Privacy Policy

Privacy Policy for Creative RE Capital Fund
Last Updated: July 2025

Creative RE Capital Fund LLC (“we,” “us,” or “our”) operates https://creativerecapitalfund.com (the “Site”). We respect your privacy and are committed to protecting your personal data. This Privacy Policy explains what information we collect, how we use it, with whom we share it, and your rights.

Information We Collect

1.1 Information You Provide

Contact Details: name, email address, phone number, company, job title

Investment Inquiry Data: accredited-investor status, subscription amounts, documentation uploaded via secure forms

Communications: messages you send us via contact forms, email, or live chat

1.2 Automatically Collected Data

Website Analytics: IP address, browser type, operating system, pages visited, time stamps (via Google Analytics or similar)

Cookies & Tracking: session cookies, persistent cookies, and third-party pixels to remember preferences, improve Site performance, and deliver relevant content

How We Use Your Information

We use your data to:

Respond to Inquiries & Service Requests (e.g., provide documents, answer questions)

Process Subscriptions & Investments under Rule 506(c)

Maintain & Improve the Site: analyze usage patterns, enhance user experience

Send Marketing Communications: newsletters, fund updates, event invitations (you may opt out at any time)

Comply with Legal Obligations: AML/KYC checks, SEC regulations, tax and reporting requirements

Legal Basis for Processing

Consent: when you sign up for newsletters or opt into marketing

Contractual Necessity: to process your investor subscription or service request

Legitimate Interests: to improve our Site and protect our business (e.g., fraud prevention)

Legal Compliance: to satisfy regulatory and reporting obligations

Sharing Your Information

We do not sell your personal data. We may share it with:

Service Providers: fund administrator (Verivest LLC), email platform, analytics providers—all under strict confidentiality agreements

Regulatory Authorities: upon request by SEC, FINRA, or other government bodies

Professional Advisors: legal counsel, auditors, accountants as necessary for fund administration

Acquisition/Restructuring: in the event of a merger, sale, or reorganization—your data remains protected

Cookies & Tracking Technologies

Essential Cookies: required for Site functionality (session management, security)

Performance Cookies: anonymized analytics to understand and improve user experience

Marketing Cookies: deliver relevant content and track marketing campaign effectiveness

You may manage or disable cookies via your browser settings or our Cookie Consent banner.

Data Retention

We retain inquiry & subscription data for as long as necessary to fulfill our contractual and legal obligations (generally 7 years for financial records).

Analytics data is retained in aggregated, anonymized form indefinitely.

Your Rights & Choices

Depending on your jurisdiction, you may have the right to:

Access a copy of your personal data

Correct or update inaccurate data

Delete your data (subject to legal record-keeping requirements)

Restrict or object to certain processing (e.g., direct marketing)

Withdraw Consent at any time for marketing communications

To exercise your rights, please contact [email protected].

Security

We implement industry-standard technical and organizational measures (encryption, firewalls, access controls) to protect your data. However, no method is 100% secure—please notify us immediately of any suspected breach.

International Transfers

If you’re located outside the U.S., your data may be transferred to and processed in the United States. We ensure appropriate safeguards (e.g., standard contractual clauses) to protect your personal information.

Children’s Privacy

Our Site is not intended for individuals under 18. We do not knowingly collect data from minors—if you believe we have, please contact us for deletion.