5) Performing services on behalf of the business or service provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider.
(6) Undertaking internal research for technological development and demonstration.
(7) Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business.
A consumer shall have the right to request that a business that sells the consumer’s personal information, or a business that discloses it for a business purpose, disclose to that consumer:
(1) The categories of personal information that the business collected about the consumer.
(2) The categories of personal information that the business sold about the consumer and the categories of third parties to whom the personal information was sold, by category or categories of personal information for each third party to whom the personal information was sold.
(3) The categories of personal information that the business disclosed about the consumer for a business purpose.
A business that sells personal information about a consumer, or that discloses a consumer’s personal information for a business purpose, shall disclose the information specified in items (1) through (3) above to the consumer upon receipt of a verifiable request from the consumer.
A business that sells consumers’ personal information, or that discloses consumers’ personal information for a business purpose, shall disclose:
(1) The category or categories of consumers’ personal information it has sold, or if the business has not sold consumers’ personal information, it shall disclose that fact.
(2) The category or categories of consumers’ personal information it has disclosed for a business purpose, or if the business has not disclosed the consumers’ personal information for a business purpose, it shall disclose that fact.
A third party shall not sell personal information about a consumer that has been sold to the third party by a business unless the consumer has received explicit notice and is provided an opportunity to exercise the right to opt out pursuant to the CCPA.
Right Not to be Discriminated Against
Stanton Road shall not discriminate against a consumer because the consumer exercised any of the consumer’s rights under the CCPA, including, but not limited to, by:
(A) Denying goods or services to the consumer.
(B) Charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties.
(C) Providing a different level or quality of goods or services to the consumer, if the consumer exercises the consumer’s rights under this title.
(D) Suggesting that the consumer will receive a different price or rate for goods or services or a different level or quality of goods or services.
Nothing in the CCPA prohibits Stanton Road from charging a consumer a different price or rate, or from providing a different level or quality of goods or services to the consumer, if that difference is reasonably related to the value provided to the consumer by the consumer’s data. Stanton Road may offer financial incentives, including payments to consumers as compensation, for the collection of personal information, the sale of personal information, or the deletion of personal information. Stanton Road may also offer a different price, rate, level, or quality of goods or services to the consumer if that price or difference is directly related to the value provided to the consumer by the consumer’s data. If Stanton Road offers any financial incentives related to collection, sale, or deletion of personal information, it shall notify consumers of such financial incentives. Stanton Road may enter a consumer into a financial incentive program only if the consumer gives Stanton Road prior opt-in consent in accordance with the CCPA, which consent clearly describes the material terms of the financial incentive program, and which may be revoked by the consumer at any time. Stanton Road shall not use financial incentive practices that are unjust, unreasonable, coercive, or usurious in nature.
Consumer Communications With Stanton Road
In order to comply with the CCPA in a form that is reasonably accessible to consumers Stanton Road has made available to consumers two designated methods for submitting requests for information required to be disclosed under the CCPA including a telephone number and a Web site address. Consumers may contact Stanton Road at the following number 1-310-427-3066, at the following Web site address: www.stantonroadcapital.com, and at the following email address: email@example.com.
Stanton Road shall disclose and deliver the required information to a consumer free of charge within forty-five (45) days after receiving a verifiable request from the consumer. Stanton Road shall promptly take steps to determine whether the request is a verifiable request, but this shall not extend the business’s duty to disclose and deliver the information within forty-five (45) days of receipt of the consumer’s request. The time period to provide the required information may be extended once by an additional forty-five (45) days when reasonably necessary, provided the consumer is provided notice of the extension within the first 45-day period. The disclosure shall cover the 12-month period preceding Stanton Road’s receipt of the verifiable request and shall be made in writing and delivered through the consumer’s account with Stanton Road, if the consumer maintains an account with Stanton Road, or by mail or electronically at the consumer’s option if the consumer does not maintain an account with Stanton Road, in a readily useable format that allows the consumer to transmit this information from one entity to another entity without hindrance. Stanton Road shall not require the consumer to create an account with Stanton Road in order to make a verifiable request.
As a business that collects personal information about consumers, Stanton Road shall do the following in order to verify consumer identity and comply with the CCPA: To identify the consumer, associate the information provided by the consumer in the verifiable request to any personal information previously collected by the business about the consumer. In addition, Stanton Road shall identify by category or categories the personal information collected about the consumer in the preceding 12 months by reference to the enumerated category or categories of information outlined in the CCPA that most closely describes the personal information collected.
