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This Privacy Policy governs how we collect, store transit and use your personal information when you access and use the Website: https://www.startwithfiveapp.com/  (“the Website”) and or download  our mobile application (the “the Application”), including any content, component, functionality and/or service offered on or through Website or Start with Five App (collectively and together with Website and the Application, the “Platform”) owned or controlled by Start with Five LLC (“Company” or “Start with Five” or “we” or “our” or “us”), as a registered user of the Platform .

 

All reference to “you” or “your”, as applicable, mean a user and/or the Person who accesses, uses and/or participates in Platform in any manner, and such Person’s heirs, assigns, and successors. If you use the Platform on behalf of an entity, “you” or “your,” as applicable, means that entity and its affiliates and their respective directors, officers, employees, and agents.

 

We reserve the right to change this policy at any given time, of which you will be promptly updated. If you want to make sure that you are up to date with the latest changes, we advise you to frequently visit this page.

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Start With Five LLC, is a real estate investing platform involved in acquisition, development, leasing, management and financing of real estate and real estate projects. Start With Five provides the opportunity for investment to US Residents, accredited and non-accredited, on its platform (Mobile Application) under a separate agreement governed by separate terms and conditions outlined in a unique contract between “Us/The Company” and our investors.

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Interpretation and Definitions

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Interpretation

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The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

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Definitions

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For the purposes of this Privacy Policy:

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• Account means a unique account created for You to access our Service or parts of our Service.

• Affiliate means an entity that controls, is controlled by or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.

• Application refers to Start With Five, the software program provided by the Company.

• Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to Start With Five LLC, 51 JFK Parkway, 1st Floor West, Suite 1, Short Hills, NJ 07078.

• Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.

• Country refers to: United States

• Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.

• Personal Data is any information that relates to an identified or identifiable individual.

• Service refers to the Application or the Website or both.

• Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.

• Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

• Website refers to Start With Five, accessible from www.startwithfiveapp.com

• You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

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Investors

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If you choose to access our mobile application 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 mobile application. Our registration forms will specify the information which you must provide in order to enjoy the particular features to which you wish to set up your plan investment, which may include such items as your name, email address, telephone number(s), postal address, social security number (for IRS tax reporting purposes), bank account number, birth date. Our registration forms may additionally request information that you may, at your option, choose to provide. 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; information from a successfully completed electronic check transaction or 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 on the mobile application for Investors provides additional details on the types of payment information needed.

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Collecting and Using of Your Personal Data

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Types of Data Collected

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Personal Data

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Collection of Your Personal Information

 

In order to better provide you with the investment  services (“the Services”) offered on the Platform, Start with Five may collect personally identifiable information, such as your:

 

● First and Last Name

●Date of birth

●Social security number

● Mailing Address

● Email Address

● Phone Number

● Your IP address

● Data profile regarding your online behavior on the Platform.

 

We also collect billing and credit card information. This information is used to complete the transactions conducted on the Platform.

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Usage Data

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Usage Data is collected automatically when using the Service.

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Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

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When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.

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CCPA 

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The parties acknowledge and agree that the Company shall not sell any personal information collected. The Company shall not retain, use or disclose any personal information provided by Customer pursuant to the Agreement except as necessary for the specific purpose of performing the Services for the Customer pursuant to the Agreement, or otherwise as set forth in the Agreement or as permitted by the CCPA. 

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Your California Consumer Privacy Act of 2018 (CCPA) Privacy Rights and Choices

 

California residents may have certain rights under the CCPA, many of which are subject to limitations or exceptions under applicable law:

 

1. Right to Know about Personal Information Collected or “Sold”:

 

You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months. After we receive and confirm your verifiable consumer request, we will disclose to you within the time required by the CCPA, the relevant information, which may include:

 

• The categories of Personal Information we collected about you.

• The categories of sources for the Personal Information we collected about you.

• Our business or commercial purpose for collecting or selling that Personal Information.

• The categories of third parties with whom we share that Personal Information.

• The specific pieces of Personal Information we collected about you (also called a data portability request).

• If we sold your Personal Information, or disclosed your Personal Information for a business purpose, two separate lists disclosing: 
   

a)    sales, identifying the Personal Information categories that each category of recipient purchased; and

b)    Disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.

 

 

California “Shine the Light” Law/Your California Privacy Rights

 

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits consumers, customers or clients who are California residents, to request and obtain from us once a year, free of charge, information about the categories of personal information (as defined in the Shine the Light law), if any, that we disclosed in the preceding calendar year to third parties for those third parties’ direct marketing purposes. Our disclosure requirements apply only if we share our clients’ personal information with third parties for them to directly market their own products to those clients, instead of assisting us with our own business. If you are a California resident and would like to make such a request, contact us here: https://www.startwithfiveapp.com/contact

 

Exercising Your Rights

 

To exercise the rights described above, please submit a verifiable consumer request to us through the web form link provided above.

 

You may only make a verifiable consumer request for access or data portability twice within a 12-month period.

 

The verifiable consumer request must provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative. This means that in making a request you may be required to: provide your email and phone number, client information, and/or account sign-up authentication or other information needed to verify your identity depending on the sensitivity of the Personal Information that is the subject of the request.

 

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. If we are unable to verify your identity, we reserve the right to deny the request. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

 

 

Response Timing and Format

 

We use good faith efforts to respond to a verifiable consumer request within forty-five (45) days after its receipt. If we need more time (up to 90 days), we will inform you of the reason and the needed 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 email.