As a business that may disclose personal information for a business purpose, Stanton Road shall do the following in order to verify consumer identity and comply with the CCPA disclosure requirements:
(A) Identify the consumer and associate the information provided by the consumer in the verifiable request to any personal information previously collected by the business about the consumer.
(B) Identify by category or categories the personal information of the consumer that the business sold in the preceding 12 months by reference to the enumerated category of personal information that most closely describes the personal information, and provide the categories of third parties to whom the consumer’s personal information was sold in the preceding 12 months by reference to the enumerated category or categories of personal information that most closely describes the personal information sold. Stanton Road shall disclose the information in a list that is separate from a list generated for the purposes of subparagraph (C) below.
(C) Identify by category or categories the personal information of the consumer that the business disclosed for a business purpose in the preceding 12 months by reference to the enumerated category or categories under the CCPA that most closely describes the personal information, and provide the categories of third parties to whom the consumer’s personal information was disclosed for a business purpose in the preceding 12 months by reference to the enumerated category or categories under the CCPA that most closely describes the personal information disclosed. Stanton Road shall disclose the information in a list that is separate from a list generated for the purposes of subparagraph (B) above.
Stanton Road is not obligated to provide the information requested by the consumer and required by CCPA to the same consumer more than twice in a 12-month period.
The obligations imposed on Stanton Road by the CCPA shall not restrict Stanton Road’s ability to:
(1) Comply with federal, state, or local laws.
(2) Comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, or local authorities.
(3) Cooperate with law enforcement agencies concerning conduct or activity that the business, service provider, or third party reasonably and in good faith believes may violate federal, state, or local law.
(4) Exercise or defend legal claims.
(5) Collect, use, retain, sell, or disclose consumer information that is deidentified or in the aggregate consumer information.
(6) Collect or sell a consumer’s personal information if every aspect of that commercial conduct takes place wholly outside of California.
Certain of the obligations imposed on Stanton Road by the CCPA in connection with disclosure of information to verified consumers, shall not apply where compliance by Stanton would violate an evidentiary privilege under California law and shall not prevent Stanton from providing the personal information of a consumer to a person covered by an evidentiary privilege under California law as part of a privileged communication. The CCPA shall not apply to protected or health information that is collected by a covered entity governed by the Confidentiality of Medical Information Act (Part 2.6 (commencing with Section 56 of Division 1)) or governed by the privacy, security, and breach notification rules issued by the federal Department of Health and Human Services, Parts 160 and 164 of Title 45 of the Code of Federal Regulations, established pursuant to the Health Insurance Portability and Availability Act of 1996. The CCPA shall not apply to the sale of personal information to or from a consumer reporting agency if that information is to be reported in, or used to generate, a consumer report as defined by subdivision (d) of Section 1681a of Title 15 of the United States Code, and use of that information is limited by the federal Fair Credit Reporting Act (15 U.S.C. Sec. 1681 et seq.). The CCPA shall not apply to personal information collected, processed, sold, or disclosed pursuant to the federal Gramm-Leach-Bliley Act (Public Law 106-102), and implementing regulations, if it is in conflict with that law. The CCPA shall not apply to personal information collected, processed, sold, or disclosed pursuant to the Driver’s Privacy Protection Act of 1994 (18 U.S.C. Sec. 2721 et seq.), if it is in conflict with that act.
Notwithstanding Stanton Road’s obligations to respond to and honor consumer rights requests pursuant to the CCPA, a time period for Stanton Road to respond to any verified consumer request may be extended by up to ninety (90) additional days where necessary, taking into account the complexity and number of the requests. Stanton Road shall inform the consumer of any such extension within forty-five (45) days of receipt of the request, together with the reasons for the delay. If Stanton Road does not take action on the request of a consumer under the CCPA, Stanton Road shall inform the consumer, without delay and at the latest within the time period permitted of response by the CCPA, of the reasons for not taking action and any rights the consumer may have to appeal the decision to the business. If requests from a consumer are manifestly unfounded or excessive, in particular because of their repetitive character, Stanton Road may either charge a reasonable fee, taking into account the administrative costs of providing the information or communication or taking the action requested, or refuse to act on the request and notify the consumer of the reason for refusing the request. Stanton Road shall bear the burden of demonstrating that any verified consumer request is manifestly unfounded or excessive. The CCPA does not require that Stanton Road reidentify or otherwise link information that is not maintained in a manner that would be considered personal information.