 

Use of your Personal Information

 

Start with Five collects and uses your personal information to  contact you by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation; to operate the Platform and deliver the Services you have requested;  to manage your Account: to manage your registration as a user of the Service. The Personal Data you provide can give you access to different functionalities of the Service that are available to you as a registered user. Start with Five also collects and uses your personal information for its legitimate business interests (the interest of our business in conducting and managing our business to enable us to give you the best service, the best and most secure experience and to protect our business), for example; to keep its records updated and to study how consumers  use the Services, develop its services, define types of clients or consumers  for its services, keep Start with Five Platform  updated and relevant, develop its business, and inform its marketing strategy.

 

Start with Five may also use your personally identifiable information to inform you of other products or services available from Start with Five and its affiliates.

 

Sharing Information with Third Parties

 

Start with Five does not sell, rent or lease its customer lists to third parties.

Start with Five may, from time to time, contact you on behalf of external business partners about a particular offering that may be of interest to you. In those cases, your unique personally identifiable information (e-mail, name, address, telephone number) is not transferred to the third party. Start with Five may share data with trusted partners to help perform statistical analysis, send you email or postal mail, provide customer support, or arrange for deliveries. All such third parties are prohibited from using your personal information except to provide these services to Start with Five, and they are required to maintain the confidentiality of your information.

 

Start with Five may disclose your personal information, without notice, if required to do so by law or in the good faith belief that such action is necessary to: (a) conform to the edicts of the laws, regulation, order, ordinances, acts or mandates of the United States of America, or any state or municipality thereof or comply with legal process served on Start with Five; (b) protect and defend the rights or property of Start with Five; and/or (c) act under exigent circumstances to protect the personal safety of users of Start with Five, or the public.

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Tracking Technologies and Cookies

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We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Service. The technologies We use may include:

• Cookies or Browser Cookies. A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service. Unless you have adjusted Your browser setting so that it will refuse Cookies, our Service may use Cookies.

• Web Beacons. Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).

Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser. 

We use both Session and Persistent Cookies for the purposes set out below:

• Necessary / Essential Cookies

Type: Session Cookies

Administered by: Us

Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.

• Cookies Policy / Notice Acceptance Cookies

Type: Persistent Cookies

Administered by: Us

Purpose: These Cookies identify if users have accepted the use of cookies on the Website.

• Functionality Cookies

Type: Persistent Cookies

Administered by: Us

Purpose: These Cookies allow us to remember choices You make when You use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Website.

For more information about the cookies we use and your choices regarding cookies, please visit our Cookies Policy or the Cookies section of our Privacy Policy.

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Google Analytics 

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To assist the Company in maintaining and improving this Platform, the Company uses Google Analytics to gather information about usage of the Service. For example, it tracks how many visitors the Service has, which screens they spend time on, what kinds of operating systems and devices they use, and how they found the Service. Google Analytics does not track, collect or upload any data that personally identifies an individual (such as a name, email address, account number or billing information), or other data which can be reasonably linked to such information. The information helps the Company improve the performance of this Service for you. For more information on Google's use of the data, please see the website "How Google uses data when you use our partners' sites or apps" at: https://policies.google.com/technologies/partner-sites?hl=en-US

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Use of Your Personal Data

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The Company may use Personal Data for the following purposes:

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• To provide and maintain our Service, including to monitor the usage of our Service.

• To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.

• For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.

• To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.

• To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.

• To manage Your requests: To attend and manage Your requests to Us.

• For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.

• For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.

We may share Your personal information in the following situations:

• With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of our Service, to contact You.

• For business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.

• With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.

• With business partners: We may share Your information with Our business partners to offer You certain products, services or promotions.

• With other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside.

• With Your consent: We may disclose Your personal information for any other purpose with Your consent.

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Retention of Your Personal Data

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The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

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Transfer of Your Personal Data

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Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

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Delete Your Personal Data

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You have the right to delete or request that We assist in deleting the Personal Data that We have collected about You.

Our Service may give You the ability to delete certain information about You from within the Service.

You may update, amend, or delete Your information at any time by signing in to Your Account, if you have one, and visiting the account settings section that allows you to manage Your personal information. You may also contact Us to request access to, correct, or delete any personal information that You have provided to Us.

Please note, however, that We may need to retain certain information when we have a legal obligation or lawful basis to do so.

 

Disclosure of Your Personal Data

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Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other legal requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

• Comply with a legal obligation

• Protect and defend the rights or property of the Company

• Prevent or investigate possible wrongdoing in connection with the Service

• Protect the personal safety of Users of the Service or the public

• Protect against legal liability

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Feedback, Questionnaires and Surveys.

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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.

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Email Marketing and Correspondence

 

From time to time, Start with Five may contact you via email for the purpose of providing announcements, promotional offers, alerts, confirmations, surveys, and/or other general communication. By accessing the Platform, you consent to the electronic receipt of Start with Five’s marketing material. In order to improve our Services, we may receive a notification when you open an email from Start with Five or click on a link therein.

 

If you would like to stop receiving marketing or promotional communications via email from Start with Five, you may opt out of such communications by clicking on the unsubscribe button.

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Security of Your Personal Data

 

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

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Children's Privacy

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Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.

If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent's consent before We collect and use that information.

 

Links to Other Websites

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Our Service may contain links to other websites that are not operated 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.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

 

Changes to this Privacy Policy

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Changes to this Statement

 

Start with Five reserves the right to change this Privacy Policy from time to time. We will notify you about significant changes in the way we treat personal information by sending a notice to the primary email address specified in your account, by placing a prominent notice on our site, and/or by updating any privacy information on this page. Your continued use of the Services available through the Platform after such modifications will constitute your: (a) acknowledgment of the modified Privacy Policy; and (b) agreement to abide and be bound by that Policy.

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Contact Us

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If you have any questions about this Privacy Policy, You can contact us:

• By visiting this page on our website: https://www.startwithfiveapp.com/contact